CHAPTER 4 

 

 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-1

4.0 ENVIRONMENTAL CONSEQUENCES 

This chapter discusses the potential environmental consequences, or impacts, associated with 

the proposed alternatives as required by DO-12. The analysis includes considerations of context, 

intensity, duration, and timing of each alternative, and predicts the degree of change from the 

baseline existing conditions to identify potential impacts on the following resource areas: 

• Socio-economics, including land use and property ownership, visitor experience, 

planning control and policies and community facilities; 

• Cultural resources, including historic and visual resources; 

• Transportation systems, including vehicular traffic and parking, public and Georgetown 

University transit service, pedestrian and bicycle facilities, and river navigation and use; 

• Physical and biological resources, including water resources, geology, soils and 

topography, terrestrial and aquatic vegetation and wildlife, and noise; 

• Utilities and infrastructure, including stormwater drainage and management, and urban 

systems. 

The discussion of potential impacts includes those impacts that may occur as a direct result of 

the proposed alternatives, or as an indirect result that could occur later in time or farther in 

distance than the action. In addition, this chapter also addresses cumulative impacts on each 

resource, which could result from, “the incremental impact of the action when added to other 

past, present, and reasonable foreseeable future actions regardless of what agency undertakes 

such other actions” (Council on Environmental Quality’s regulations 40 CFR Section 1508.7). 

 

4.1 SOCIO-ECONOMIC IMPACTS 

4.1.1 Land Use and Property Ownership 

Land use impacts are generated by physical changes to a site area and by induced changes to the 

surrounding land areas. This section evaluates the potential direct and indirect impacts to the 

land use patterns, as well as the relationship of the proposed alternatives to the regulatory 

environment and applicable planning policies. 

Alternatives A, B and C 

Land Use

Finalization of the preliminary land exchange agreement would allow for zoning of the site and 

subsequent action under Alternatives A, B and C. Under Alternatives A, B and C, a boathouse 

would be constructed on Tract 102-114 within the C&O Canal NHP. While the land use would 

remain recreational, the construction of a boathouse would change the use from public open 

space to a private collegiate rowing use (with public access to the river). 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-2

Although the proposed boathouse is a more intensive recreational use of the site, it would not be 

inconsistent with surrounding recreational uses. Beginning at the Georgetown Waterfront Park 

and continuing up the shoreline to Jack’s Boathouse, the Washington Canoe Club (WCC), and 

the Potomac Boat Club (PBC), recreational uses dominate the waterfront. This location as a 

private boathouse use would be consistent with the land immediately to the east, at WCC, which 

is a private facility operated on public land through a special use permit. This use is also 

consistent with historic recreational uses constructed along this section of the Potomac during 

the 19th and 20th centuries (documented in Section 3.2.1). 

Because construction of the boathouse on Tract 102-114 is dependent upon the exchange of land 

between NPS and Georgetown University, the proposed actions under Alternatives A, B and C 

would result in the addition of Tract 102-109 to federally controlled open space. The long-term 

preservation of Tract 102-109 would result in positive impacts to land uses upstream of the site. 

The size of both land tracts is approximately equal and would result in no net loss of public open 

space. In addition, the land exchange would result in Georgetown University relinquishing a 

one-mile right-of-way easement that it currently retains along the CCT between the two parcels. 

Since the proposed boathouse is conditional on a one-for-one land exchange resulting in no net 

loss of public recreational land, the land use impacts of Alternatives A, B and C are judged 

minimal. A precedent has already been established (at the boathouse at Fletcher’s Cove and 

WCC, for example) for allowing a privately-run recreational use on public parkland along the 

Potomac River. Further, the reduction in outdoor boat storage at TBC resulting from 

construction of this facility would contribute to enhancing the Georgetown Waterfront Park for 

NPS and the public at-large. 

Property Ownership

Construction of the proposed boathouse on Tract 102-114 is contingent upon an approved land 

exchange between NPS and Georgetown University. The construction of a new facility would 

require transfer of ownership of Tract 102-114 to Georgetown University and 102-109 to the NPS 

according to the conditions set forth in the Preliminary Land Exchange Agreement, and the 

corresponding Environmental Assessment, Finding of No Significant Impact, and Section 106 

Memorandum of Agreement based on acceptance of all conditions by the approval authorities 

involved. 

The exchange of lands would result in a shift from public ownership of Tract 102-114 to private 

ownership. This transfer would ensure that Tract 102-109 remains as open space under NPS 

control. This exchange of land would eliminate the potential for development of this land within 

the Park. It would also result in extinguishing the right-of-way over the CCT between the two 

parcels that Georgetown University currently owns in conjunction with its ownership of Tract 

102-109. 

Tract 102-114 would only be allowed to develop as a boathouse location. Thus, although the 

property would become private, the NPS will hold a scenic easement over it restricting its design 

and use in perpetuity. The NPS holds approximately 1,500 acres of scenic easements in the rest 

of the C&O Canal NHP. 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-3

DC WASA currently has an easement across the project site as a result of the construction of the 

Potomac Interceptor Sewer line in 1969. The existing easement was granted to DC WASA in 

1967 by Permit No. 6:850:73. If the land exchange between NPS and Georgetown University 

takes place and the boathouse is constructed, DC WASA would maintain access to the 

interceptor sewer line through an easement agreement with Georgetown University. The 

agreement would allow DC WASA to maintain “continued operation, maintenance, repair, 

replacement, inspection and removal of the existing Upper Potomac Interceptor Relief Sewer 

located beneath the surface of Tract 102-114.”1

Through the course of this study, it was determined that the sewer line easement was incorrectly 

recorded on maps filed by DC WASA at the District of Columbia’s Department of Public Works. 

Prior to executing the land exchange and as part of the construction permitting process, the 

error in recording the sewer line easement would be rectified through an updated survey (See 

Appendix for a preliminary survey). 

Also, the adjacent WCC would be affected by the construction and operation of the boathouse 

alternatives since relocation of the fence adjacent to the CCT would be required during 

construction and since WCC is also using a portion of Tract 102-114 for boat and other outdoor 

storage. As this is a private facility on NPS property, NPS would be required to negotiate any 

changes with WCC as part of the subsequent boathouse approval and permitting process. 

Mitigation

Because of the changes in ownership resulting from the exchange of land, multiple parties would 

be affected through this real estate transaction. These effects were also addressed in the 

previous Land Exchange EA conducted by NPS. If approved, the NPS would be required to 

negotiate all arrangements with DC WASA or WCC and any other parties involved to minimize 

disruption and to properly record the real estate documents involved in this transaction. 

No Action Alternative 

Under the No Action Alternative, there would be no impact to land use or property ownership 

(assuming there would be no land exchange). The use of the project site would continue as 

passive open space. The land would remain undeveloped but would not serve as a continuation 

of recreational uses identified in the Georgetown Waterfront Park Plan. The No Action 

Alternative would invalidate the Preliminary Land Exchange Agreement and Tract 102-114 

would remain federal property. Georgetown University would retain control of Tract 102-109, 

along with the right-of-way along the CCT for the nearly one mile distance between the two 

parcels. Under private ownership, Tract 102-109 would be left open for potential development 

of a boathouse or other uses, in accordance with the C-M-1 zoning and other land use 

regulations applicable to the parcel. 

 

1

 Preliminary Agreement to Exchange Real Property. Signatories- Georgetown University Vice President and Treasurer and 

Regional Director, National capital Region, NPS. October 1998. 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-4

4.1.2 Visitor Experience 

 

Alternatives A, B and C 

Alternatives A, B and C would result in the establishment of a boathouse, as well as site 

improvements at the project site. Along the C&O Canal, the experience of running, hiking, 

biking, or boating would remain predominantly unchanged for hikers, runners, or bicyclists 

using the towpath or the canal for recreational activity as the towpath itself would remain 

unaltered. However, under all three alternatives, the boathouse would restrict views of the river 

from the section of the towpath adjacent to the site (described and illustrated in more detail in 

Section 4.2.2 below). Therefore, for recreational users of the towpath, there would be some loss 

of these views of the river that are currently available. Because of the site’s location, their 

experience of pursuing recreation in an environment that includes the historic canal, 

intermittent views of the river, and roadway structures or buildings in Georgetown, however, 

would remain similar to existing conditions. 

For visitors involved in cultural interpretation, there would be a change in the visual setting of 

the canal in the vicinity of the project area under each of the three alternatives. Under 

Alternative A, the setting would change more than the other two alternatives, because of its 

larger size. Under each alternative, the change in the visual setting of the canal due to the 

construction of a boathouse would be localized to the area adjacent to the structure. Since the 

change would be localized and visitors would continue to have similar opportunities upriver to 

experience the canal, the impact on a visitor’s experience under each alternative is considered 

minor. Additional discussion regarding visual impacts is provided later in Section 4.2.2. 

Along the CCT, visitors would be directly affected by construction of the boathouse because of 

its proximity to the trail. Once the boathouse is constructed, views from the CCT will be 

obstructed when biking or walking along the trail adjacent to the new building. While a similar 

condition exists as the CCT passes the WCC, under Alternatives A, B or C visitors would 

experience a two story building in an area where they currently experience a natural 

environment. Further, while visitor use of the trail would continue similar to existing 

conditions, there would be occasional periods when movement is restricted due to a trailer, or 

service vehicle, turning into or out of the turnaround area (see Section 4.3.1). Therefore, the 

proposed boathouse under each of the alternatives would result in an overall moderate impact 

on visitor experience along the CCT. These impacts are discussed further in Sections 4.1.4, 4.2.2 

and 4.3.1, below. 

Mitigation

Public access to the river and waterfront would be maintained under Alternatives A, B and C. To 

minimize impacts to park visitation, Georgetown University would ensure public access to the 

site is maintained when operating the facility. In addition, any interference or impacts to trail use 

would be minimized as much as possible both during the construction period and afterwards 

when the facility is in use. The boathouse building would be designed to maximize windows 

and other fenestrations aimed to reduce the effect of creating a solid wall adjacent to the CCT. 

 

 

 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-5

No Action Alternative 

 

Under the No Action Alternative, a boathouse would not be constructed and there would be no 

improvements at the project site. Therefore, visitor experience in the area would remain 

unchanged. However, potential development of the upstream site for a boathouse or other uses 

and access to that site along the University’s one-mile right-of-way concurrent with the CCT 

could impact the use of the trail. 

 

4.1.3 Planning Controls and Policies 

 

Alternatives A, B and C 

Non-motorized Boating in the Potomac and Anacostia Rivers – Washington, D.C.

The Non-motorized Boating in the Potomac and Anacostia Rivers Study (1985 and subsequent 

updates in 1989 and 2000) identified an increased need and unmet demand for additional nonmotorized boating facilities in the vicinity of Key Bridge. The study explored several sites along 

the waterfront for the placement of new facilities on both rivers, including the site west of WCC, 

described as follows: 

 “This site lies just west of the Washington Canoe Club at the west end of the 

Georgetown waterfront plan’s zone 14, and encompasses almost one half acres. It could 

comfortably accommodate an average-sized (6,000- to 8,000- square foot) building. For 

the public to get to the site, a new road providing emergency access and a drop-off point 

must be part of the package as well as new utility connections and avoidance of 

construction over the Upper Potomac Interceptor Sewer.”2

The 2000 Supplemental Report identified the potential for a one-acre site at this location and 

for a 15,000 square foot boathouse (in accordance with the Section 106 MOA). Action under 

Alternatives A, B and C would result in meeting one of the main recommendations of the study 

(and the updates) of constructing additional boathouses, which would benefit the rowing 

community. The construction of a new boathouse for Georgetown University would add 

indoor storage space for rowing shells along the Georgetown waterfront and would make space 

available at TBC for other programs including high schools and individual rowers. 

The proposed boathouse under Alternatives A, B and C would be larger in size than the 

recommended size for a boathouse at the proposed site in the 1985 and 1989 Non-Motorized 

Boating studies. However, neither study included the full one acre site as identified in the Land 

Exchange EA; they were prepared without detailed knowledge of the requirements of a 

collegiate rowing facility; and they did not anticipate that a boathouse could be constructed over 

the interceptor sewer. Alternatives A and C are larger in size than recommended in the 2000 

Supplemental Report. However, both alternatives (and Alternative B) would fulfill the 

recommendation to provide more indoor facilities to service the unmet demand for crew and 

other non-motorized recreational activities along the Potomac River. 

 

2

 Nonmotorized Boating in the Potomac and Anacostia Rivers, Washington D.C., NPS, 1989.
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-6

Georgetown Waterfront Park Plan

For approximately 20 years, it has been the goal of NPS to encourage water-oriented recreation 

through the construction of non-motorized boathouses along the Potomac, in the vicinity of 

Key Bridge. Under Alternatives A, B and C, a boathouse would be constructed in the area 

identified by both the NPS and the Georgetown Waterfront Park Plan as a designated boathouse 

zone. Under Alternatives A (Zoning Alternative) and C (Preferred Alternative), the 

westernmost edge of the facility would extend approximately 1,175 feet west of Key Bridge 

(approximately 75 feet more than the 1,100 feet identified in the plan). (This estimate is based on 

GIS data and may need to be verified through surveying of the site.) Under Alternative B (MOA 

Alternative), the westernmost edge of the building would extend approximately 1,162 feet west of 

Key Bridge (approximately 62 feet more than the 1,100 feet identified in the plan). 

A new boathouse under Alternatives A, B and C would be consistent with the plan’s goal of 

clustering boathouses within a non-motorized boathouse zone and extending the wateroriented recreational component of the Georgetown Waterfront Park Plan. In further 

agreement with the objectives of the Waterfront Plan, the land area upstream of the boathouse 

zone would remain undeveloped in order to preserve the natural appearance of the Palisades. 

 

Finding of No Significant Impact (FONSI) and Environmental Assessment for the Proposed 

Exchange of Properties between the NPS and Georgetown University within the District of 

Columbia and within the Boundary of Potomac Palisades Park within the C&O Canal NHP

Under Alternatives A, B and C, the exchange of land between National Park Service and 

Georgetown University would be completed and the proposed boathouse constructed on Tract 

102-114. The Land Exchange EA concluded that there would be no significant impacts as a result 

of this transaction. The EA determined that the project would not negatively affect the 

waterfront area, the Georgetown Waterfront Park Plan, or the C&O Canal NHP. NCPC 

approved the land exchange contingent upon completion of the NHPA Section 106 process.3

 

The Preliminary Land Exchange Agreement described the boathouse zone boundary limitation 

as follows: 

“The boathouse may be situated more than 1,155 feet west of Key Bridge so long as no 

portion of the boathouse structure(s) is located beyond a point 1,250 feet west of Key Bridge. 

