Category: Resources

State’s Transportation Board delays vote on North-South plan

Posted on by Andrew Brown

Virginia’s Commonwealth Transportation Board on May 15 delayed a vote to accept the state’s North-South Corridor master plan that includes a proposal to more directly link Loudoun and Prince William’s roadways.

The North-South plan includes several regional projects, including the so-called Bi-County Parkway, which extends Route 234 from I-66 in Prince William to Route 50 and Northstar Boulevard in Loudoun. The project is meant as a north-south alternative to U.S. 15 and Route 28 that would provide greater connectivity between the two counties.

Pro-business officials from both Loudoun and Prince Williams have been adamantly in favor of the plan, while environmentalists and more conservative-growth groups are doing their best to thwart the project.

Tony Howard and Rob Clapper, presidents of the Loudoun and Prince William chambers of commerce, receptively, favor the Bi-County proposal. They issued a statement in late April after the study was released expressing their support for the project and dismissing the vocal opponents, whom they claim are misleading the public.

“The need for improved north-south connectivity between Loudoun and Prince William Counties has been well-documented by transportation and regional planning experts for decades,” the chamber presidents said in a prepared statement. “ … improvements to Route 234 and construction of a new Bi-County Parkway (Route 234 Extended from I-66 to Route 50 and Northstar Blvd.) will not require closure of Route 29 through the Battlefield. In fact, the closing of Route 29 through the Battlefield could only be triggered by construction of the Manassas Battlefield Bypass, a project for which there is currently no funding and, in our belief, is a project that is unlikely to occur.”

U.S. Rep. Frank Wolf (R-10th), however, is urging thoroughness in the review and advancement of the project. Before last week’s vote Wolf sent a letter to Gov. Bob McDonnell pushing for the delay.

“Thousands of people have moved to Prince William and Loudoun counties since the project’s master plan was approved in 2005,” Wolf said. “More public hearings must be held and more citizen input must be received before any final decision is made about the North-South Corridor.”

Opposition has been firm from environmental groups, notably the Piedmont Environmental Council (PEC) and the Coalition for Smarter Growth. PEC officials have gone far enough to call the proposed project an “outer beltway,” something project advocates have quickly dismissed.

“Rather than solve traffic problems, a billion dollar Outer Beltway will spark higher levels of residential development within the Prince William Rural Crescent and the Loudoun Rural Transition Area, adding more traffic to already congested east-west commuter routes. It will bring noise and pollution, split properties and neighborhoods, and reduce community access to local roads and services,” states a section on PEC’s website.

Click here to read the original story>>

Friends Around Town

Posted on by Andrew Brown

Your Friends have been out in the community over the last month and we’re grateful to our partners for engaging us in these fascinating opportunities.  Dan Reed and I were both panelists during a Montgomery Housing Partnership breakfast focused on social media in community engagement.

Montgomery Housing Partnership’s mission is to expand and preserve affordable housing in Montgomery County – something that will become an issue in White Flint if the county truly wants to draw a younger demographic.  MHP doesn’t just advocate, they also walk the talk by “acquiring, rehabilitating, building and managing quality affordable housing.”

061113 white flint

Friends of White Flint was very proud to be part of Coalition for Smarter Growth’s Walking Tours and Forum Series.  ”White Flint: From Drag to Desirable” was the topic that kicked off this season of walking tours – and to a sold out crowd!  Nearly sixty people joined Stewart Schwartz of CSG, Nkosi Yearwood of the Planning Department, Tommy Mann from Federal Realty and me on a beautiful morning’s trek through the past, present and future of White Flint.

The tour was a great way to feel and see the differences between streets that solely car-focused, as opposed to those that consider all travelers.  Features like tree buffers, bike lanes, benches and trash cans equalize priorities among pedestrians, bikers and drivers.  Many of our main White Flint streets still have a long way to go in becoming truly walkable.