In the event the University proposes siting the boathouse or any portion thereof within the 

space between 1,155 feet to 1,250 feet west of Key Bridge, the United States will seek and 

obtain the concurrence of the National Capital Planning Commission and the Commission 

of Fine Arts prior to issuing a final determination as to an approved site for the boathouse.”4

Based on available mapping data, the proposed boathouse facility extends 1,175 feet upriver from 

Key Bridge under Alternative A (Zoning Alternative) and C (Preferred Alternative) and 1,162 feet 

upriver from the bridge under Alternative B (MOA Alternative). Since the boathouse would be 

located within the specified 1,155 to 1,250 distance from Key Bridge, the University will need to 

 

3

 September 5, 1995 NCPC Meeting. 4

Preliminary Agreement to Exchange Real Property. Signatories – Office of University Counsel and Regional Director, National 

Capital Region, NPS. October 1998.
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-7

obtain final approval of the proposed building from the CFA, and the NPS will consult with 

NCPC through this EA process. 

Comprehensive Plan for the National Capital

The project site is currently under Federal ownership and not subject to District of Columbia 

zoning controls. Following implementation of the land exchange, the site would change from 

unzoned to W-O (Waterfront Open Space), as approved in Zoning Case No. 02-42. The 

alteration to the W-O District for the property introduces the potential for improvements to the 

area, allowing for construction of the boathouse. This Action would help carry out the goals of 

the Comprehensive Plan for the National Capital, particularly the Federal and District Elements 

discussed in Section 3.1.2. 

The Federal Element for Parks and Open Space has identified a weakness of the area as being a 

lack of accessibility and the poor condition of local parks, specifically the Georgetown 

waterfront area. Under Alternatives A, B and C, the construction of a new recreational facility 

along the Georgetown waterfront would encourage greater use of the parks and open space in 

the area by allowing a new collegiate rowing use along the river and subsequently providing 

more space at TBC for high schools and other programs and individuals on the waiting list for 

this facility. Further, finalization of the land exchange would help “retain the palisades and 

gorges of rivers and streams in their natural state” through the acquisition of a private parcel 

(Tract 102-109) currently not under NPS ownership, as recommended by the Parks and Open 

Space Element. 

Ward 2’s objectives specify the need for non-motorized boating facilities along the Georgetown 

waterfront, west of the Washington Harbour complex, to meet the increasing demand for nonmotorized boating in the area. Approval and construction of the proposed boathouse under 

Alternatives A, B and C would meet Ward 2’s objectives, as stated in their waterfront 

development element of the District of Columbia Comprehensive Plan. 

Washington, D.C. Zoning

Contingent upon finalization of the land exchange agreement, the project site would be 

regulated under the waterfront zoning district, W-O. The W-O District was created to provide a 

“low-density alternative to previously existing waterfront zones and to minimize negative 

environmental, physical, and visual impacts of development along the Potomac and Anacostia 

waterfronts.”5

 Special exceptions and a variance have already been granted to allow for the 

construction of a boathouse on this land, to remove parking requirements, and to allow for a 

decreased setback distance. A boathouse would introduce a water-oriented recreational use to 

this area, in accordance with the intentions of the W-O District. 

The W-O District applies building and lot use restrictions to the proposed boathouse. Under 

these restrictions, a structure on this site would be subject to a FAR of 0.75, maximum height of 

40 feet as measured from finished grade to the ceiling of the uppermost story, lot occupancy of 

50%, and a 12-foot side yard. 

 

5

Zoning Commission for the District of Columbia, Notice of Final Rulemaking, Z.C. Order 02-30 (Georgetown University 

Boathouse -- Map Amendment, Special Exception, Variance).
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-8

Under Alternative A (Zoning Alternative), the boathouse facility would result in a FAR of 0.71, 

would have a maximum building height of 50’- 8”6

 (40 feet as measured from the finished grade 

to the ceiling of the exercise room, in accordance with D.C. zoning regulations), and the lot 

occupancy would be 39%, within the requirements of the W-O zone. All setback requirements 

would be met, except the distance from mean high water level would be 15 feet, which was 

approved as part of a requested variance for this property. 

Under Alternative B (MOA Alternative), the boathouse facility would result in a FAR of 0.55, a 

total building height of 39’-8”, and a lot occupancy of 32%, all within the requirements of the WO zone. The distance from mean high water level would be 15 feet as for Alternative A; the 

sideyard setbacks would be slightly greater for this alternative and well within the zoning 

requirements. 

Under Alternative C (Preferred Alternative), the boathouse facility would have the same FAR, 

lot occupancy and setbacks as Alternative A but would be 36’-6” in total height (to the ridge of 

the central wing) and under the D.C. building height requirements as defined by zoning. 

NHPA Section 106 Memorandum of Agreement (MOA)

Action under Alternative A (Zoning Alternative) does not comply with the stipulations 

contained in the 1997 NHPA Section 106 MOA. The 18,862 square foot footprint would be larger 

than 15,000 square foot size that was identified in this document. Also, the height of the 

boathouse of 50’-8” (measured from the finished grade to the ridge of the central portion of the 

boathouse) would be taller than the agreed height of 40 feet above grade as stated in the MOA. 

Therefore, to construct a boathouse under Alternative A, a new or revised MOA would be 

required. 

Action under Alternative B (MOA Alternative), where the boathouse would have a footprint of 

less than 15,000 square feet and a height that would be less than 40 feet above grade, would meet 

the stipulations contained in the MOA. A new or revised MOA would not be required for this 

alternative. 

Action under Alternative C (Preferred Alternative) partially complies with the MOA since it 

meets the height requirements (36’-6” above grade) specified in this document. However, like 

Alternative A, a new or revised MOA would be required from the appropriate review parties that 

allows the proposed footprint (18,862 square feet) included in this alternative. 

Mitigation

The proposed boathouse under Alternatives A, B or C would extend slightly further west of Key 

Bridge than the approximately 1,100 feet identified in the Georgetown Waterfront Park Plan, a 

condition that is allowed under the Preliminary Exchange Agreement. In accordance with the 

agreement, the University will obtain final approval of the proposed building from the CFA, and 

 

6

 Under Alternative A, the building would stand 50’-8”’ tall; however, zoning regulations restrict height based on measurement of

height from finished grade to the ceiling of the uppermost story of the building. Applying D.C. zoning height measurement 

procedures results in a building height of 40 feet, within the W-O zoning regulations.
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-9

the NPS will consult with NCPC through this EA process, to locate a boathouse between 1,155 

feet to 1,250 feet west of Key Bridge. 

In accordance with the Preliminary Land Exchange Agreement, Georgetown University will be 

required to maintain the open space connection to the rest of the waterfront area. In an effort to 

preserve the continuity of recreational open space and maintain public access to the waterfront, 

fences or other boundary defining structures would not be permitted on the land. In addition, 

all boat storage would be indoors. Georgetown University would also comply with any other 

requirements resulting from subsequent agency review for all of the alternatives and the revised 

MOA for Alternatives A and C to minimize impacts as appropriate. 

 

No Action Alternative 

 

Under the No Action Alternative, the land use for Tract 102-114 and surrounding area would 

remain the same. The land would remain undeveloped and would not be subject to the Land 

Exchange Agreement between the National Park Service and Georgetown University. The land 

would remain under Federal ownership and would not be subject to Washington, D.C. zoning 

controls. However, since there would be no progress toward supporting the goals of the Federal 

or District Elements of the Comprehensive Plan for the National Capital, the Georgetown 

Waterfront Park Plan, or the Non-motorized Boating in the Potomac and Anacostia Rivers 

Study, there would be an adverse impact to the existing planning policies in effect for this part of 

the Georgetown waterfront. 

Also under the No Action Alternative, Tract 102-109 would remain privately-owned land under 

C-M-1 zoning (Commercial and Light Manufacturing Zone) and would be available for 

development by the University, subject to any required public and agency review and approvals. 

Also, the right-of-way easement that Georgetown University currently controls along the CCT 

(from the beginning of the trail in Georgetown to Tract 102-109) would remain available for 

future use by Georgetown University. If that site is developed, it would be contrary to NPS’s 

goals of precluding this wooded, prime wetland site from development and acquiring and 

extinguishing the University’s right-of-way along the CCT, as identified in the FONSI for the 

1995 Land Exchange EA. 

 

4.1.4 Community Facilities 

Alternatives A, B and C 

Allowing Georgetown University to construct their own facility would allow the team to vacate 

space within the TBC, making room for other high school and college boat storage. 

Georgetown University is the largest crew program currently using TBC. Moving the 

University’s training site upstream would also reduce the boat congestion on the docks at TBC, 

as well as in that section of the river. 

The existing crew facilities (TBC and PBC) consist of approximately 45,370 square feet of indoor 

storage space with a total of 12 indoor boat storage bays. The construction of a new facility 

under Alternatives A (Zoning Alternative) and C (Preferred Alternative) would add 

approximately 8,700 square feet of boat storage space, while Alternative B (MOA Alternative) 

would add approximately 7,400 square feet of space. Georgetown University currently stores 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-10

their ergometers and other training equipment in a room on the second floor of TBC. Moving 

Georgetown University out of this facility would provide this space to other users at TBC. Also, 

as identified in Chapter 2, the proposed boathouse facility would be used for a summer rowing 

program for high school aged youth, providing a potential benefit to the area’s rowing 

community. 

Under Alternatives A, B and C, the CCT would be widened. The widening would provide space 

for emergency, trailer and service vehicles to access the boathouse and a turnaround area at the 

western end of the property. The trail area would be widened first and the CCT would be 

temporarily shifted to the north so it can be kept open for biking and other trail use during the 

construction period (see Section 4.3.1). After construction of the boathouse, the CCT would be 

re-striped at its current location. The plans for access in and out of the proposed boathouse, and 

any resulting effects, are further discussed in the transportation section (Section 4.3.1) below. 

 

Mitigation

To accommodate this proposed new use north of Key Bridge and to reduce any potential river 

use conflicts, the Potomac River Safety Committee should meet to agree upon and update its 

training and river use guidelines. Georgetown University should take the lead in organizing this 

meeting with all parties on the Committee. This is also addressed in Section 4.3.4. 

Georgetown University will take all precautions during construction and operation of the 

boathouse to ensure that there is minimum interference with the CCT use (described in more 

detail in Section 4.3.1 below). Coordination with NPS would be required to minimize any 

impacts to the CCT both during construction and operation of the facility. 

No Action Alternative 

Under the No Action Alternative, the University would not construct a boathouse and the need 

for additional boating facilities would continue. Thus, the current shortage of recreational 

boating space would continue for the foreseeable future, unless the University constructs a 

boathouse on the upstream site. However, if the upstream site is developed, the University’s 

right-of-way concurrent with the CCT would be utilized to access the site, potentially resulting 

in impacts to trail users. 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-11

4.2 CULTURAL RESOURCES IMPACTS 

4.2.1 Historic Resources 

Potential impacts to historic properties are characterized as either direct or indirect impacts. 

The physical displacement or demolition of a resource would be a direct impact; changes in use, 

operation or character of the resource could be direct or indirect; and changes to the visual 

context or historic setting of the resource would be indirect impacts. The following criteria 

were used in determination of potential impacts on historic resources that would result from the 

proposed alternatives (40 CFR 1508.7-1508.8): 

• No Impact occurs when the proposed action does not displace or demolish the historic 

resources; does not change the use, operation, or historic character of the resources; and 

does not affect the historic setting or visual context of the resources. 

• Minor Impact occurs when the proposed action is visible or present within the visual 

context of the resources without interfering with the historic setting of the resources. 

• Moderate Impact occurs when the proposed action results in a change in the use, 

operation, or historic character of the resources; results in a change in use that is 

incompatible with the historic use of the resources; substantially disrupts the normal 

operation of the resources; or substantially diminishes the historic character of the 

resources through physical alteration of, or visual intrusion on, the resources. 

• Major Impact occurs when the proposed action is severely adverse and highly 

noticeable within the historic context of the resources, and interferes with the historic 

setting of the resources. 

• Positive Impact occurs when the proposed action improves the use, operation, or 

historic character of the resources; and/or improves the visual context of the historic 

setting of the resources. 

No historic structures are located on the project site. Consequently, the proposed boathouse 

would not result in the demolition or physical alteration of any historic structures. The project 

site is located within three recognized historic areas: the National Register- and National 

Landmark-listed Georgetown Historic District; the National Register-listed Chesapeake and 

Ohio Canal National Historical Park; and the D.C.-listed Potomac Gorge. All of the abovementioned areas are potentially affected resources within the project site. Effects of the 

proposed boathouse on historic resources are related to the changes to the historic context and 

setting, resulting in indirect impacts. The assessment has been completed in two study areas: 

resources along the Georgetown waterfront, and resources on the Georgetown University 

campus. 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-12

Alternatives A, B and C

 

Historic Districts and Individual Landmarks Impacts- Study Area

 

Chesapeake & Ohio Canal National Historical Park 

The project site is located within the Chesapeake and Ohio Canal National Historical Park. This 

area includes the land that borders the canal, and the area south of the canal to the Potomac 

River. The C&O Canal and towpath are located to the north of the proposed project site on an 

embankment. The proposed boathouse would be directly visible from the C&O Canal and 

towpath under all three alternatives. However, the addition of a boathouse on the proposed 

location would not negatively affect the historic setting of the C&O Canal since it would be 

consistent with the existing urban views of Georgetown already present along the canal in this 

area. Historically, the C&O Canal was an area of bustling activity. Georgetown was one of the 

many “canal towns,” or urban environments located along the canal in contrast to the otherwise 

natural surroundings. The banks of the canal were considered a prime location to locate a 

business; many sought out this location for the power source and access the canal provided. 

The CCT is located directly adjacent to the proposed project site. Prior to its current use as a 

hiking and biking trail, the land served as a rail line for the Georgetown Branch of the former B 

& O Railroad. Historic photographs reveal that development, including boathouses, existed 

along the B&O tracks in proximity to the proposed project location (see Photographs 3-3 and 3-

5). The CCT alignment would remain intact in the proposed project area as discussed under 

Section 4.3.1 below. The overall result of the proposed construction under Alternatives A, B and 

C would have a minor impact on these resources. However, because action under Alternative A 

(Zoning Alternative) would result in a larger boathouse in its footprint and height than what is 

proposed in Alternatives B (MOA Alternative) and C (Preferred Alternative), action under 

Alternative A is judged to have the most impact, with actions under Alternatives B and C 

anticipated to result in lesser impacts on historic resources associated with the C&O Canal 

NHP. 

Old Georgetown Historic District 

 

The project site is located within the Old Georgetown Historic District. As a result of its 

location relative to the proposed boathouse, the majority of the historic district would be 

shielded from impacts resulting from the proposed action. The project site is at a lower 

elevation than Georgetown University and the more residential components of the Old 

Georgetown Historic District. Also, the Georgetown waterfront has experienced a dynamic 

history as an industrial center and a successful harbor. A boathouse, in particular, would be 

consistent with the type of development that has historically been, and currently is, present 

along the waterfront. Additionally, the design and materials of all three boathouses are 

proposed to be architecturally compatible with the Georgetown Historic District. Therefore, 

action under Alternatives A, B and C would have no impact on the Old Georgetown Historic 

District. 

Potomac Gorge (Potomac Palisades) 

Located upstream from Key Bridge along the Potomac River, the project site is located within a 

low-lying area of the Potomac Gorge, more characteristically known for its palisades. 
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IV-13

Development in this region of the Potomac Gorge is viewed as less intrusive because it is not 

occurring on the character-defining line of lofty, steep cliffs that line the Potomac River’s edge. 

Instead, the proposed boathouse would be constructed within a historically mixed-use section 

of Georgetown. Since the late nineteenth century, boathouses have existed along the 

Georgetown waterfront at various locations including north of Key Bridge in the Potomac 

Gorge area. Therefore, a boathouse is not an incompatible use for the project site from an 

historical perspective. Consequently, the proposed construction of the proposed boathouse 

under Alternatives A, B and C would have a minor impact on the Potomac Gorge. 

Alexandria Aqueduct Bridge Abutment and Pier (at the Potomac River west of Key Bridge) 

The Alexandria Aqueduct Bridge Abutment and pier are located on the Washington, D.C., 

shoreline of the Potomac River, just upstream from Key Bridge, southeast of the project site. 

Action under Alternatives A, B and C would result in a new boathouse that is highly visible from 

these historic resources. Historically, however, this was not an undeveloped natural setting. 

The construction of the Alexandria Aqueduct Bridge resulted in the linkage of the C&O Canal 

to the Alexandria Canal. This linkage provided a greater accessibility than ever before to far 

reaching markets, and resulted in the waterfront experiencing a surge in growth. Industrial and 

manufacturing enterprises such as ice houses, lime kilns, lumber yards, and coal piles were 

located along the waterfront in addition to boathouses during the late nineteenth and early 

twentieth centuries. As the waterfront in Georgetown has experienced different kinds of 

development throughout its history, new construction in itself is not inappropriate for the 

project site. Consequently, action under Alternatives A, B and C would not interfere with the 

resources’ historic settings. 

Washington Canoe Club (WCC), 3700 Water Street 

Prior to the construction of the WCC, the character of the Georgetown waterfront was largely 

industrial, spurred by the construction of the Alexandria Aqueduct Bridge and the C&O Canal. 

By the start of the twentieth century, around the time of construction of the WCC, boathouses 

began to emerge on the waterfront in greater number, illustrating the popularity of the activity 

and the use of the river for recreational purposes. Action under Alternatives A, B and C would 

locate a new boathouse adjacent to the WCC. As the waterfront in Georgetown has 

experienced varied development patterns throughout its history, new construction in itself is 

not inappropriate for the project site. Tied closely with the plan for the Georgetown Waterfront 

Park, the creation of a boathouse “row” similar to Philadelphia is an important aspect of the 

project plan, as indicated within the Preliminary Land Exchange Agreement. The adjacency of 

the WCC and the PBC supports the creation of additional boathouse facilities along the river, 

and the compatibility of this proposed land use. 

The integrity of location and setting would remain intact, for the addition of a boathouse along 

the Potomac River would reinforce the character of the waterfront where the WCC has played 

its historical role. The removal of the non-historic fence and other outdoor storage facilities at 

the site (east of the proposed boathouse) will not lessen the integrity of setting. These site 

features are modern additions to the property and do not contribute to the overall significance 

or character of the WCC. The integrity of feeling and association would also remain intact 

because the WCC would still be able to convey its connection with boating along the Potomac 

River. The materials of the proposed boathouse under each alternative would be consistent with 
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typical elements of boathouse architecture although the scale and massing of the proposed 

facility, particularly Alternative A (Zoning Alternative) is larger than the WCC. Action under 

any of these alternatives would have a moderate impact to the WCC, as defined above in the 

historic resources impact criteria used for this EA. 

Potomac Boat Club (PBC), 3530 K Street 

 

The PBC is located east of the project site on the downstream side of Key Bridge from the WCC. 

Boathouses have existed on the waterfront since the late nineteenth century. At the height of 

boating popularity, there were at least six boathouses along the Georgetown waterfront. Thus, 

construction of a boathouse would be appropriate for the project site. The scale of the 

proposed boathouse under Alternatives A, B, and C is larger than that of the PBC. Although 

portions of the proposed boathouse may be visible from the PBC, this would not be a negative 

impact because, historically, other boathouses were visible from the PBC. Considered a 

compatible use, the proposed boathouse would restore the historic setting of boathouses along 

the river, increasing the integrity of association, location, and setting. The presence of the WCC, 

Aqueduct Bridge Abutment and Pier in between the proposed boathouse site and the PBC 

however, lessen the differences in scale and massing between the two structures. For these 

reasons, the proposed boathouse under Alternatives A, B, and C would have a minor impact on 

the PBC. 

Key Bridge 

The project site is located northwest of Key Bridge along the waterfront in Georgetown. The 

proposed boathouse would be highly visible from Key Bridge because of their proximity to one 

another. Boathouses have existed on the waterfront since the late nineteenth century, and have 

been visible from the Key Bridge since 1923, when the bridge was built. New construction in 

itself is not inappropriate for the project site, as the waterfront in Georgetown has experienced 

different types of development throughout its history. Consequently, the development of a 

boathouse under Alternatives A, B and C would have minimal impact on Key Bridge. 

 

Historic Districts and Individual Landmarks Impacts – Georgetown University

 

Old North, the Healy Building, and the Georgetown University Astronomical Observatory are 

buildings that are individually listed historic resources on the Georgetown University campus. 

The potential impacts of the proposed project on these resources would be indirect, related to 

alteration of their visual context or historic setting. 

 

Old North 

Located within the original quadrangle of Georgetown University, Old North is located to the 

north of the project site. The proposed boathouse is sited along the waterfront at a lower 

elevation than Old North, and would not be visible from this vantage point. Therefore, the 

proposed Georgetown University boathouse under Alternatives A, B and C would have no 

impact on Old North. 
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Healy Hall 

Healy Hall, one of the tallest buildings on the Georgetown University campus, is located within 

the original quadrangle of the University, located to the north of the project site. Because of the 

height of Healy Hall, there is potential that the proposed boathouse would be visible from the 

building. Substantial grade changes, other buildings on the campus, and existing vegetation 

serve as buffers between Healy Hall and the project site. Although the boathouse could 

potentially be visible from Healy Hall, there would be no impact on Healy Hall. 

Georgetown University Astronomical Observatory 

 

The Observatory is situated on a hilltop northwest of the original Georgetown University 

quadrangle, and north of the project site. The proposed boathouse would be shielded from view 

from the Observatory by substantial grade changes, other buildings on the University campus, 

and by trees. Consequently, the proposed boathouse under Alternatives A, B and C would have 

no impact on the Observatory. 

Mitigation

 

Overall, the proposed action under Alternatives A, B and C would have minor to moderate 

impacts on historic resources in the vicinity of the project site. The impact to historic resources 

is assessed the same for all three alternatives, except on the C&O Canal NHP and WCC as 

described above. It should be noted that the Old Georgetown Board approved Alternative A, 

and Alternative B is consistent with the existing Section 106 Memorandum of Agreement. Visual 

impacts are discussed in more detail in Section 4.2.2 below. 

The C&O Canal NHP Towpath and Canal and the WCC are the closest historic resources 

immediately adjacent to the proposed boathouse. The project is also located within the C&O 

Canal NHP, the Georgetown Historic District and the Potomac Gorge area. In order to reduce 

impacts of the proposed boathouse on these historic resources, NPS will coordinate with the 

D.C. Historic Preservation Office and the Advisory Council on Historic Preservation to comply 

with Section 106 (if Alternative A – Zoning Alternative, or C – Preferred Alternative is pursued) 

to reduce impacts of the proposed boathouse to these historic resources. If Alternative B (MOA 

Alternative) is pursued, no additional action would be necessary under Section 106. 

 

No Action Alternative 

The No Action Alternative would have no effect on historic resources since the project site will 

not be developed and will remain in its present use as public parkland. Views from the adjacent 

historic districts and landmarks would not change from current conditions under the No Action 

Alternative. However, potential development of the upstream site, could impact cultural 

resources within the C&O Canal NHP, including the remnants of the incline plane. 
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4.2.2 Visual Resources 

Methodology

The overall visual impacts that can be attributed to the proposed action would result primarily 

from the degree of visual change that would be generated by the three boathouse alternatives. 

For this analysis, the visual impacts were determined for representative viewpoints. The degree 

of visual change considers the existing character of the landscape in view, the relationship of the 

project site to the land around it, and the type of visual changes that would occur in the 

“viewshed” as a result of the project. As described in Section 3.2.2, viewpoints representing 

views from key locations were used in the analysis to identify impacts. These viewpoints were 

determined based on scoping input, as well as an analysis of the relationship of the proposed 

boathouse to the existing visual environment. 

Several factors were taken into account in determining visual impacts as described below: 

• The visual character of the project setting, that varies between a natural environment 

(that has no built elements) to an urban environment (that is dominated by built 

structures). 

• Current relationship and visibility of the project site to the overall landscape in view (i.e., 

viewshed). 

• Other inter-related variables concerning the viewpoint, viewer conditions, and how the 

landscape is being viewed. These could include the context of the specific view, the 

orientation and angle of the view, the presence of screening elements, the activity of the 

viewer during which the view is experienced, and the duration of the view. 

Based on these factors, the degree of visual impact is described in the following categories: 

• No Visual Impact occurs when the proposed action would not be visible from the 

representative viewpoint. 

• Minor Visual Impact occurs when the proposed project would be visible as a 

background element of a view that includes buildings of similar mass and scale. The 

project would not interfere with views from the representative viewpoint and would not 

change the existing viewshed character. 

• Moderate Visual Impact occurs when the proposed project would be visible as part of a 

view that includes buildings of similar mass and scale and interferes with views from the 

representative viewpoint without changing the existing viewshed character. 

• Major Visual Impact occurs when the proposed project would be visible as a 

contrasting or dominant element, interferes with views from representative viewpoint, 

and substantially changes the existing viewshed character. 

The impact assessment included review of the plans, sections, and elevations for the proposed 

boathouse as prepared by MUSE Architects for Georgetown University. In addition, computer 

simulations of the proposed boathouse were prepared for each alternative and superimposed on 
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IV-17

existing images (landscape, paving and other proposed features are not included). Views 

towards the project site were photographed using a 50 mm lens, which most closely 

approximates the human eye without wide angle or other distortion, on a 35 mm Single Lens 

Reflex (SLR) camera. The simulations were drawn to scale and rendered using computer 

software to as accurately as possible depict the visual appearance of the proposed boathouse. 

The photographs for the simulations were taken during the winter months when the proposed 

boathouse has the most likelihood to be visible. 

The visibility of the proposed boathouse under each alternative (called “area of influence”) was 

quantified by measuring the area of the overall image frame that would change due to the 

proposed development of the project site. This was calculated by superimposing a grid on the 

picture frame and measuring the portion of the picture affected by the proposed building. 

Percentages of change at the viewpoints used in the analysis were calculated for each alternative 

using this methodology. 

Example of a superimposed grid on existing viewpoint from Key Bridge to help quantify 

potential visual impacts 
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Alternatives A, B and C

Under the proposed build alternatives, the boathouse would be located in an area that is situated 

at the confluence of two predominant character areas. As identified in Section 3.2, the area to 

the west (inclusive of the project site) is predominantly natural, whereas the area to the north 

and east is predominantly urban in character. The proposed boathouse would add a structure in 

a location that is currently vacant and vegetated. This would change the visual condition of the 

project site from a natural to an urban environment, and would extend the recreational 

character that is currently provided by the PBC and WCC to the immediate east. 
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Impacts on Key Viewpoints

View from Virginia including the George Washington Memorial Parkway (GWMP) 

The proposed boathouse under Alternatives A, B and C would be visible from the GWMP. 

Drivers or passengers in vehicles headed in the northbound direction would see the boathouse 

to their right for a brief duration immediately after passing Key Bridge. Similarly, drivers or 

passengers in vehicles headed in the southbound direction would see the boathouse from 

portions of the GWMP across the river. The proposed boathouse would also be visible to hikers 

along the Potomac Heritage Trail. 

From this location, the boathouse would be visible as part of a visual environment that would 

include the Potomac River in the foreground, the WCC flanking the downriver side, a natural 

environment (C&O Canal NHP) flanking the upriver side, as well as immediately above the 

structure, and Georgetown University buildings along the skyline (see Photo Simulation 1). 

Since the proposed boathouse would be located in a visual environment that includes urban and 

natural features, as visible from this viewpoint, visual contrast against the existing setting would 

be less than if the boathouse was located in a setting that was completely natural. In addition, 

while the proposed boathouse is larger than the adjacent WCC in mass and scale, it is 

compatible with the multi-storied buildings on the Georgetown University campus that provide 

a backdrop. 

From this viewpoint, the area of influence of the proposed boathouse was measured as 2.6 

percent for Alternative A (Zoning Alternative), 2.1 percent for Alternative B (MOA Alternative), 

and 2 percent for Alternative C (Preferred Alternative) based on the methodology as described 

above. The No Action Alternative would not result in any change to the existing viewpoint. 
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Alternative A (Zoning Alternative)

Alternative B (MOA Alternative) 

 
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Alternative C (Preferred Alternative) 

No Action Alternative 

 

Photo Simulation 1 - Simulated View of Proposed Boathouse from the George Washington Memorial 

Parkway
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View from Key Bridge 

The proposed boathouse under all three build alternatives would be visible from Key Bridge. 

While motorists headed towards Washington, D.C., would not see the proposed boathouse, 

motorists headed towards Virginia would see it for a brief duration if they looked towards their 

right. 

The boathouse would be most visible to pedestrians walking on the upriver side of the bridge, 

especially those walking to or from D.C. on this side of the bridge. For most of the duration that 

a pedestrian would be on the bridge, the boathouse would appear as part of a changing visual 

environment. At the Virginia end of the bridge, the boathouse would appear on the periphery, 

below eye level, between the urban environment of Georgetown to the right, and the Potomac 

River and natural environment located to the left. As pedestrians move towards the center of 

Key Bridge, the boathouse would increase in proximity and visibility to the left (see Photo 

Simulation 2). Once pedestrians move towards the D.C. side of the bridge, the boathouse would 

become less evident among the other elements, including the Whitehurst Freeway Ramp, the 

C&O Canal, and Canal Road. 

For pedestrians walking in the opposite direction (towards Virginia) the boathouse would be 

visible to the right during the duration that they would walk from the beginning of the bridge on 

the D.C. side to approximately the middle of the bridge. In this direction, the tall multi-storied 

structures in Rosslyn are the dominant elements in the viewshed, with the Potomac River 

providing the second dominant element to the right. Within this visual context, the boathouse 

would be a new structure that would be evident but would not dominate the visual environment. 