Friends of White Flint also hosted a Developer Showcase on April 30th in the Whole Foods Rockville café.  It was an opportunity for the community to browse new projects in White Flint’s future, and meet the people behind the ideas.   Paladar Latin Kitchen, Montgomery County Parks Department (Wall Park), LCOR (North Bethesda Center), Lerner Enterprises (White Flint Mall), and Federal Realty Investment Corp (Pike & Rose) were all available to chat, show their plans and share guacamole.  Friends of White Flint member Chevy Chase Land Company was also present with information about their plans for Chevy Chase Lake.

Over 100 visitors checked out the exciting plans for White Flint and appreciated seeing the images up close.  If you weren’t able to join us that rainy morning, let us know if you’d like us to host a similar event on an upcoming evening!

Finally, Friends of White Flint has begun a monthly presence at the Pike Central Farmers Market!  Find us among the food trucks and produce and learn more about your community while you browse!

And, wherever you see us – don’t hesitate to share your thoughts on the plans for White Flint.  We’re here to have a positive and consensus-building conversation.  Join in!

Click here to read the original story>>

‘Outer Beltway’ in D.C. Suburbs Meets Opposition From Residents, Lawmakers

Posted on by acustis
A proposed highway that would skirt a Civil War battlefield is raising hackles in Virginia.

A group of six conservative Republican state lawmakers, flanked by dozens of local homeowners, announced their opposition on Monday to the McDonnell administration’s plan to build a 45-mile, major north-south highway connecting I-95 in Prince William to Rt. 7 in Loudoun, arcing west of Dulles International airport and brushing the western edge of Manassas National Battlefield Park.

The highway concept — a tri-county parkway — has been around for years and now carries the official name of “north-south corridor of statewide significance.” But to opponents it’s an “outer beltway.”

Waging war on I-66

The group held a news conference at the intersection of Rt. 234 and Rt. 29, a pair of two-lane roads slicing through rolling green fields that witnessed two of the Civil Wars most important engagements. Opponents of the highway plan said state transportation officials are waging war on commuters who use nightmarish I-66, one of the most congested highways in the region.

Because the north-south highway would pave over 12 acres of the Manassas historic district and four acres of actual battlefield land, the National Park Service is seeking a deal with the Virginia Department of Transportation to build a bypass running east-west on the battlefield’s northern edge. The construction of the bypass and north-south highway would then allow the state to close Rts. 234 and 29 to all but visitor traffic to Manassas battlefield.

“When you close 29 you condemn those people who travel on 66 to eternal congestion,” said State Delegate Tim Hugo, who said motorists would clog I-66 instead of using the battlefield bypass once 29 is closed. “It’s north of the battlefield.  I think there are serious questions as to whether anyone would even use it.”

To some local homeowners, the supposed benefits of the north-south highway mean little when compared to the prospect of losing their homes. The 600-foot wide corridor under consideration would potentially condemn about 100 homes in the Gainesville area, lawmakers said.

“It would be an easier pill to swallow if this was to help commuters who are traveling east to west on Rt. 66, but it does nothing for that,” said Alan Johnson of Pageland Road.

The state’s vision for a major, tolled highway providing multiple lanes for cars, buses and truck traffic and turning Dulles Airport into the East Coast’s premier freight hub is raising a range of issues, not least its estimated price tag of $1 billion. Opponents say the plan also neglects east-west traffic demand in Northern Virginia, will contribute to sprawl and air pollution, and set a precedent that national park land can be paved over in the interest of commercial development.

Confidence in the project persists

In response to these criticisms, Virginia Transportation Secretary Sean Connaughton defended the project as necessary to meet the demands of future job and population growth in one of the fastest developing areas of the state.

“Anyone who has ever seen the Rt. 28 and I-66 interchange knows full well that the traffic demand is north-south as well as east-west,” said Connaughton.

The Republican lawmakers at the Manassas news conference suggested Rts. 234 and 29 through the battlefield might be closed before the north-south highway and battlefield bypass are completed. But the transportation secretary said no such plan is under consideration.

“Under no circumstances will we close the roads before the corresponding facilities are complete,” said Connaughton, who said improvements to I-66 will also be finished by the time the north-south highway is finished.