From this location, the boathouse under both Alternatives B (MOA Alternative) and C 

(Preferred Alternative) is lower and appears closer in scale to the WCC compared to Alternative 

A (Zoning Alternative). Further, from this viewpoint, the area of influence of the proposed 

boathouse was measured as 2.3% for Alternative A, 1.7% for Alternative B, and 1.7% for 

Alternative C based on the methodology as described above. The No Action Alternative would 

not result in any change to the existing viewpoint. 
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Alternative A (Zoning Alternative) 

Alternative B (MOA Alternative) 

 
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Alternative C (Preferred Alternative) 

No Action Alternative 

Photo Simulation 2 – Simulated View of Proposed Boathouse from Key Bridge 
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View from Capital Crescent Trail 

The proposed boathouse under all three build alternatives would be directly visible and a 

noticeable change to this portion of the CCT would result. To users of the trail, the boathouse 

would appear as a two story structure that would extend for 255 to 280 feet (depending on the 

alternative) as they jog, walk, bike, or rollerblade past the site. 

For users headed away from Georgetown, the proposed boathouse would be a dominant 

structure for the duration from when they pass the WCC until they pass the proposed 

boathouse (see Photo Simulation 3). The visual environment would include the embankment of 

the C&O Canal to the right along with the CCT and the added access lane (for the boathouse) in 

the foreground. Once past the boathouse, the visitors would enter a more natural environment 

that continues for several miles. 

For users headed towards Georgetown, the boathouse would appear to the right after the trail 

passes through a natural environment for more than three miles. For the duration that users 

pass the boathouse, it would be a dominant visual element. Once past the boathouse, visitors 

would pass by the WCC, which adds a similar visual buffer between the trail and the river, 

before arriving at the end of the trail in an environment that can be characterized as urban. 

From this viewpoint, all three build alternatives are similar since the CCT is so close to the 

building that the height and size differences between the alternatives would not be overly 

discernable when biking or walking along the trail. However, when approaching the boathouse 

from either direction as illustrated in Photo Simulation 3, the visibility of the proposed 

boathouse in the viewpoint would vary between 37% for Alternative A (Zoning Alternative), 

29.5% for Alternative B (MOA Alternative), and 28% for Alternative C (Preferred Alternative) 

using the methodology described earlier. Obviously, this change would be greater as one 

approaches the building and less the farther one moves away either walking or biking along the 

CCT. Under the No Action Alternative, there would be no change to the current view and 

existing vegetation would continue to provide intermittent views towards the river. 
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Alternative A (Zoning Alternative) 

 

Alternative B (MOA Alternative) 

 

 

 
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Alternative C (Preferred Alternative) 

No Action Alternative 

Photo Simulation 3 – Simulated View of the Proposed Boathouse from the Capital Crescent Trail 
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View from C&O Canal Towpath

The proposed boathouse under all three build alternatives would be directly visible from the 

C&O Canal Towpath. Since differences in the alternatives could be discernable from this 

location and given the historic nature and proximity of this resource, several simulations were 

prepared (see Photo Simulations 4, 5 and 6). It should be noted that along this stretch of the 

towpath, the existing vegetation provides a visual screening effect with occasional openings that 

offer views of the river and the shoreline on the Virginia side. For the duration when a person is 

walking or running along the path, the boathouse would be visible through openings in the 

vegetation, particularly during the wintertime. During the summer, because of the existing 

vegetation, much of the view towards the river is blocked. 

To users headed towards Georgetown, the boathouse would be to the right and part of a visual 

environment that would include the C&O Canal, the retaining wall adjacent to Canal Road and 

the Whitehurst Freeway spanning the canal as a backdrop (from this vantage point, the 

Alexandria Aqueduct bridge abutment or the Theodore Roosevelt Island are not visible). These 

users arrive at the site of the boathouse after passing through a natural environment that offers 

multiple opportunities to view the river. After passing the boathouse, they have intermittent 

views of WCC (through the existing vegetation) before arriving in an area where the vegetation 

opens to reveal Key Bridge as the most dominant element in the visual environment. Past that, 

multistoried buildings in Georgetown flank the canal and become the dominant visual elements. 

To users headed away from Georgetown, the boathouse would be visible to the left during the 

duration that they pass the structure. Before arriving at the boathouse, they pass through the 

urban area of Georgetown, followed by an open area adjacent to the Aqueduct structure where 

the river is the dominant element in the visual environment. Past that, existing vegetation adds a 

buffer to the left and portions of WCC are visible prior to arriving along the proposed 

boathouse. Once users pass the proposed boathouse, they are in a natural environment where 

existing vegetation offers intermittent views of the river, particularly during the winter. 

When standing directly adjacent to the boathouse on the towpath, for Alternative A (Zoning 

Alternative), the wings of the boathouse would be above eye-level with the central portion rising 

higher. The river would not be visible; however, portions of the Virginia side of the river would 

be visible to viewers standing on the towpath directly behind or north of the boathouse. For 

Alternative B (MOA Alternative), the wings of the building would be at eye-level and, although 

the wings would restrict the view of the river, more of the Virginia shoreline would be visible 

when standing in this same location. For Alternative C (Preferred Alternative), the wings of the 

building would be below eye-level, and with the exception of the central portion, would allow a 

view of both the opposing edge of the river and the Virginia shoreline. Under the No Action 

Alternative there would be no change to the current view and existing vegetation would 

continue to provide intermittent views towards the river. 

Using a similar methodology as described above, calculations were made of the degree the 

boathouse obstructed views from the three representative viewpoints immediately adjacent to 

the site. These visibility calculations are summarized in Table 4-1. 
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IV-31

Table 4-1: Projected Boathouse Visibility from Towpath 

Percentage of View Blocked 

Peak of Boathouse 

(Photo Simulation 4) 

Hyphen 

(Photo Simulation 5) 

Wing 

(Photo Simulation 6) 

Alternative A (Zoning) 84.6% 71% 38.1% 

Alternative B (MOA) 61.2% 59.6% 25.8% 

Alternative C (Preferred) 52.5% 55.6% 29% 

No Action Alternative* 0% 0% 0% 

* Existing vegetation blocks portions of the view as illustrated in the No Action photographs. 

Percentage of Opposing Shoreline Blocked 

Peak of Boathouse Hyphen Wing 

Alternative A (Zoning) 100% 100% 50% 

Alternative B (MOA) 100% 100% 31.25% 

Alternative C (Preferred) 68.75% 69% 0% 

No Action Alternative* 0% 0% 0% 

*Existing Vegetation blocks portions of the view as illustrated in the No Action photographs. 

Figure 4-1: Viewpoints for Photo Simulations 4, 5 and 6 

from the C&O Canal Towpath 

 
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Alternative A (Zoning Alternative) 

Alternative B (MOA Alternative) 

 

 
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Alternative C (Preferred Alternative) 

 

No Action Alternative 

 Photo Simulation 4 – Simulated View from the C&O Canal Towpath towards the Peak (central 

portion) of the Proposed Boathouse under the three proposed Boathouse Alternatives and the No 

Action Alternative 
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Alternative A (Zoning Alternative) 

Alternative B (MOA Alternative) 
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Alternative C (Preferred Alternative) 

 

No Action Alternative 

 Photo Simulation 5 – Simulated View from the C&O Canal Towpath towards the Hyphen (roof 

area between the central portion and side wings) of the Proposed Boathouse under the three 

proposed Boathouse Alternatives and the No Action Alternative 
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Alternative A (Zoning Alternative) 

Alternative B (MOA Alternative) 
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Alternative C (Preferred Alternative) 

No Action Alternative 

 Photo Simulation 6 – Simulated View from the C&O Canal Towpath towards the Wings of the 

Proposed Boathouse under the three proposed Boathouse Alternatives and the No Action 

Alternative 
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Visual Impact Summary 

From two key viewpoints, the George Washington Memorial Parkway and the Key Bridge, a 

boathouse under each alternative would result in a minor visual impact due to the following 

reasons: 

• The boathouse would be visible among buildings of somewhat similar mass and scale; 

• The boathouse would not interfere with the view; and 

• The boathouse would not change the overall character of the existing viewshed. 

From the CCT and the C&O Canal Towpath, the degree of impact would vary depending on the 

location of the viewer. From the viewpoints used in the analysis above, each alternative would 

result in a major impact because: 

• The boathouse would be a dominant visual element; 

• It would interfere with existing views; and 

• It would substantially change the character of the existing viewshed from these locations. 

Based on scoping comments and the historic nature of the C&O Canal Towpath, views to the 

river from this resource were considered particularly important. The visual obstruction 

methodology as described above attempts to quantify impacts from viewpoints immediately 

adjacent to the building. As described above, this analysis shows differences among the 

alternatives with Alternative A, B and C having from most to least impacts, respectively, at this 

key location. As one moves away from the building, impacts to the towpath obviously lessen. 

Overall, because the boathouse under each alternative would result in minor impacts from two 

of the key viewpoints, because along the CCT and the towpath, the view towards the river 

would be blocked for a limited duration when a viewer is walking, jogging or biking past the 

boathouse, and because views towards the river would continue to be available upstream and 

downstream from the boathouse, the visual impact of all three alternatives is considered 

moderate. Variations among the alternatives are most noticeable when standing directly 

adjacent to the building at the towpath location and are documented in Photo Simulations 4, 5 

and 6 and Table 4-1 above. 

 

Mitigation

 

Under all three alternatives, the following measures would reduce the visual impact of the 

proposed boathouse: 

• To reduce impacts to views from the south (GWMP and Key Bridge), architectural 

materials and colors to reduce the contrast of the boathouse to the extent possible 

against the existing natural setting would be used. Also, landscaping would be used as 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-39

screening and to soften the visual impact of the building from viewpoints across the river 

and from Key Bridge. 

• To reduce impacts to views from the C&O Canal towpath and the CCT, vegetation 

would be retained to the extent possible in key areas, such as along the towpath and at 

the eastern and western end of the boathouse, to reduce the period of visibility of the 

boathouse from these locations. 

• As noted above, in Section 4.2.1, since Commission of Fine Arts and National Capital 

Planning Commission review is required for the proposed boathouse and a revised MOA 

would be required for Alternatives A and C, any other conditions and changes to the 

building resulting from these reviews would be implemented to reduce overall visual 

impacts. 

No Action Alternative 

 

Under the No Action Alternative, the site would remain vacant and undeveloped. Therefore, 

there would be no change to the visual environment along this part of the Georgetown 

waterfront. However, minor adverse affects would occur around the TBC since outdoor boat 

storage would remain outside and visible to viewers in and around that area. Further, if the 

upstream site is developed, the view of the Potomac Gorge from the GWMP could be adversely 

affected, and impacts to existing views along the CCT and the towpath could occur. 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-40

4.3 TRANSPORTATION SYSTEMS IMPACTS 

4.3.1 Vehicular Traffic and Parking 

Alternatives A, B and C 

The impacts on transportation systems and routes must be assessed in several stages: 

construction, during daily operations, and under special circumstances such as regattas. 

As a part of the zoning application process, Georgetown University prepared a parking 

management plan, which has been endorsed by the D.C. Department of Transportation. The 

parking management plan would be implemented during daily operations, as well as regattas, 

and consists of the following elements: 

• “All students and Georgetown’s crew will either walk or bicycle to the site. 

• Visitors and visiting crew will be shuttled to the end of K Street, a short walking distance 

to the boathouse along the CCT. 

• The shuttles will run as continuously as required by the demand, leaving the campus 

every fifteen minutes, dropping patrons off and picking up others to return to campus. 

• The team bus of visiting crews will park on campus for the duration of the regatta after 

dropping off team members. 

• Patrons will be encouraged to park on campus and utilize the shuttle or walk to the 

boathouse from the campus via the C&O Canal tunnel or the stairwell located across 

from the Car Barn. 

• Spectators and visiting teams will be shuttled by University buses, from the University 

campus to the K Street dead-end, from which they will walk to the Boathouse. The race 

course will not be altered from its current path. The finish line will remain in front of 

Thompson Boat Center; therefore, there will be no vehicular congestion at the 

boathouse due to regattas.”7

Construction Stage 

Construction of the boathouse, under Alternatives A, B and C, would last for approximately 16 

months. In order to minimize impacts during the construction stage, construction activities 

would have to be coordinated to avoid conflict with local trail users. The paved CCT provides 

the only existing access to the site. In order to avoid conflict with trail users during 

construction, the trail area would be widened from 10 feet to 22 feet and the trail would be 

temporarily shifted to the north without cutting into the embankment of the C&O Canal. A 

dedicated 12 foot-wide access lane during construction would accommodate construction crews 

and vehicles and a chain-link fence would separate the trail users from the access lane. The 

access lane would run parallel to the existing CCT, for the length of the boathouse site, up to the 

turnaround at the western end. The pavement would be widened and the CCT would be 

relocated first before construction of the access lane to reduce potential conflicts with trail users 

during the construction period. Construction activities (such as installing underground utilities) 

 

7

 Washington DC Department of Transportation, Zoning Commission Case No. 02-30 application for Map amendment 

from unzoned to W-O, Memorandum 5/03.
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-41

that could potentially impact trail users would be performed at night to ensure that the CCT 

remains open for public use during daytime. 

Construction on the boathouse site would mostly occur during daytime hours. Construction 

activities would not occur on Federal holidays, or on weekends, when pedestrian and bicycle 

activity is at its peak. It is not anticipated that pedestrian or bicycle activity levels would change 

as a result of construction. However, construction activities could have a slight to moderate 

impact on the CCT and hikers/bikers using this trail system since vehicles may interrupt 

pedestrian and bicycle flow when unloading equipment or maneuvering vehicles. 

Widening of the trail area would require the existing fence along the northeastern portion of 

WCC to be shifted to the south. Also, proposed development of the boathouse site under 

Alternatives A, B and C would require the existing fence along the western portion of WCC to 

be relocated by approximately 40 feet to the east. This area is currently used for parking and to 

store boats, both of which would need to be removed or relocated prior to construction at the 

proposed boathouse site. 

Daily Operations 

Daily operations of the proposed boathouse under Alternatives A, B and C would be primarily 

for training purposes. Georgetown University would use the facility during both morning and 

afternoon training sessions. The crew would arrive at the boathouse between 6:15 and 7:00 a.m. 

and would leave the facility between 8:00 and 8:45 a.m. during the morning session, and would 

arrive around 4:00 p.m. and leave around 6:00 p.m. during the afternoon session. All daily 

boathouse users would be expected to access the site by bicycle or on foot. 

There will be no on-site parking for regular users of the boating facility; all students, coaches 

and visitors would be expected to comply with the parking management plan which specifies 

the mode of transportation as bicycling or walking. Therefore, a change in vehicular traffic and 

parking in the vicinity of the site would not be expected once the boathouse facility is in 

operation. 