Real estate developer Gary Garczynski, the Northern Virginia representative on the influential, 17-member Commonwealth Transportation Board (CTB), echoed Connaughton’s confidence.

“There is no intention by the CTB at this time to close [Rt. 29] until the battlefield bypass is funded and built,” he said.

The CTB is expected to accept the state’s study of the “north-south corridor of statewide significance” at its next meeting in May.

Read the original article on Transportation Nation >>
Photo credit: Martin DiCaro. 

White Flint: From Drag to Desirable

White Flint: From Drag to Desirable

Posted on by acustis

White Flint is fundamentally transforming from an aging auto-oriented commercial corridor to an accessible and vibrant walkable community. On April 27, 2013, CSG brought together together Federal Realty’s Tommy Mann, Friends of White Flint’s Lindsay Hoffman, and Nkosi Yearwood, the Montgomery County lead planner for White Flint, to update us on progress, explore what’s changing and what it means for the neighborhood, and what we can expect in this area as it becomes one of the Washington region’s newest walkable communities. See the event program.

Testimony before the Hon. Muriel Bowser, Chair of the Committee on Economic Development and Housing re: FY 2014 Budget Oversight for DMPED and DHCD

Posted on by Andrew Brown

Please accept these comments on behalf of the Coalition for Smarter Growth. We are a regional organization based in the District of Columbia focused on ensuring transportation and development decisions are made with genuine community involvement and accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas.

DMPED should recommit to leveraging public land dispositions for affordable housing

We are greatly disappointed in DMPED’s reduced expectations for affordable housing in new public land dispositions. Given the increasing challenge of housing affordable to our residents, we urge the Council to ensure DMPED recommit to leveraging public land dispositions for affordable housing, including for very low income households. In our 2012 report, Public Land for Public Good, we show that the District has and can do great things with its city-owned land. We are disappointed that DMPED is departing from the practice of the past decade to ask for 20-30 percent of affordable housing in public land dispositions affordable to households earning 30%, 50%, 60% and 80% Area Median Income (AMI). We are also surprised that the Mayor’s Housing Task Force dropped any recommendation to make the most of public land sales for affordable housing and sent this issue to the future study list.

Under DMPED’s current leadership, commitment to affordable housing in solicitations for public land dispositions has steeply declined. DMPED no longer asks for a specific percent of affordable housing or specific income levels. Instead, DMPED asks that proposals comply with or exceed the Inclusionary Zoning (IZ) law, which is already required for most residential development. IZ sets a minimum of 8-10 set aside at 50-80% AMI, with most income targeting at 80% AMI. To compensate, developments receive a 20% bonus density. Given the city can (and used to) leverage the value of its own land to subsidize housing, we should expect much more from public land deals. We recommend that DMPED restore the earlier practice of to asking for a 20-30% set aside with income targeting at the 30% AMI, 60% AMI and no more than 80% AMI income levels. (See tables 1 & 2 below).

This drop off in affordable housing in public land dispositions as a priority is particularly surprising given the attention the administration has put on renewing efforts to preserve and create more affordable housing. Public lands are an important tool for creating new affordable housing that the administration should not abandon now. We ask the council to ensure we are making the most of the unique opportunity to leverage the value of the District’s land to create more affordable housing through the public land disposition process. Public land disposition and development requests should clearly ask for and prioritize proposals that offer substantial amounts of affordable housing, including units affordable to those earning 30 percent AMI. As was the practice in the past, we ask that requests specify the city is seeking 20 percent to 30 percent of the total number of residential units affordable at 30 percent and 60 percent AMI for rentals, and up to 80 percent AMI for ownership. We suggest table 2, below, as a model. In addition, we ask that DMPED better coordinate with other agencies to pool resources to ensure the production of housing affordable at deeply affordable levels as a part of larger mixed income or all affordable development.

DHCD – support $100 million to affordable housing, ensure IZ & ADUs have support they need

Regarding DHCD’s budget, first and foremost, we want to express our support for the $100 million commitment to affordable housing, with $87 million going to the Housing Production Trust Fund. We commend the Mayor for this commitment and ask the Council to support this. These funds are critically important to addressing our city’s escalating housing prices that are burdening a large share of D.C. households with higher and higher housing costs.