The only vehicular access to the site would be for emergency purposes, occasional services (e.g., 

trash pickup), and delivering and retrieving boats. The emergency/service access area would be 

striped clearly with a turnaround located just past the facility to accommodate these vehicles. In 

total, it is anticipated that a vehicle for deliveries such as uniforms, supplies, etc., would access 

the site approximately three to four times per week, between the hours of 9:30 a.m. and 3:00 

p.m. This includes trash pick-up anticipated to occur once a week between the hours of 6:30 

a.m. and 3:00 p.m. 

This minimal traffic would have minimal impacts to the trail users, particularly because the 

access lane would be separate from the CCT, and most deliveries would occur during non-peak 

periods of trail use. 

Regattas 

Georgetown University currently hosts regattas during weekends in the spring season (they 

participate in regattas during the spring and fall but only host spring events). The regatta 
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National Park Service 1v-42

schedule would not be affected by a new boathouse and would be similar to previous years. 

During regattas when Georgetown University is hosting the event, visiting teams would 

transport their boats to the proposed boathouse facility. 

The method of transporting and storing the boats of the visiting team would depend on the 

number of teams competing in the regatta. A visiting team typically brings four boats on a trailer 

that would be brought to the boathouse either on the preceding day or on the morning of the 

event. The site can temporarily accommodate up to two trailers at one time. Depending upon 

the number of visiting teams, the boats would be unloaded and, either the trailer would be kept 

on site, or removed from the site and parked on campus. 

A regatta with one or two teams visiting would typically last for approximately three hours, after 

which the trailer would be loaded and would depart. In the event of larger regattas, 

Georgetown University anticipates coordinating with either TBC or PBC to provide boat 

unloading space for the additional visiting teams. In this case, trailers would be stored on 

campus. 

Similarly, Georgetown University teams go to other locations to participate in regattas. During 

these times, the University would remove boats on a trailer before the regatta, and would 

subsequently bring them back. Georgetown University participates in five to six events in the 

spring season and two to three in the fall season on the Potomac. The spring season regattas last 

from late March until late May, with two additional events occasionally occurring in June. Also, 

the University participates in approximately fifteen regattas away from D.C. during the spring 

season and approximately eight during the fall season. 

In total, the University anticipates a trailer accessing the project site between 50 and 75 times in a 

year. During these occasions, there would be a potential impact on CCT users when trailers 

turn into or out of the turnaround area. Georgetown University and visiting teams would need 

to be attentive to trail users when using the access lane. Due to the high cost of the crew boats, a 

trailer is typically driven by a coach or a professional driver, with an accompanying person to 

assist in directing the driver while turning around and parking. This accompanying person 

would help to direct the trailer driver and help to minimize conflicts with CCT users when a 

trailer is brought or leaves the project site. 

Team members would be brought to the site by bus, and dropped off at the dead end of Water 

Street. The number of visitors to the waterfront area during regattas would be higher than daily 

operations but similar to existing conditions. The racing finish line would remain near the TBC, 

where most of the spectators would be expected. 

Parking requirements have been waived by the D.C. Zoning Commission and no parking spaces 

are provided on-site. An increase in parking demand along the waterfront is not anticipated as a 

result of the proposed boathouse under Alternative A, B or C because spectator activity is not 

anticipated to change. The schedule, and frequency of visiting teams coming to the Georgetown 

waterfront, would not be altered as a result of the new boathouse. The race course would also 

remain the same and it would be expected that spectator areas would remain the same. 

In order to improve existing conditions, the Georgetown University bus service that is already in 

operation could be expanded to accommodate visiting teams. Shuttle service, as required by the 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-43

transportation management plan would offset the increase in visitors to the waterfront area 

during regattas, as compared to daily operations. Visitors would park their vehicles on 

University grounds, therefore reducing the current impact to the parking facilities along the 

waterfront. 

Mitigation

Mitigation measures will be employed to reduce the impact of construction activities on CCT 

users. The construction access road will be separated from the trail by fencing. In addition, 

flagmen will be utilized when a construction vehicle is using the access lane or unloading 

equipment at the site. Also, construction activities (such as installation of utilities) that could 

potentially interrupt trail use will be conducted during nighttime to ensure that the CCT 

remains open for public use during the daytime. 

There are stairs connecting the towpath and CCT at the end of Water Street, as well as a path 

connecting the two routes approximately one-half mile upstream. Posting detour signs would 

allow pedestrian trail users to pass by construction activities by use of the towpath, avoiding the 

construction site completely, if desired. 

Following construction, the new access lane and CCT will be painted or re-striped to clearly 

distinguish the areas designated for vehicles versus the areas designated for bikers and trail 

users. 

Since WCC is a private facility on NPS property by permit, impacts either from construction or 

operation of the proposed boathouse would require negotiation between the two parties to 

resolve prior to construction. Any loss of parking would be mitigated through public spaces 

currently available along Water Street. 

No Action Alternative 

Under the No Action Alternative, the proposed boathouse would not be constructed. There 

would be no additional users brought to the project site. The primary boating facility would 

remain at TBC. Visitors would continue to drive to TBC and park their vehicles there during 

events. There would be no change in the number of vehicles accessing the waterfront on regatta 

days. However, if a boathouse or another use is developed at the upstream site, there could be 

impacts to existing users from vehicles (both construction and operational) that would use the 

CCT to access the site. 

4.3.2 Public/Georgetown University Transit Service 

 

Alternatives A, B and C 

Under Alternatives A, B and C, Georgetown University’s new boathouse would not be expected 

to have an effect on the need for University operated or public bus service. Should an increase 

in need arise, shuttle service would be provided by Georgetown University. Visitors would be 

able to park on the campus, and from there take a shuttle to the waterfront area. There are 

several pathways the buses could take to get from the campus to the boathouse drop-off point. 

The buses could leave the campus from Reservoir Road, heading south toward the water on 
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National Park Service 1v-44

Foxhall Road, and East on Canal Road which turns into M Street. Buses could then turn right 

onto Wisconsin Avenue and left onto Water Street, which runs parallel to the water. Most 

spectators view the races from in front of Washington Harbour and TBC, where the finish line is 

located. Spectators would be dropped off along the waterfront near Washington Harbour. The 

same route, up to Water Street, would be followed for dropping off competitors whose boats are 

at the proposed Georgetown University boathouse. The dead end of Water Street would serve 

as the drop-off point and the closest point for vehicular access (other than for emergency 

purposes). The roads that access the project site are the same as those currently used by vehicles 

traveling from the Georgetown University campus to K Street. 

There are a number of public transportation systems that service the Georgetown waterfront 

area. These routes come from Rosslyn, Dupont Circle, and Foggy Bottom. Although they may 

not access the facility, they could be used by visitors and spectators to get to the Georgetown 

waterfront. 

The University could expand their operation (the Georgetown University Transportation 

Shuttle) to provide bus service to and from the site during events if needed. Faculty, staff, and 

students with a valid Georgetown University ID card can ride on any GUTS route at no charge. 

Bus service to the site may be required approximately five to six times per year for regattas. 

Therefore, minimal impacts are anticipated on the public or Georgetown University’s transit 

systems. 

No Action Alternative 

Under the No Action Alternative, there would be no change in need for transit service to the 

project site or the waterfront area. 

4.3.3 Pedestrian/Bicycle Facilities 

 

Alternatives A, B and C 

The project site is well served by pedestrian and bicycle pathways, as discussed in Section 3.3.3. 

The Glover Archbold Trail runs from the University entrance, near the intersection of 44th Street 

and Reservoir Road, for approximately 0.6 miles to Foxhall Road. The trail continues beneath 

Foxhall Road and the canal via a paved tunnel, connecting to the towpath and CCT. Students 

would be expected to use this pathway as their primary access to the proposed boathouse. 

Bicycle access is also available in this area; however, the Glover Archbold Trail does not permit 

bicycles. Bicyclists would need to use Canal Road to access the tunnel. These pedestrian and 

bicycle routes are similar to the routes currently used by students. 

As discussed above, existing users on the CCT would be impacted during construction and 

when boat trailers access the site. 

No Action Alternative 

 

Under the No Action Alternative, the pedestrian and bicycle activity in the area would be 

expected to remain unchanged. Students currently use the local trails to get to TBC. The trails 

connect to Water Street which provides direct access to TBC via bicycle or walking. As 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-45

discussed above, there could be potential impacts on CCT users if the upstream site is 

developed. 

4.3.4 River Navigation/Use 

Alternatives A, B and C

The addition of a new boathouse facility on the Potomac River would have varying impacts at 

different points along the river. The proposed project would impact river use in areas ranging 

from the current crew training facility, TBC, upstream to the project site. 

Action under Alternatives A, B and C would not result in a change to the rowing season, training 

times, or regatta schedule. Moving the Georgetown University crew out of TBC would reduce 

the boat congestion entering and exiting the river along this portion of the River. Currently, 

there are a number of teams and individual rowers and paddlers using TBC to enter, exit, and 

row along this segment of the river below Key Bridge. The Georgetown University crew 

consists of an average of 180 members, all of whom would discontinue use of TBC as a result of 

the new facility. Under Alternatives A, B and C, construction of a new boating facility upstream 

from Key Bridge would have a positive impact on the use of this section of the Potomac River. 

The new facility would divert some of the crowding of boats and river users in the vicinity of 

TBC. In addition, conflict between competitive and recreational rowers during regattas would 

be reduced. There would not be an impact to the practice and race routes of the rowers; 

however, the relocation of entry and exit points would result in a positive impact because of the 

reduced congestion near TBC. 

Aside from the location of their facility and docks, Georgetown University’s training practices 

would not be expected to change from their current routine. The proposed action would not 

affect the canoe and kayak team’s training times or scheduled regattas. The placement of a new 

facility and associated docks, however, could interfere with the WCC practice and race courses. 

The Potomac River Safety Committee is responsible for guiding the use of the river for nonmotorized boating uses. The Potomac River Safety Committee’s guidelines direct the paddlers 

to travel along the D.C. shoreline and the rowers to travel along the Virginia shoreline. Moving 

the Georgetown University rowers’ point of river access to the project site would result in the 

need for a revised plan. The existing conditions guiding the use of the river by the paddlers and 

rowers is illustrated in Figure 3-3. In its current design, the position of Georgetown University’s 

docks would be in the path where canoers and kayakers typically practice. 

Figure 4-2 illustrates the paddlers’ current race course, provided by WCC, which depicts a 

potential impact on the WCC paddlers. The width of the river in this location is approximately 

1,200 feet, compared to the 800-foot width of the river in front of TBC. The proposed dock 

would extend 75 feet into the water for a length of 250 feet along the shoreline. The docks at 

TBC extend about 50 feet into the water, running for approximately 300 feet. The size of the 

docks is a function of the length of the crew shells, height of the deck grade above water and 

maximum desired slope of the access ramp. The proposed docks are designed to accommodate 

easy maneuvering of the long boats into and out of the boathouse. Because the width of the 

river in this area is much greater than at TBC, it is not anticipated that the docks would cause 

congestion on the river as a result of their extending into the river. 
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National Park Service 1v-46

Source: Washington Canoe Club, 2005. 

Figure 4-2: Washington Canoe Club and Proposed Georgetown 

University Boathouse Dock 

WCC has expressed concern over the interaction between paddlers and rowers because of the 

difference in boat types and directions the boaters face. Canoers and kayakers face forward 

while rowers face backwards, using a coxswain to guide them. Because of the proximity of the 

two facilities, the potential for conflict between the rowers and paddlers is expected to be 

slightly greater than current conditions. PBC and WCC have shared and coordinated the use of 

the river for over 100 years. The introduction of a new facility adjacent to WCC would increase 

the need for coordination between rowers and paddlers. A cooperative agreement between the 

boating facilities in this area is recommended. 

Motorized boats also pass through this area. They are restricted to a no-wake zone in the front 

of the boating facilities. Coaches as well as boaters must always be aware of the potential for 

motorized boats in the area. The proposed action should not have any effect on these boaters. 

Most motorized boat traffic occurs below Memorial Bridge and does not interfere with crew or 

paddling use above and below Key Bridge. 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-47

Mitigation

In order to accommodate all non-motorized boating activities, the Potomac River Safety 

Committee’s river navigation guidelines should be revised and updated through a cooperative 

process by all members of the committee. New river patterns to guide the Georgetown crew 

should be included in this plan, similar to the guidelines used to coordinate river egress and 

ingress between WCC and PBC. During this process, practice routes as well as official race 

courses for rowers, canoers, and kayakers would be designated. The race lanes illustrated in 

Figure 4-3 have been developed by Georgetown University as a potential mitigation measure 

where the WCC racing lanes would be shifted slightly to accommodate the proposed dock. This 

illustration needs to be reviewed by WCC and other members of the River Safety Committee to 

determine race course locations that minimize conflict and are acceptable to both parties. 

Source: MUSE Architects, 2004 

Figure 4-3: Potential Realignment of WCC Race Course 

 

No Action Alternative 

 

River navigation and use would not change under the No Action Alternative, and, therefore, 

there would be no impacts or improvements as a result of this alternative. 
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National Park Service 1v-48

4.4 PHYSICAL/BIOLOGICAL RESOURCES IMPACTS 

 

4.4.1 Water Resources 

 

Alternatives A, B and C 

Surface Water and Water Quality

 

Construction of Alternatives A, B or C would have the potential to transport sediments and 

contaminants to the Potomac River, which could affect water quality. The construction process 

would require removal of the vegetative soil cover from the site, exposing surface soils, 

disturbing soils along the shoreline for bank stabilization, and excavating soil for underground 

utility installation and boathouse/dock pilings. These activities would create a potential for 

stormwater and wind erosion of exposed soils, and the subsequent potential transport of 

sediment and contaminants contained therein (if any) to the Potomac River. The on-site use of 

construction materials, equipment, and vehicle operation would potentially introduce 

contaminates to the soil from these sources (e.g., petroleum products), which could be 

transported to the river via stormwater runoff. To minimize the potential sedimentation and 

contaminant impacts to the river, erosion and sediment control measures would be 

implemented on-site. 

Constructing a fixed dock, approximately 24 feet by 80 feet, would require approximately four 

pilings of 12-inch diameter. In addition, several concrete blocks will be placed on the river bed to 

provide anchors to the floating portions of the dock. Dock construction would create a minor 

potential for the contamination of the river from the use of construction materials and 

equipment over the water, and potential turbidity issues from constructing dock support pilings 

in the river. Boathouse and dock pilings would not be driven into the river sediments due to the 

risk of vibration impacts to the on-site concrete sewer interceptor. Instead, holes for the pilings 

would be augered utilizing piling casings, thereby minimizing vibration and noise impacts. 