Inclusionary Zoning & affordable dwelling unit management

IZ administration has experienced significant problems in the start up phase. DHCD has indicated that is making headway addressing these significant challenges. DHCD will propose revisions to overly cumbersome administrative regulations, which should improve the process. DHCD has worked with Office of Planning and the Zoning Commission to resolve conflicts with FHA mortgage lending standards. DHCD has solicited for additional assistance to implement IZ and Affordable Dwelling Unit (ADU) programs. These are all important steps to addressing the major administrative challenges IZ implementation has encountered. We remain concerned that the office responsible for administering IZ and ADUs is understaffed. We suggest that at a minimum, and new Capital City Fellow be added to their small team.

I want to thank Director Michael Kelly and his staff for their openness and responsiveness to us.

Thanks also to Chairman Bowser’s keen interest in ensure these programs work, and affordable housing opportunities are increased.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Table 1
Table 2

Getting Parking Right

Getting Parking Right

Posted on by acustis

Parking policy guru Jeff Tumlin will outline sixteen ways to tailor parking policies to meet parking demand while reducing some of the negative effects of current policies. D.C. Department of Transportation’s Associate Director Sam Zimbabwe will present the city’s latest thinking on how to take the lessons learned from around the country to craft parking policies that support community goals. Join us to learn about best practices and what D.C. government is planning to do to get parking right.

Testimony before Martin Grossman, Director of the Office of Zoning and Administrative Hearings in Opposition to Special Exception Request for S-2863, Costco Wholesale Corporation

Posted on by Andrew Brown

Dear Hearing Examiner Grossman:

Please accept these comments on behalf of the Coalition for Smarter Growth. Our non-profit organization works to ensure that transportation and development decisions in the Washington, D.C. region, including the Maryland suburbs, accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas.

We want to express our opposition to the Special Exception request for the Costco automobile filling station – a large scale gas station which will attract vehicle trips from outside the local area. We believe this proposal is wholly inconsistent with the 2012 Wheaton CBD and Vicinity Sector Plan, and antithetical to the goal of promoting transit-oriented, pedestrian-friendly development within one half mile of a Metro station. The Wheaton Sector Plan area not only offers high quality Metrorail service, but also extensive bus service and a planned rapid transit service. This concentration of transit services will increase the share of trips made by transit, encourage more walking, and reduce how much people drive in the area.

As a regional organization, we advocate for well-designed transit- and pedestrian-oriented development which focuses more housing and commercial activities within an easy walk of Metro stations and other high quality transit services and historic downtowns. We seek to mitigate existing automobile-oriented uses in transit districts, and prohibit new ones. Reducing auto-oriented uses and their impacts are important to fostering a public realm and private development that better cater to pedestrians rather than prioritize the movement of motor vehicles. Uses such as gas stations, automobile repair services, drive thrus, and similar uses that attract motor vehicular traffic and encourage automobile-oriented designs such as additional driveways, wider driveways, surface parking, and curb cuts should be minimized, reduced, and in some cases, prohibited in transit districts like the Wheaton Sector Plan area. The proposed, a high volume gas station, is an unnecessary new auto-oriented use that would detract from the county’s and our efforts to create a more pedestrian-friendly environment around the Metro station.

The Plan specifically identifies the existing “auto-oriented uses” of the area as one of the key issues to be addressed through the implementation of the Sector Plan. The addition of a large scale gas station would compound the “auto-oriented uses” problem identified in the Sector Plan. We recognize that the site of the gas station is on the outer part of the mall property and Plan boundary. Yet we find the proposed use not a neutral use related to our goals to improve the pedestrian environment, but rather a use that actively degrades the pedestrian environment and works against Sector Plan goals. With such a large scale gas station, additional vehicle trips will be attracted to the transit district from outside the local area simply for the purpose of refueling vehicles with cheaper gasoline. This regional automobile service use  contradicts the Sector Plan’s and our goals to reduce vehicle miles traveled. Introduction of a new large scale gas station would directly oppose the Plan’s guidance to:

“Provide better pedestrian connectivity and support safe, secure, and appealing street level activity” (p. 25)

In an area like the Wheaton Sector Plan area, we have often found that the transition from auto-oriented land uses take time, but can be phased in to create more transit-oriented and pedestrian-friendly development. The Wheaton Sector Plan accommodates the existing auto-oriented regional mall surrounded by surface parking, but seeks to manage the negative impacts on pedestrians but proposing pedestrian access improvements, pedestrian-oriented street design changes, and encouragement of redevelopment to a more pedestrian-friendly design. Preventing new uses that would further degrade the transit district is also an important part of progressing towards a more pedestrian-friendly Wheaton Sector Plan and Metro station area. The large scale gas station would degrade the pedestrian environment by attracting additional automobile trips to the area and force more automobile-oriented designs for public rights-of-way to accommodate this auto-oriented use. Preventing this kind of use also promotes our overall goals to support greater use of transit, and build safe, walkable places, especially around major transit hubs.

For all of these reasons, the Coalition for Smarter Growth urges denial of the Special Exception application for the Costco automobile filling station.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Testimony before the City of Alexandria City Council re: Coordinated Development Districts #21/#22 and Design Standards for Beauregard Small Area Plan

Posted on by Andrew Brown

Good afternoon. I am Stewart Schwartz, Executive Director for the Coalition for Smarter Growth.

The Coalition for Smarter Growth closely tracked the planning for the redevelopment of the Beauregard corridor and testified in support of the new plan. We have studied the staff report for the new Coordinated Development Districts in great detail.

Our review of the staff report, community advisory committee reports and other supporting documentation indicates a very high degree of due diligence and analysis. The city has invested significant resources in ensuring all the pieces fit together in this complex rezoning, including the design standards, the staging related to transportation improvements, and the developer commitments to financing public infrastructure and affordable housing. The city also established community advisory committees to collect ongoing input and provide independent recommendations to the staff, Planning Commission and Council.

Mixed-use, mixed-income development in walkable, transit-oriented development offers the best way for our region to grow while managing traffic, increasing access to jobs for all incomes, and reducing energy use and pollution, including greenhouse gas emissions.

Understandably, the key area of ongoing concern has been affordable housing and we understand the concern of existing residents who depend on affordable rents. Entendemos. The Coalition for Smarter Growth has included affordable housing policy as a core component of our work including support for housing trust funds, inclusionary zoning, use of public land, zoning and other tools.

Market rate affordable housing is under pressure and at risk due to the region’s continued population growth and the traffic that is encouraging residents to live closer to jobs and transit. It is this demand to live close to jobs, transit and the core, that has developers like JBG seeking out larger parcels of land with the potential for significant redevelopment, such as the garden apartments within the Beauregard community.

Most of the garden apartments are found in an area that the city included in CDD #4 a number of years ago, which created an incentive for purchase and redevelopment, but without a set-aside or other affordable housing preservation strategies for the area. Given the current situation, CDD #21/#22 offers the best opportunity to secure long-term committed affordable housing and a range of other community benefits.

We are glad that the city conducted a tenant survey to better understand the needs, and that as a result, the city has made adjustments to the affordable housing plan, tenant transition, and associated financing plan, including increasing the number of units for households with incomes at 40% of Area Median Income and below.

The plan’s housing goal and an effective strategy to create 800 long-term committed affordable units are essential. It includes the largest developer contribution ever made to affordable housing in our region – $66 million, and the city’s substantial commitment using tax increment financing. It appears to now be better tailored to the needs identified in the tenant survey with a focus on people earning $15,000 to $65,000 per year, depending on family size. Over 50% of the 800 units will be at 40% AMI and below.

Redevelopment of the garden apartments will happen over many years, providing time for creative affordable housing deals, especially with non-profit housing developers, and other strategies to offer additional committed affordable housing units. Espero que; creo que la Ciudad va a hacer lo que es necesario para ayudar a la communidad con este cambio.