The constructed facilities would cover approximately 42 percent of the site under Alternatives A 

(Zoning Alternative) and C (Preferred Alternative) and 34 percent of the site under Alternative B 

(MOA Alternative) with impervious surfaces, and approximately 2,500 square feet of river 

surface and subsurface area with the fixed dock. The increase in impervious surfaces would 

result in a reduction in assimilation and absorption of stormwater with a subsequent increase in 

stormwater run-off. The proposed facility under each alternative would include a stormwater 

management system with a subsurface drainage system, stormwater catchment, and a 

biofiltration sand filter prior to controlled discharge to the river. Therefore, the quality and 

quantity of stormwater discharged to the river would be controlled. The dock would cover the 

river area, blocking sunlight to the water column and river bottom sediments, potentially 

affecting growth of submerged aquatic vegetation. However, no SAV was observed in the 

proposed location of the docks and therefore, there would be no impacts. 

Physical impacts to the river bottom including minor scour and deposition of sediment, and 

turbidity would potentially occur from the proposed dock pilings in the river. The added water 

depth of scoured areas would be advantageous for boat launching; the deposition areas would 

be advantageous for the introduction of aquatic plant species and the desired restoration of 

aquatic habitat. Due to a sufficient water depth at the end of the dock, where boats would be 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-49

launched, the need for periodic dredging due to fluctuating river levels and sediment accretion 

would be unlikely. There would be no change to the number or type of boats used at the new 

facility, thereby potentially affecting water quality from what currently exists where the 

Georgetown crew functions out of the TBC. 

Motorized boat fueling would occur on-site; however, these boats would have outboard motors 

with removable gas tanks, which would be filled off-site and transported to the boats for use. If 

gasoline storage is proposed on-site, appropriate spill containment would be implemented. 

Therefore, as discussed above, potential impacts to water quality under Alternatives A, B and C 

that would be based on the construction, maintenance, and operation of the boathouse, 

including soil erosion, installation of docks, the presence of boats, and runoff from impervious 

surfaces, would be minimal. Further, since sewage material from the proposed boathouse will 

be sent to a treatment facility, there are no water quality impacts associated with waste water 

disposal. 

Mitigation

Construction impacts to the river would be short-term and minor due to the use of appropriate 

Best Management Practices (BMPs) for soil erosion and stormwater runoff. A soil erosion and 

sedimentation control plan, and a stormwater management plan would be prepared to minimize 

impacts to the river during construction and operation. Stabilization of the site shoreline with a 

combination of man-made materials (e.g., stone riprap) and vegetation would reduce the soil 

erosion of the exposed shoreline and the subsequent sedimentation to the river. 

Potential water quality impacts from boat cleaning will be controlled to reduce the release of 

contaminants into the river. Phosphate-free and biodegradable detergents and cleaning 

compounds will be used. A spill response plan will be prepared for spill accidents and tank 

leakage. To minimize the discharge of incomplete fuel combustion and motor leaks, boat motors 

will be appropriately maintained and stored. 

Flooding and Floodplains

 

The proposed development of a boathouse under either Alternatives A, B or C would be located 

in a FEMA-designated flood zone. The proposed boathouse is to be constructed at the soil 

surface level supported by underground pilings; therefore, the ground floor of the facility would 

be subject to flooding since the river’s high water mark at the project site is 19 feet above msl. 

The lowest floor elevation (at approximately 11’ above msl) would be approximately eight feet 

below the base (100-year) flood elevation (BFE), and the second floor elevation (at 

approximately 26’-6 ” above msl for Alternatives A and B, and approximately 25’ above msl for 

Alternative C) would be approximately seven to six feet above the BFE, respectively. 

Based on a 2002 geotechnical study by Schnabel Engineers, there are potential physical impacts 

with the flooding of the Potomac River on the project site. The study indicated that hydrostatic 

pressure should not be allowed to build up on future site structure during flood conditions to 

reduce the potential for uplift forces on the proposed structure. Therefore, the proposed 

boathouse would be flood-proofed where the first floor would include automatic openings to 

allow surging floodwater to move freely through the lower floor of the boathouse, eliminating 
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National Park Service 1v-50

the pressure differential on the outside of the building. The second floor would be at least six 

feet above the 100-year flood elevation for all alternatives. 

Design of the facility under either Alternative A, B or C, therefore, would include building floodproofing that would allow flood water to enter and exit the ground floor. These flooding 

allowances would allow the energy of the floodwater to be reduced around the facility, thereby, 

reducing scouring of surface soils around the structure. The lowest floor area would utilize 

flood resistant materials as identified by FEMA, and all mechanical and electrical equipment 

would be built above the BFE. In addition, the District requires that the proposed development 

not increase the BFE more than one foot at any point within the community. 

A hydraulic impact analysis was performed for the project site in 2004 by Patton Harris Rust & 

Associates to assess the impacts of a boathouse on the floodplain, flow velocities, and other flow 

characteristics of the east bank of the Potomac River (see the Appendix for a summary of this 

study). According to the study, a boathouse structure on the project site would result in no 

change downstream from the boathouse site and a 0.02 feet increase in water surface elevation 

immediately upstream from the proposed structure during a 100-year flood (PHRA 2004). The 

study also concluded that water surface elevations, velocities, and shear stresses of the river in 

flood conditions would vary only slightly at the proposed boathouse building, and there would 

be no change in these factors at the WCC, located downstream (PHR&A 2004). 

Since the proposed boathouse is in the floodplain, action under Alternatives A, B and C are 

subject to Executive Order No. 11988, Floodplain Management; the National Flood Insurance 

Program; District floodplain regulations including the District’s Flood Hazard Rules; and FEMA 

standards for building within a floodplain. Flood-proofing measures as described above are 

included since the boathouse is water-dependent and no alternatives exist to locate it outside 

the floodplain. 

Mitigation

Implementation of proposed building flood-proofing and shoreline stabilization measures 

would minimize floodwater damage to the boathouse structure and its contents, and to soil 

erosion around the boathouse and along the shoreline. In addition, Georgetown University has 

proposed measures to mitigate the effects of a flood event that include the following: 

Before a flood event: 

• Removing shells and equipment from storage bays & relocating to main campus (major 

flood) or moving some to upper racks (minor flood); 

• Moving docks to safe location (major flood); 

• Removing launches from dock area and relocating to main campus; 

• Removing equipment in first floor work room and storage room; 

• Removing items from entrance hallway & relocating to second floor; 

• Moving elevator cab to second floor level and locking in place; 

• Closing valve on sand filter inlet side (designed to keep mud out of sand filter vault 

during floods); 

• Shutting off electric power at main disconnect; 
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IV-51

• Shutting off main gas valve; 

• Draining the rowing tank (into the sanitary sewer system and not directly into the river); 

and 

• Opening doors and windows as necessary and vacating the structure. 

After a flood event: 

• Cleaning up and making repairs as required; and 

• Reversing procedures for all “before flood” items. 

For each flooding event, advance notice of the time and severity of the expected flooding is 

critical to determine the appropriate flood-proofing measures to be taken. Everything in the 

first floor must be moved above or out of the expected high water mark. Depending on the 

severity of the flood, this could mean raising items above the expected water level in a minor 

flood or completely vacating the storage bays in a major flood. 

Georgetown University, in coordination with NPS, will be required to implement all Federal 

and local review and reporting measures for construction of the proposed boathouse in the 

floodplain, including review and approval of the proposed facility by FEMA, prior to 

implementation of the land exchange and proposed construction. 

C&O Canal

Implementation of Alternative A, B or C would not impact the C&O Canal structure. Project 

construction would not occur in the toe (base edge) of the canal. In addition, no subsurface 

work would occur under the canal structure, and construction on-site adjacent to the canal toe 

would include: installation of utilities; expansion of the paved area adjacent to the CCT for 

emergency and delivery/service vehicles; and construction of the boathouse on pilings, which 

would be installed by drilling/augering soil and lining piling holes with cassions. Prior to 

construction, the Upper Potomac Intercepter Sewer pipeline on-site will be structurally 

enhanced by excavating around it and encasing the pipeline. The proposed construction and 

excavation on-site would not impact the canal. 

The project site would continue to be impacted by water seepage from the C&O Canal. The 

groundwater and soils on the project site would continue to receive the seepage of canal water 

migrating through the subsurface soils towards the river, and being confined by interceptor 

pipe, saturating surface soils on the site. 

Mitigation 

Canal water seepage on-site will be mitigated by installing a subsurface perforated pipe along the 

perimeter of the site to collect the seepage by gravity flow (not under a vacuum) and 

transporting the water to the river’s edge for discharge. 
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Wetlands

Implementation of Alternatives A, B and C would include construction on-site above and below 

the soil surface, and result in surface and subsurface structures on-site including the boathouse, 

dock system, access roadway, and realignment of the bikepath. Therefore, the construction and 

structures would be subject to the saturated soils of the artificial wetland created on-site by the 

subsurface seepage of canal water and the confining of groundwater flow by the Upper Potomac 

Interceptor sewer. Since the USACOE determined that the source of ponding water was 

artificial, and therefore that the wetlands are artificial, the area does not fall under USACOE 

jurisdiction. (This letter is included in the Appendix.) Therefore, the Corps will not exert its 

regulatory permitting authority under Section 404 of the Clean Water Act. Additionally, there 

are no naturally occurring wetlands on-site. Therefore, no wetland impacts are anticipated with 

the implementation of Alternatives A, B or C. 

Chesapeake Bay Watershed

The Potomac River is a major part of the Chesapeake Bay Watershed. Implementation of 

Alternatives A, B and C would potentially contribute sediment, contaminants, and turbidity, 

which would potentially contribute to water quality impacts to the Potomac River. However, 

due to the relatively small surface area of soil disturbance, and the implementation of 

appropriate stormwater and erosion control BMPs, the water quality impacts to the river would 

be minor, short-term, and localized, and would not contribute to water quality impacts of the 

Chesapeake Bay. 

Groundwater

Groundwater on-site, identified at a depth of one to seven feet below ground surface, would 

likely be encountered during construction of the interceptor encasement and piling caisson 

installation under Alternatives A, B and C. In addition, groundwater could be at the surface level 

due to high rainfall events. Therefore, soil dewatering techniques would be required during 

construction, but would not be necessary for project operation since the boathouse would be 

supported at the soil surface by pilings. 

Construction and operation of the facility would potentially indirectly introduce minor amount 

of hazardous materials to the soil surface from petroleum-based materials from vehicle traffic, 

and any chemicals (paints, solvents, lubricants, etc) associated with the boathouse construction 

and operation, which may be transported through the soil to the groundwater. Excavation 

during construction would potentially disturb the identified contaminated soils on-site, and 

result in leaching of contaminants into the groundwater. 

With the addition of the impervious surfaces of the proposed facility, there would be a minor 

decrease in localized groundwater recharge potential from stormwater percolation into the soil. 

Also, since groundwater is not to be used as water supply for the project, this would have a 

negligible affect on groundwater levels. 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-53

Mitigation

Due to the shallow groundwater table and proximity to the Potomac River, groundwater flows 

would provide an immediate conduit for the transport of contaminants to the river. Special 

precautions including appropriate BMPs for groundwater protection will be required during the 

construction and operation of the facility to protect groundwater quality, thereby indirectly 

protecting river water quality. Stormwater runoff from the site’s impervious surfaces will be 

collected and treated on-site prior to discharge to the Potomac River. 

 

No Action Alternative 

 

Under the No Action Alternative, the project site would not be developed and the condition of 

water resources would remain unchanged. The site’s surface soils and groundwater would 

continue to be affected by the migration and deposition of canal seepage water on-site. If the 

upstream site is developed for a boathouse or another use, there could be potential impact to the 

existing high-grade wetland at that site (as identified in the 1995 Land Exchange EA). 

 

4.4.2 Geology, Topography, and Soils 

 

Alternatives A, B and C 

 

Implementation of Alternative A, B or C would not impact site geology due to the depth of 

bedrock exceeding the depth of project construction (e.g, piling installation). 

 

Site topography would not be greatly affected by the construction and operation of the 

proposed facilities. Alternatives A, B and C would include some fill and grading of the site so 

that the first floor of the structure would be at the highest location on the site and the land 

would slope away from the structure in every direction. This would allow for appropriate 

drainage of precipitation and snow melt away from the building and toward a common drainage 

collection location on the site. 

Because the fill soils on the site are slightly contaminated and are continually in contact with site 

surface and subsurface drainage waters, the proposed drainage scenarios for Alternatives A, B 

and C would provide a reduced potential for impacts to water quality. Stormwater in contact 

with slightly contaminated soils now continually leach and “flush” any present contaminants 

directly and indirectly into the Potomac River. Under Alternatives A, B and C, stormwater 

would be redirected into a filter providing some isolation from site soils minimizing contact with 

and carrying of contaminants into the river. Therefore, the proposed boathouse would reduce 

potential chemical contamination of the Potomac River compared to existing conditions. 

Site soils would be impacted due to being covered by a building (boathouse) and sidewalk and 

other impervious materials, as well as by grading activities during construction. Construction 

generally results in compaction of site soils and elimination of the natural permeability of those 

soils. Lacking permeability, site drainage through the soils no longer takes place and 

surface/sheet flow would be encouraged. However, these soils are not native to the site, and 

have been subject to grading and movement when they were placed. In addition, the site soils 

are contaminated by elevated (but low) levels of heavy metals. Therefore, there could be a 
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positive impact from covering the soils since the soils would no longer be exposed to the 

environment and accessible to organisms or mobilization by wind and water. 

Under Alternatives A, B and C, topsoil would be brought for use around the building. Use of 

topsoil would help to enrich the soils currently located at the site. Pedestrian areas around the 

proposed boathouse structure would consist of both gravel and concrete, with one area of 

concrete block covered with sod at the western side of the boathouse. Use of gravel on surfaces 

would increase permeability of the soils; however, concrete surfaces would decrease 

permeability of the soils and encourage increased runoff and concentrated flow during 

precipitation events. 

Mitigation 

Impacts caused by covering soils include increased stormwater runoff and its increased 

potential for transport of contaminates to the Potomac River. Treatment of “first flush” 

stormwater by subsurface sandfilters and storage for a limited period would improve water 

quality by filtering out sediments and those chemicals that adhere to sediment particles. 

Increasing ground permeability in more locations on-site would also improve groundwater 

recharge and the subsequent “natural” filtering performed by subsurface sediments. The use of 

pervious geoblock in the turnaround area and gravel for the access lane would also minimize the 

addition of impervious surfaces to the site. In addition, mixing of natural topsoil would increase 

the organic content of the soils and improve soil fertility by introducing organic content, which 

does not exist in many areas of the site. 

No Action Alternative 

The No Action Alternative would not alter topography, soils, or geology. Similar to existing 

conditions, the river would continue to be subject to the direct runoff of stormwater without the 

removal of potential contaminants of surface soils. 