The city has drafted an Affordable Housing Master Plan, which is much needed. We’ve lost too much because of not doing enough in the past. The plan should also be improved with clear numerical goals, dedicated funding, and the city’s priority attention to adopting the policies and programs necessary to more effectively preserve and expand affordable housing. At the same time, the city also needs the tax base from well-planned, competitive transit-oriented redevelopment to create the taxpayer resources necessary for this affordable housing strategy.

In conclusion and weighing the information before you today, we recommend that you support the rezoning to Coordinated Development Districts 21 and 22. Thank you.

Stewart Schwartz
Executive Director

Letter to Stephen Walter, Parsons Transportation Group Re: I-66 Tier 1 Draft EIS, Comments by the Coalition for Smarter Growth

Posted on by Ted Van Houten

Dear Mr. Walter:

The Coalition for Smarter Growth, with members and partner groups in Northern Virginia, hereby submits these comments on the Virginia Department of Transportation’s Tier 1 Draft Environmental Impact Statement for I-66 (“outside the Beltway”).

We agree that addressing transportation in the I-66 corridor should be a top priority. We are pleased that the study considers a range of transit modes and focuses on person-trips.  However, we are concerned that this 2040-oriented study fails to offer a long-term, sustainable and effective solution both for 2040 and the decades following. Presuming one of the build alternatives meets the capacity needs for 2040, what happens after 2040? More lanes?

The study appears to favor the managed lane (congestion-priced, high occupancy toll lane scenario), but does that scenario really offer the long term demand reduction and capacity that a high-capacity transit with transit-oriented land use would offer?

Documentation is far too limited for why this study favors managed lanes and there is no analysis of the comparative effects on land use of each of the modes.

The most significant shortcoming is the failure to evaluate an integrated land use and transit scenario that would offer a way to more effectively reduce the growth in driving demand and provide the capacity to handle the demand that does come. We have made this comment repeatedly with VDOT studies, yet never do VDOT studies include such a scenario.

The land use discussion is particularly thin and at too high a level (see 4.1.1.1). As was found in the Tysons study, mixing uses, providing a local grid of streets, and measuring the results using more compact traffic analysis zones can show remarkable SOV trip reductions and transit mode share increases — networking these centers with Tysons could provide synergistic vehicle demand reduction benefits, while improving reliable access to jobs.

The study should evaluate an alternative land use scenario linking transit-oriented development (compact, walkable, mixed-use communities linked to transit), with land conservation of rural areas, and high capacity transit, in order to maximize transit trips, minimize vehicle trips, and to provide the means to handle future growth. The study explicitly states that it has excluded a systems oriented transit scenario, but a systems oriented transit and TOD scenario is exactly what’s needed and should be combined with TDM measures and targeted bottleneck and safety improvements in a composite scenario.

Table ES-1 shows that a transit approach matched with TDM and addressing chokepoints would rank highest in meeting the needs identified in the Purpose in Need, yet the study did not provide an integrated scenario linking transit, TDM and addressing chokepoints.

Since the Council of Governments adopted Region Forward Plan and Compact is framed as a transit-oriented future for the region, this study should have studied such a regional scenario. Once again a too narrow corridor focus improperly exclude the networked transit and TOD solution.

The Purpose and Need Statement fails to include what should be key goals for the corridor.  While the stated purpose ” is to improve multimodal mobility along the I-66 corridor by providing diverse travel choices in a cost-effective manner, and to enhance transportation safety and travel reliability for the public along the I-66 corridor,” it should also include goals to reduce demand for single occupant vehicle trips (including vehicle miles traveled and vehicle trips), by increasing mode share for non-auto trips through transit and changes in land use — changes in both the location of future development and improved community design which would result in higher transit ridership.  Again, looking to the long term, the stated goals cannot be met unless demand reduction goals are also a core goal and focus of this study.

In addition Purpose and Needs states, “the identified needs to be addressed include: transportation capacity deficiencies, major points of congestion, limited travel mode choices, safety deficiencies, and lack of transportation predictability,” orients the study too much toward capacity expansion and fails to include as key needs, such as reducing driving demand and improving land use to reduce driving demand and increase non-auto mode share.

The study is also artificially separated from the analysis of I-66 inside the Beltway even though a substantial proportion of inbound trips travels inside the Beltway and will have impacts all the way into D.C..

The study also inappropriately and without explanation excludes a dedicated transit and HOV scenario, leaving expanded HOV scenarios completely out of the study.

While the practice is to include all projects in the CLRP in the No Build scenario, inclusion of the controversial Route 234 extension (TriCounty Parkway western alignment) which would open up rural areas to more development and increase traffic would likely make the No Build perform worse than it would otherwise.

By separating a full tolling analysis from this story, it’s not possible to get a full picture of the effects of HOT lanes on transit usage, carpooling, general purpose lanes and parallel roadways. A full toll effects analysis should not be deferred to a separate study.  Moreover the relative benefits of privately tolled should be compared to public tolling, including the ability to use public tolling to fund more transit service in the corridor.

We were very concerned by the way Tiering of the I-81 study, which also failed to study a composite solution recommended by our group, was used to later foreclose the offering of a composite alternative at Tier 2. In addition, by tying the Tiering with the concept of “projects of independent utility,” a too general and flawed Tier 1 study can then open the door to allowing VDOT to move forward with whichever project it wishes and to foreclose more effective system wide alternatives.  Here, the issue may involve specific segments, but equally likely it would allow VDOT to move forward with just one component of the Integrated Concept Scenarios — such as tolled, managed lanes. In fact, the discussion of the ICS, very clearly proposes to allow VDOT to move forward with just one component. Read with other chapters of this study, it appears that the study is framed to favor the tolled, managed lanes.

The study cites the 1999 MIS in a history of previous studies but fails to note the stated preference of elected officials at that time (at least Fairfax County and probably others) for a transit-first solution.

We are also concerned that the Memorandum of Understanding, which we do not believe was subject to public comment, is also structured to focus on and favor a tolled, managed lane scenario, rather than another potentially non-tolled scenario.  The study states that per the MOA, decisions on the following will be made upon completion of the Tier 1 study:

  • The concepts to be advanced for the I-66 corridor, including transit improvements, transportation demand management strategies, and/or roadway improvements. Within these concepts, consideration will be given to managed lanes and tolling;
  • The general location for studying future highway and transit improvements in Tier 2 NEPA document(s);
  • Identification of projects with independent utility to be evaluated in Tier 2 NEPA document(s) and evaluated pursuant to other environmental laws; and
  • Advancing tolling for subsequent study in Tier 2 NEPA document(s).

With points one and four focused on tolling, and the potential intention to use the “projects of independent utility” to advance only the tolled portion of an ICS, the study appears to improperly lean toward one approach over others — the tolled, managed lanes.

The entry and exit tables are confusing because it’s not clear from the use of eastern, middle and western tables where the greatest demand may lie nor what the primary origin and destination data might be.

The COG growth projections which are used by this study fail to account for the dramatic changes in demographics, market demand and energy prices, nor a future of higher energy prices.  In turn, having had one of the largest expansions of the federal government in recent history shifting to a very likely downsizing, especially in defense, means that the growth projections should be reevaluated.  This can mean substantially less growth in outer areas. In turn, it’s important to note that the allocation of growth within the region is a subjective exercise and that high growth assigned to outer areas is not inevitable, nor is the form of that growth.

In addition, use of percentages for growth can be misleading and tables should be provided to show the magnitude of growth.  In addition, the report may overstate Gainesville/Haymarket growth while understating Tysons Corner growth.

While VDOT might argue that it is not responsible for land use, when billions of dollars are at stake, a thorough analysis of cost-effective alternatives must look at alternative growth scenarios.  And simply because an agency is not responsible for a subject area like land use, doesn’t mean it shouldn’t be studied in an EIS as a potential piece of an alternative. VDOT itself has published a report on the benefits of “Transportation Efficient Land Use” yet inappropriately eliminates such demand management solutions from this corridor.