4.4.3 Terrestrial/Aquatic Vegetation and Wildlife 

 

Terrestrial Vegetation

Alternatives A, B or C would have an adverse impact on site vegetation due to the unavoidable 

removal of a number of trees and shrubs on-site. Alternative B (MOA Alternative) would result 

in a slightly smaller number of trees being removed compared to either Alternative A (Zoning 

Alternative) or C (Preferred Alternative). The initial impact of the tree loss would be the 

increased visibility of the construction and operation of the boathouse, as well as reduced 

habitat and canopy for wildlife. There is a small area of natural woody vegetation that would be 

preserved in the southwestern corner of the site under all three alternatives. Maintaining 

mature woody vegetation on the shoreline as much as possible would continue the benefits that 

all the woody vegetation now provides, which includes strengthening of site soils with 

subsurface roots, increased perching locations for birds, increased food source for birds, 

mammals and insects, shading of the site, and increased permeability of soils. Maintaining or 

introducing woody vegetation elsewhere on the site would also provide similar positive impacts. 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-55

All three alternatives include the introduction of native shrub and tree species and the removal 

of a large number of highly invasive and competitive plant species that tend to lower the quality 

of the habitat. This site is largely dominated by a very aggressive invasive plant, Amur 

honeysuckle (Lonicera maackii) and to a lesser, but still significant extent by Japanese 

honeysuckle (Lonicera japonica). Removal of the seed source for these plants could have minor 

positive affects on the surrounding areas. Both plants produce large numbers of apparently 

flavorful berries, attractive to many birds. The consumption and later elimination of the seeds 

by birds results in spreading the plant to surrounding areas. 

All alternatives also include removal of the two American Elms on site, which meet the District’s 

minimum criteria for Special Trees requiring mitigation in accordance with DC regulations. 

Submerged Aquatic Vegetation

 

Alternatives A, B or C would not impact SAV due to the lack of SAV in the vicinity of proposed 

dock along the shoreline directly offshore. Based on the potential for SAV to return to the area, 

the establishment of the dock over the water would block sunlight, reducing a component of the 

favorable conditions for the return of SAV at the site. However, there is no guarantee that plants 

may thrive as their absence indicates that conditions for their existence are currently 

unfavorable. Unfavorable conditions may have more to do with the ambient water quality 

within the Potomac than the suitability/unsuitability for the site to support SAV. Therefore, 

removal of the space from potential SAV growth due to construction of docks of any size should 

not have a substantive impact. 

Aquatic Wildlife and Habitat 

 

Impacts to aquatic organisms could take place due to the construction of the dock and 

gangways, shoreline stabilization, and discharge of water to the Potomac River. Although there 

appeared to be some aquatic habitat on the site (artificial wetland area), the vegetation observed 

indicates that the site is not wet for long enough periods of time to develop aquatic habitat. It is 

possible that a more seasonal habitat may exist (ephemeral wetlands, or vernal pools). The 

water that appears in this wetland is presumed to originate from the C&O Canal system as 

determined by the USACE. Construction of Alternatives A, B or C would result in removing this 

ephemeral system. 

Impacts to benthic invertebrates would not occur with the construction of a boathouse under 

Alternatives A, B or C, but would occur with the construction of the dock. The area covered by 

the dock would be removed from the potential area for inhabitation by benthic invertebrates 

due to shading and lack of water currents. Because these areas are currently not highly valuable, 

and the dock would occupy a very small portion of the available habitat area along the river’s 

edge, the losses to the general ecosystem are considered potentially small. 

There would be limited negative impacts to fish and fish habitat due to construction of any of 

the boathouse alternatives. The existence of the dock could contribute a positive impact 

providing a cool, shaded, and protected area for fish fry and young or prey fish. Negative 

impacts would be the loss of invertebrate (presumably food sources) available to fish. It 

appeared during the SAV study that there were no soft-bodied invertebrates or insect larvae 
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National Park Service 1v-56

within the top few inches of the river bottom at the proposed dock location, and the overall 

effect of the dock coverage on available food sources in the Potomac is considered negligible. 

 

Terrestrial Wildlife and Habitat

Impacts to animal habitat would be similar under Alternatives A, B and C. Although the 

proposed boathouse is smaller under Alternative B (MOA Alternative), the smaller footprint 

would be offset by larger areas for lawn and common areas. 

Birds 

Impacts to bird populations would occur with the removal of mature tree and shrub cover. 

These areas are used for nesting, resting, and food sources (insects and fruit). In addition, 

removal or blocking of shoreline shallows limits the use of the area for shoreline wading birds. 

The existing condition of the banks, consisting of hard fill, limits their use by bank nesting 

species. Increasing the amount of hard fill on the shoreline would further eliminate this type of 

habitat. 

Mammals 

Removal of the trees and shrubs on the site would impact the mammal community here. 

Although much of the plant community is invasive, the components are likely used by mammals 

for browse, supply of small fruits and seeds, and cover. Construction of the boathouse and 

construction and maintenance of the surrounding common areas and lawn under all three 

alternatives would remove the potential for the habitat to re-establish itself here. However, 

similar additional habitat exists upstream and adjacent to the site. Maintaining the native, 

mature trees where possible, and planting native trees and shrubs on the site (incorporating 

native and food bearing plants into the landscaping) would contribute to mitigating the losses. 

Maintaining access to the river would also help to maintain raccoon and deer use at the 

shoreline. 

Reptiles and Amphibians 

It is unlikely that the site currently possesses suitable habitat for herptile species, with the 

exception of the shoreline area. Impacts to herptile habitat may take place at the shoreline of 

the proposed development after construction of the dock. Once the docks are constructed, 

rocks or logs at the shoreline edge would not be available for resting and sunning spots for 

turtles. Also, construction of the proposed boathouse under either of the alternatives would 

result in the loss of habitat for invertebrate species, a food source for herptiles. Therefore, there 

would be a localized impact on reptiles and amphibians due to the proposed project. 

 

Protected Plant and Animal Species

 

The U.S. Fish and Wildlife Service reported that there were no known protected plant or animal 

species in or around the proposed boathouse site (see correspondence in the Appendix). 

Investigation into state-listed species identified the closest site for location of protected plant 

species two miles upstream of the proposed site. The nearest state-listed animal species was 

located almost one mile upstream in the C&O Canal. Therefore, it is assumed that none of the 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-57

proposed alternatives would impact protected species on the site or in the area of the dock and 

gangway. 

Mitigation

Creation of shallows in the vicinity between the dock and the shoreline, or incontiguous areas 

could improve the chances for occurrence of SAVs and, therefore, the organisms that are 

attracted to them, like fish and invertebrates. Grading the shoreline in the vicinity of the site 

from the abrupt vertical to a more gradual slope could also improve habitat here. 

Any trees to be retained on-site will require protection measures during construction. New trees 

and landscaping would be planted on-site which would partially offset the tree loss and effects 

on existing vegetation. Replacement fees for the two Special Trees lost under the District’s 

Urban Forest Preservation Act will also be required, reduced by credits for any new trees 

replanted on-site. 

By maintaining as much of the native, large tree cover as possible, impacts to habitat and wildlife 

would be reduced. In addition, the planting of shoreline areas with native shrubs/trees (on the 

river bank slope) and emergent or submerged aquatic plants within the shallow areas would 

result in attracting birds and waterfowl to the area. Much of the vegetation on the site is not 

native. If some of the existing tree cover is maintained and non-native vegetation is replaced 

with native vegetation, the loss of habitat for bird species could be reduced. A greater 

opportunity exists for this type of planting under Alternative B (MOA Alternative), which has a 

smaller footprint, than either Alternatives A (Zoning Alternative) or C (Preferred Alternative). 

Maintenance of shoreline shallows and strategically locating partially submerged rocks and 

large pieces of driftwood in and around the docking area would also mitigate wildlife and 

habitat impacts resulting from dock construction.

No Action Alternative 

Under the No Action Alternative, there would be no impact to terrestrial or aquatic plant and 

animal species. Without site development, vegetation would remain on-site at current levels, 

providing habitat for wildlife. The No Action Alternative would allow the continued coexistence of native trees and aggressive, non-native shrub species on-site. The proximity of this 

site, which supports a dominant community of invasive species, to areas vulnerable to 

introduction of invasives, would continue the potential for adverse impact on these contiguous 

natural areas. If the University constructs a boathouse at the upstream site, removal of 

vegetation from an established woodland site (as identified in the 1995 Land Exchange EA) 

would potentially impact terrestrial plant and animal species at this location. 
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4.4.4 Noise 

Alternatives A, B and C 

The District of Columbia limits weekday construction and demolition noise to 80 dBA (hourly 

average) from 7:00 a.m. to 7:00 p.m., and 55 dB(A) from 7:00 p.m. and 7:00 a.m. unless granted a 

variance. The construction equipment expected to be used on-site is not expected to achieve 

this noise limit. There are no identified noise-sensitive receptors on-site or adjacent to the site 

that would be affected by the project grading and construction. However, if noise levels exceed 

the District’s construction noise limits, measures to reduce noise and/or a variance to the 

construction noise limit would be required. 

The movement of heavy trucks transporting construction materials could cause an adverse noise 

impact to residences if they are adjacent to the designated travel route. However, material 

hauling is anticipated to operate within the daytime construction hours specified above, and 

hauling routes would be selected to minimize travel along residential areas. 

The site would be visited by large groups associated with the University and visiting schools 

during scheduled regatta events. This increase in visitation would increase ambient noise levels 

at the site during visitation to the site. In association with these visits, there would be an increase 

in vehicle traffic to transport visitors to the end of Water Street which is the closest vehicular 

connection to the site. Therefore, there would potentially be operational noise from Alternatives 

A, B and C during these events, but these noise levels should not exceed ambient noise levels 

typical of the urban area surrounding the site and will not disrupt or affect any noise sensitive 

sites in the vicinity. 

Mitigation

Short-term construction-related noise would be minimized by controlling noise at the sources 

through implementation of best management practices, as necessary, to meet the District noise 

standards. It is recommended that construction specifications require the selection of truck 

routes that would minimize the potential for noise impacts to residences from trucks during 

construction, particularly during truck delivery of construction materials. 

No Action Alternative 

 

Under the No Action Alternative, the proposed boathouse would not be constructed. 

Therefore, construction and operational noise would not be generated, and there would be no 

impacts to noise. 

 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-59

4.5 UTILITIES/INFRASTRUCTURE IMPACTS 

 

4.5.1 Stormwater Management System 

The proposed boathouse would include an underground sand filter in a pre-cast concrete vault 

for the purpose of stormwater drainage and management. This type of system involves flushing 

water through a sand filter for treatment and contaminant removal. As required by the District 

of Columbia and the U.S. Environmental Protection Agency, the first flush of storm drainage is 

forced to flow by gravity through a sand filter media to reduce the concentration of pollutant 

elements. The sizing of the sand filter would be reviewed for approval by the District of 

Columbia Watershed Protection Division of the Department of Health. 

The storm drainage system would intercept the stormwater runoff for on-site runoff resulting 

from the proposed boathouse’s roof and paved pedestrian areas. Currently, off-site runoff 

drains from the towpath and across the CCT as surface runoff. The existing runoff flows from 

the CCT would be directed by inlets and storm drainage pipes to the east of the boathouse and 

out to the river. This storm drainage pipe would bypass the sand filter. The storm drainage 

within the site would be conveyed and eventually discharged into the stormwater management 

quality control structure located on the site. The underground pre-cast concrete structure with 

a sand filter media chamber would treat the first 0.3 inches of runoff from the buildings and 

pedestrian areas. Only after the runoff has been detained for the appropriate amount of time for 

treatment to reduce the pollutant levels, the water would exit the structure, draining into the 

Potomac River. 

Stormwater management for quantity control has been preliminarily waived by the District of 

Columbia, Watershed Protection Division based on verbal discussion during a meeting that 

presented design documentation, and the “Storm Water Management Guidebook” (Watershed 

Protection Division Bureau of Environmental Health Administration Department of Health, 

DC) Section 2.2. No impacts on the tidal levels of the Potomac River are anticipated due to the 

development of the site. Detaining stormwater runoff in the downstream reaches of the 

watershed fluvial flow regime during low tide events is counterproductive to controlling storm 

river peak flow rates. The detention of runoff at the site could increase the flow rate of the river 

if there were a simultaneous occurrence of the flow events from the site and the river. This 

could cause flooding at the point of discharge from the site as it is in the downstream reach of 

the river. 

Alternatives A, B and C 

Under Alternatives A, B and C, the proposed project would include stormwater management 

facilities to provide stormwater quality treatment. Stormwater quantity control, to reduce the 

increases in peak discharge to predevelopment levels, is not required by the District of 

Columbia for this project. The site adjoins the Potomac River which is tidal at the location of 

project and does not have an effect on the river’s tidal flows. Under Alternatives A and B, the 

boathouse project would use a D.C. Standard underground pre-cast concrete sand filter 

structure for stormwater quality control. The sand filter structure will filter the first flush of 

storm drainage runoff as required by District of Columbia and the EPA. 
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National Park Service 1v-60

Action under Alternative B (MOA Alternative) would require the same stormwater management 

quality treatment as described above except the sand filter media surface area in Alternative B 

would be slightly less than Alternatives A (Zoning Alternative) and C (Preferred Alternative), as 

there would be less impervious surface under this alternative. 

No Action Alternative 

Under the No Action Alternative, the current storm drainage conveyance system would remain 

unchanged. The existing park land to the north would continue to drain to the south across the 

site and the undeveloped area of the site would continue to drain into the river. The existing 

area has no stormwater management facilities and none are required by the District of 

Columbia. The No Action Alternative would not affect the conditions of the Potomac River. 

4.5.2 Urban Systems 

Sanitary Sewer System

The project site is not served by an existing sanitary sewer system by the District of Columbia. 

An existing 84-inch sanitary interceptor sewer traverses the site. An inactive 48-inch sanitary 

relief sewer is located north of the site along the bike path. The sanitary sewers are owned and 

operated by DC WASA. Sanitary sewer service, based on a review and the direction of DC 

WASA, would be provided by a sanitary sewer grinder and pump station and 1 1/2–inch force 

main to the existing active gravity sanitary sewer east of the Alexandria Aqueduct abutment. 

The projected average daily wastewater flow to the sanitary sewer from the boathouse is 

approximately 3,600 gallons per day. DC WASA will not allow the site to be connected to the 

existing inactive relief sewer or the interceptor sewer. 

Alternatives A, B and C 

Action under Alternatives A, B and C would include the provision of sanitary sewer service for 

the facility. Service would be provided by a pump station and force main. DC WASA has 

determined that there is adequate capacity in the sanitary sewer system and wastewater 

treatment facilities to accommodate the new boathouse and has approved the connection to the 

sanitary sewer system from the boathouse site. The pump station would be located on the site 

and owned/operated by Georgetown University. Routing of the 380 feet of force main would be 

within Georgetown University’s 15 foot right-of-way from the site to D.C.’s Water Street, NW 

right-of-way at the east side of the Alexandria Aqueduct abutment. The force main would 

terminate in a manhole that would discharge by a new four-inch gravity sewer to an existing 

manhole. The pump station, force main, manhole, and gravity sewer would be built to DC 

WASA and EPA standards. 