Again in chapter 3 (figure 3-1), the process for evaluating solutions is flawed by ruling out TDM and system/out of corridor solutions early in the proces.

The four step evaluation approach (3-2) is also flawed for failing to look at alternative growth scenarios and changes in land use combined with other TDM approaches, meaning that the total travel demand entered in the first step may be higher than it would otherwise be.

We don’t understand and are concerned by the statement on 3-6 that “Demand is also based on
unconstrained capacity on I-66 itself (although connecting roads were constrained) in order to
ascertain total demand.”  That would seem to inflate the travel demand and overly favor capacity expansion solutions.

It doesn’t appear that the study factors in the congestion feedback signal from congestion in the general purpose lanes which would lead to higher transit use or new residents and jobs moving to transit-accessible locations as has been happening in recent years.

It’s not clear from Table 3-1 if the transit ridership numbers are based on transit-efficient land use or a continued pattern of auto dependent development in Prince William and western Fairfax, where transit efficient development might result in higher transit ridership.  It’s also not clear whether the managed lane scenario counts transit trips in the lanes — trips that could also be achieved by HOV/transit lanes without tolls.

Again, Table 3-3 shows that combining transit with a chokepoints solution could meet more components of the Purpose and Need than the managed lanes.

Table 3-4 lacks adequate supporting documentation and is a virtual “black-box” to the public.  The ICS alternatives fail to include non-tolled HOV with transit in any of the alternatives, which biases the study to managed toll lanes. It does not appear that the transit ridership factors in congestion feedback from the general purpose lanes.

It is unclear how Table 3-4 and Table ES-2 footprint widths are calculated.

The “Key Findings” (3-9) don’t appear to be fully substantiated.  For example, it states:

  • “Other than the two-lane Managed Lanes concept (ML2) which accommodates autos and buses alike, single mode improvement concepts result in large corridor width, high cost, poor efficiency, and/or inability to serve total demand.”  Would that indeed be true of Metrorail or an HOV/BRT approach, with each tied to transit-efficient land use?
  • Another stated finding is that:  “The share of trips made either by transit or in multi-occupant vehicles for those ICSs that perform best against the Table 3-4 metrics reach over 80 percent. While accommodating such high percentages of trips by transit and multi-occupant vehicles would be very difficult, the fact that these percentages are so high is indicative of the benefit of including transit and managed lanes that can carry large numbers of person-trips as part of the solution.”  If that is the case, why not use an HOV and transit solution rather than only use tolled, managed lanes with the various transit modes?
  • Another stated finding is that “The projected peak period travel demands in the corridor highlight the need for a transportation solution that provides space efficiency – the ability to carry large numbers of persons within limited spaces. Managed Lanes and fixed-guideway transit (in descending order of carrying capacity: Metrorail Extension, Bus Rapid Transit, and Light Rail Transit) provide space efficiency.  But do managed lanes really provide space efficiency when the interchange needs of having dual sets of ramps are factored in?  The interchanges on the 495 HOT lanes have taken a substantial number of acres with a profound impact on surrounding communities.

Conclusion:  It is critical to get this Tier I study right because completion of this study will likely foreclose consideration of alternatives at the Tier 2 stage. The study appears biased toward the managed lane approach by failing to analyze non-toll HOV with transit alternatives and by failing to analyze a composite transit, transit-efficient land use, TDM and chokepoint alternative (a systems oriented approach and one that would meet the regional goals in Region Forward).  The study does not substantiate the footprint, ridership, table 3-4 ratios, and costs; and the “findings” are also unsubstantiated. Effects on land use are not addressed.

  • We request the opportunity for additional time for peer review of this study by independent transportation planners.
  • We also request that VDOT’s report on Transportation Efficient Development be considered in this study along with the goals of Region Forward.
  • Finally we request that this study be delayed until the composite alternative that we highlight is analyzed using alternative growth and land use.

Thank you.

Stewart Schwartz
Executive Director