The existing 84-inch DC WASA sanitary interceptor sewer will be retained at the boathouse site 

under Alternatives A, B and C. The boathouse structure would be constructed over top of the of 

the interceptor sewer. DC WASA has agreed to allow for the construction if Georgetown 

University encases the sewer pipe in reinforced concrete to protect it during construction and 

afterwards. The encasement would extend beyond the outside walls of the boathouse structure 

under each alternative. Support columns for the boathouse would be based on piles located 

outside the edge and supported below the concrete encased interceptor sewer. Beams 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-61

supported by the columns would span over the sewer and support the boathouse structure. 

Since the interceptor sewer pipe is 84-inches in diameter, any repairs that may be required at the 

boathouse site in the future would be performed from the interior of the pipe. DC WASA will 

also be reviewing this EA and has approval authority of the final construction plans over the 

sewer line. 

No Action Alternative 

Under the No Action Alternative the project site would remain undeveloped. Thus, there would 

be no impacts to sewer service. 

Potable Water

The project site is not served by an existing District of Columbia water main. An existing 12-inch 

water main is located on the east side of the Alexandria Aqueduct abutment. The existing water 

main is owned and operated by DC WASA. Potable water service for the new boathouse would 

require the extension of the water service area for fire protection and domestic usage. 

Installation of a six-inch water main would be required to provide fire protection and domestic 

use service to the site. 

 

Alternatives A, B and C 

Potable water service for the boathouse under Alternatives A, B and C would be provided by the 

extension of a new six-inch water main to the facility. DC WASA has determined that there is 

adequate capacity and pressure in the existing water mains to accommodate water service for 

the proposed boathouse. Routing of the approximately 380 feet of new water main would be 

within Georgetown University’s right-of-way from the site to a DDOT right-of-way at the 

Alexandria Aqueduct abutment in Water Street, NW. 

No Action Alternative 

Under the No Action Alternative the project site would remain undeveloped. Thus, there would 

be no impacts to potable water. 

Natural Gas

The project site is currently not served by a natural gas main. The nearest natural gas service is 

an existing two-inch gas main, located east of the Alexandria Aqueduct, owned and operated by 

the Washington Gas Company. Natural gas service for the proposed boathouse would require 

the extension of the gas service area for the heating system and a clothing dryer (2,020,000 

BTUH Input Rating). Installation of a two- to four-inch gas main would be required to serve the 

project site. 

Alternatives A, B and C 

Under Alternatives A, B and C, natural gas service for the proposed facility would be provided 

by the extension of a new two- to four-inch gas main to the boathouse. Washington Gas has 

received an application for service and has preliminarily determined that there is adequate 
GEORGETOWN UNIVERSITY BOATHOUSE

National Park Service 1v-62

capacity and will process the application to provide service. The extension of the gas main 

would run for approximately 380 feet, located within Georgetown University’s 15 foot right-ofway. A recorded easement to Washington Gas Company from Georgetown University would be 

needed in order to install the new gas main. 

 No Action Alternative 

Under the No Action Alternative the project site would remain undeveloped and not served 

with natural gas. 

Solid Waste Disposal

Currently, NPS provides solid waste disposal service (removal of dead vegetation and litter 

deposited along the CCT) to the project site. Open flat bed trucks and pick-up trucks are used to 

haul solid waste from the site. These vehicles access the site by way of the existing paved trail. 

Alternatives A, B and C 

Under Alternatives A, B and C, Georgetown University would be responsible for solid waste 

removal from the project site. Flat-bed and pick-up trucks would access the site along the 

widened portion of the CCT. Plastic containers (approximately 55 gallon drums) with trash bags 

would be used to contain the segregated recyclable waste streams. The paper products would 

be segregated from the glass and plastic. Any large solid waste items would be picked up on an 

as-needed basis by the University. A solid waste enclosure area to the west of the building 

would be used to store solid waste containers for pick-up by the University staff. Ultimate 

disposal of the solid waste would be through a recycling system and standard landfill disposal 

contracted through Georgetown University. 

No Action Alternative 

Under the No Action Alternative the project site would remain undeveloped. Thus, there would 

be no impacts to solid waste disposal. 

 

 
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Chesapeake and Ohio Canal National Historical Park 

 

IV-63

4.6 CUMULATIVE IMPACTS 

The CEQA regulations require that NEPA environmental analyses address connected, 

cumulative, and similar actions in the same document (40 CFR 1508.25). Three potential 

projects have been identified as potentially having cumulative impacts in conjunction with the 

proposed boathouse (see Section 1.6): the proposed Arlington County Boathouse; the proposed 

George Washington University (GWU) boathouse, and the proposed Georgetown Waterfront 

Park. 

Socio-Economic Impacts 

 

Land Use

 

As discussed in Section 3.1 and 4.1, the proposed Georgetown University boathouse under 

Alternatives A, B or C would provide for the continuation of defined recreational uses along the 

waterfront to the west of Key Bridge. The construction of the proposed GWU boathouse to the 

east of Key Bridge, and the construction of the Georgetown Waterfront Park (in two phases) to 

the east of 34th Street, NW, would extend defined recreational uses from the Georgetown 

University boathouse to the TBC. As part of these proposed projects, public access to the 

waterfront is included and anticipated to increase from the existing conditions. In addition, the 

additional boathouses would result in increasing water-oriented recreational opportunities 

along the Georgetown waterfront. 

Property Ownership

The Georgetown Waterfront Park would retain the land under NPS ownership and no impacts 

to land ownership would occur. The proposed George Washington University and Arlington 

County boathouses will require a land exchange or a transfer of property ownership, which has 

yet to be determined or negotiated. Separate project documentation will be required by NPS for 

each of these projects to identify potential land ownership impacts prior to implementation of 

either project. 

Visitor Experience

The proposed Georgetown Waterfront Park would substantially increase public access to the 

waterfront. Although they are private rowing facilities, public access is required in front of the 

proposed GWU and GU boathouse along the riverfront. Therefore, visitor experience overall 

would benefit from additional waterfront access opportunities as compared to the existing 

conditions. 

During regatta events, while the Georgetown Waterfront Park would expand the area for 

viewing the races, it is anticipated that most spectators would remain near the finish line at TBC. 

Increased use of the two boathouse sites would occur, particularly after events when collegiate 

rowers and visitors congregate at these facilities. Parking and other facilities are available in 

Georgetown to accommodate this increased visitation to these sites. 

The Arlington County boathouse site is within the George Washington Memorial Parkway 

(GWMP) across the river and separate from public parkland on the D.C. side of the river. 
GEORGETOWN UNIVERSITY BOATHOUSE

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Cumulative impacts to visitor experience are not expected from construction or operation of 

this facility; NPS will analyze the environmental impacts of this boathouse to the GWMP and 

site surroundings in separate NEPA documentation. 

Planning Controls and Policies

The proposed GWU boathouse and the Georgetown Waterfront Park would be consistent with 

the planning policies discussed including the Comprehensive Plan for the National Capital, the 

Non-Motorized Boating in the Potomac and Anacostia Rivers, and the Georgetown Waterfront 

Park Plan. The Land Exchange EA and the Section 106 MOA are not applicable to these two 

projects, while the applicability of Washington, D.C. Zoning would be dependent on the design 

that is prepared for the GWU boathouse. The proposed Arlington County boathouse would not 

be subject to the planning policies discussed, although it would contribute to the NonMotorized Boating study’s recommendation of constructing additional boathouses along the 

Potomac River. 

Community Facilities

Cumulative impacts related to community facilities include the potential for additional 

boathouses to be proposed along the shores of Washington, D.C. Both the George Washington 

University and Arlington high schools’ crew teams currently use facilities at TBC to store their 

equipment, for training and for regattas. Construction of new facilities for these crew programs 

would result in removal of outside storage compounds at the TBC. The conversion of an 

existing parking lot to public park space at the Georgetown Waterfront Park site would have an 

overall positive impact to community facilities in this area. Since the site for the Arlington 

boathouse has not been selected, the effect on public park uses and community facilities on the 

Virginia side of the river is unknown. 

Cultural Resources Impacts 

Historic Resources

Historic resources that are affected by the proposed Georgetown University boathouse under 

Alternatives A, B or C are the C&O Canal NHP, Alexandria Aqueduct Bridge Abutment, WCC 

and Key Bridge. Of these, only Key Bridge would be affected by the proposed GWU boathouse 

or the Georgetown Waterfront Park. As discussed under Section 4.2 the waterfront area has 

experienced a variety of development throughout its history. Also, proposed projects would be 

required to coordinate their efforts with NPS, the D.C. Historic Preservation Office, and the Old 

Georgetown Board prior to implementation. 

No cumulative impacts are anticipated due to the development of the proposed Arlington 

County boathouse on historic resources near the proposed Georgetown University boathouse 

site. 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-65

Visual Resources

The proposed GWU boathouse and the Georgetown Waterfront Park are separated from the 

proposed Georgetown University boathouse by the Key Bridge. Also, these are located in a 

urban environment where the visual setting differs from the proposed Georgetown University 

site. Similarly, the Arlington County boathouse site is separated from the project site by Key 

Bridge and the Potomac River. None of the key viewpoints considered for the Georgetown 

University boathouse would be affected by changes at any of these other locations, although the 

two proposed boathouses would result in increased built development along the riverfront as 

seen from other viewpoints. The degree of impact is dependent on the size, architecture, 

landscaping and riverfront treatment of the proposed facilities. 

Transportation Systems Impacts 

Vehicular Traffic and Parking

The GWU boathouse is anticipated to commence construction after the Georgetown University 

boathouse is constructed, and the Georgetown Waterfront Park would begin construction on 

Phase I (between 34th Street and Wisconsin Avenue) in 2006 and could overlap with the 

construction period for the Georgetown University Boathouse. Therefore, there could be a 

simultaneous addition of construction-related traffic on area roadways. The NPS and 

Georgetown University should coordinate construction phasing and schedules to ensure that 

construction traffic does not burden area roadways. 

In the long-term, the proposed GWU boathouse is anticipated to have similar requirements of 

users accessing the site by walking and bicycling since limited parking will be provided on-site. 

During regatta events along the Potomac River, there would be trailers accessing the GWU 

boathouse site and increased visitation to this site before and after these events. However, since 

similar traffic levels already occur for GWU and Georgetown University-related regatta events 

at TBC, overall cumulative traffic levels are not expected to increase significantly. Shuttle 

systems similar to those proposed by Georgetown University should be considered for GWUrelated spectators or visitors from their campus to reduce vehicular traffic in Georgetown. The 

Georgetown Waterfront Park will be a passive waterfront park that would displace public 

parking facilities currently at the site. However, other public parking is available in Georgetown 

to accommodate this use particularly on weekends when parking is available in the numerous 

office buildings in the area. 

If the Whitehurst Freeway is deconstructed, as currently being evaluated by the District of 

Columbia Department of Transportation (DDOT), the traffic patterns in the Georgetown area, 

including access to the Georgetown University boathouse, would change substantially. Due to 

the scale of that project, compared to the minimal traffic-related impacts from the construction 

of the proposed boathouse, no cumulative impacts are anticipated. Further, since there are 

several existing uses present along Water Street, DDOT will have to ensure that if the freeway is 

removed, these uses would continue to have access from public roadways. 

Since transportation systems and access are separate from the other proposed park and 

boathouse facilities on the D.C. side of the river, there would not be cumulative traffic or 

parking impacts expected from the proposed Arlington County boathouse. However, separate 
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traffic analyses and NEPA documentation will be required to address localized impacts to traffic 

and parking facilities on the Virginia side of the river resulting from the proposed facility. 

Public Transit Service

No cumulative impacts are anticipated from the development of the identified projects on 

public transit services. 

Pedestrian/Bicycle Facilities

The Georgetown Waterfront Park will improve pedestrian and bicycle access along the 

waterfront. Also, the GWU boathouse is anticipated to provide pedestrian and bicycle access on 

the waterfront side of the facility which would improve pedestrian and bicycle movement from 

existing conditions. 

The proposed Arlington County boathouse could impact trail systems along the GWMP 

depending on the site chosen for this facility. These impacts will be considered in separate 

documentation for this project. 

River Navigation/Use Impacts

 

In terms of river use, GWU which currently rows out of TBC would move to the new facility 

upriver once their boathouse is constructed. Use of the river for GWU’s practices or regatta 

events will not change from present conditions. 

Once the Arlington County boathouse is constructed, the three schools that currently row out 

of PBC, Capital Rowing Club, and TBC would move to their new facility. Additional users will 

be allowed at TBC replacing these high schools, although NPS also expects to bring boats stored 

outside into the facility to eliminate outdoor boat storage at this site. Wakefield High School that 

currently rows on the Anacostia River will be included in the Arlington facility and would add to 

the number of rowers on the Potomac River. The addition of this school is not anticipated to 

result in a substantial increase in the number of rowers on the Potomac River, but the Potomac 

River Safety Committee should review its river navigation and safety guidelines to minimize 

potential conflicts among river users, as each proposed facility comes on-line. 

 

Physical/Biological Resources Impacts

Water Resources

The development of the Georgetown Waterfront Park is anticipated to be beneficial on water 

resources as more than 10 acres of impervious parking surfaces along the Potomac River would 

be converted to pervious open space. The construction of the GWU boathouse is also not 

anticipated to result in an adverse impact on water resources as the site is currently a paved 

parking area. The Arlington boathouse would add impervious surfaces due to new building and 

parking construction that could potentially impact water quality. These impacts will be 

addressed in separate NEPA documentation for this facility. 
 ENVIRONMENTAL ASSESSMENT 

Chesapeake and Ohio Canal National Historical Park 

 

IV-67

Geology, Topography and Soils

No cumulative impacts are anticipated from the development of the identified projects on the 

geologic, topographic or soil resources. 

Terrestrial/Aquatic Vegetation and Wildlife

The development of the Georgetown Waterfront Park is also anticipated to be beneficial on 

vegetation and terrestrial wildlife as existing parking lots will be converted to vegetative open 

space. The construction of the GWU boathouse is also not anticipated to result in an adverse 

impact on vegetation and terrestrial wildlife as the site is currently a paved parking area. The 

Arlington Boathouse could result in loss of existing vegetation and habitat depending on the site 

chosen. Also, there could be minor impacts on benthic invertebrates due to the construction of a 

dock for both the GWU and the Arlington County boathouse. However, these impacts would 

be localized and would have to be dealt with at a project level. 

Noise

Due to the distance between the various project sites, no noise-related cumulative impacts are 

anticipated due to the identified projects. 

Utilities/Infrastructure Impacts 

 

Infrastructure related impacts are anticipated to be minimal due to the proposed projects since 

all three boathouses and the proposed park facilities are in an urban area with access to nearby 

utilities systems. The proposed boathouses replace current users operating out of Thompsons 

and along the Anacostia so overall system capacities would not be significantly affected. Each 

boathouse facility and comfort stations or other park facilities included in the Georgetown 

Waterfront Park need to be analyzed in terms of specific connections to local utilities systems 

serving these sites 
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