Category: Virginia

STATEMENT: Virginia Commonwealth Transportation Board Approval of $17.6 Billion Six-Year Capital Spending Program: A Road to Ruin?

Statement on Virginia Commonwealth Transportation Board Approval of $17.6 Billion Six-Year Capital Spending Program

A Road to Ruin?

Today with no debate, the appointed Commonwealth Transportation Board approved the largest transportation spending program in Virginia history, $17.6 billion in capital spending.

“We are shocked by the lack of discussion of the spending priorities in the Six-Year Plan, by the failure to tie the program to specific policy goals, and the assumption that simply adding road capacity will solve our transportation problems.  The plan includes a number of wasteful mega-projects that have been strongly criticized as unnecessary including Route 460 ($1.4 billion), the Coalfields Expressway ($2.8 billion), Charlottesville Bypass ($244 million), N-S Corridor ($1 billion plus), and a long range $11.4 billion plan for I-81.

The CTB doesn’t understand the benefits of more efficient land use – of cities, towns, and compact transit-oriented development —  along with transportation demand management programs (carpooling, telecommuting, etc.) that reduce driving demand.  They don’t understand changing demographics and market demand that have led to big declines in vehicle miles traveled.  The plan includes just 9% of the total for transit even though 69% of the state population lives in the Urban Crescent.

In short, we believe this program will be remembered for squandering billions of tax dollars while making Virginia’s patterns of development less efficient, more oil dependent, and less competitive.”

Stewart Schwartz, Executive Director

 

About the Coalition for Smarter Growth

The Coalition for Smarter Growth is the leading organization in the Washington D.C. region dedicated to making the case for smart growth. Our mission is to promote walkable, inclusive, and transit-oriented communities, and the land use and transportation policies needed to make those communities flourish. To learn more, visit the Coalition’s website at www.smartergrowth.net.

 

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Preservation Virginia lists land slotted for Tri-County Parkway as ‘endangered’

Historic Civil War parkland slotted for a controversial new parkway that would connect the counties of Prince William and Loudoun has made the “endangered” list of one of the oldest non-profit preservation organizations in the country.

Preservation Virginia, founded in 1889, focuses on the preservation of historic sites around the state, including Jamestown and the Cape Henry Lighthouse in Virginia Beach. For the first time, the group included land slated for the proposed Tri-County Parkway, a 10-mile, four-lane thoroughfare that would connect I-66 in Prince William with Route 50 in Loudoun, on its list of “most endangered” sites for 2013.

Part of the parkway, which has drawn increased scrutiny in recent weeks, would run through historic Manassas Battlefield land and rural Prince William.

“The Tri-County Parkway would run directly past the August 28, 1862 position of the right flank of Confederate troops led by Stonewall Jackson and the left flank of the Union General Pope’s troops, taking up to 20-35 acres of land from the national park and historic district,” the group said on its Web site.

“Opponents of the highway…believe that it would negatively impact the national park and historic district and predict that the parkway and connecting roads will open up rural land in Prince William … and Loudoun County.”

The group joins a chorus of preservation advocacy groups raising concerns about the project, including the National Trust for Historic Preservation, National Parks Conservation Association, Piedmont Environmental Council, Coalition for Smarter Growth, and Southern Environmental Law Center.

The administration of Gov. Robert F. McDonnell (R) and the business community in Prince William and Loudoun believe the road is vital to the success of the fast-growing region. Supporters say the parkway — which could eventually connect farther east to Interstate 95 — would create jobs and drive economic development in the area, ease congestion and provide a key connection to Dulles International Airport and between two rapidly growing counties.

Elizabeth Kostelny, the executive director of Preservation Virginia, said that the organization is interested in the project in part because the National Park Service has pushed for assurance that if the parkway is built, Route 29 through the battlefield would be closed at Route 234 and a bypass around the park would be built.

“We’re not opposing it outright,” Kostelny said of the Tri-County Parkway. “We remain concerned about the traffic through the Manassas battlefield [and] having assurances those roads will be closed to commuter traffic.”

The Prince William Board of County Supervisors recently delayed a vote on Prince William’s state transportation priorities due to an outcry about the road. The parkway proposal has long had the support of both Prince William and Loudoun supervisors.

Prince William Board Chairman Corey A. Stewart (R-At Large) said in an interview that the board’s delay does not mean that supervisors plan to pull their support. He also said that despite setback and opposition, he believes the proposed parkway will move forward.

“I think they will be successful,” he said of the state’s plans for the road. “The reason is this … we have two of the fastest growing counties in the United States that do not have adequate connections to each other.”

Despite opposition in recent weeks — including from six state area Republican legislators and U.S. Rep. Frank R. Wolf (R-Va.) — state officials say they plan to press forward and hope to explain their plans for the parkway more clearly and how it would benefit residents.

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

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.

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Timing of development above Silver Line stations debated

There are two schools of thought on whether plans should be made now for building above future Silver Line Metro stations. The Washington Post reports there’s no consensus on the topic yet.
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Fairfax Supervisor Pat Herrity, former Congressman Tom Davis and Leo Schefer, president of the Washington Airports Task Force, are urging officials to seriously study the idea of large-scale development on top of the new Silver Line stations along the Dulles Toll Road.

On the other hand, Supervisor Jeff McKay, the Metropolitan Washington Airports Authority (which owns the land and is building the stations) and even Stewart Schwartz, head of the Coalition for Smarter Growth, disagree, saying the market for such development isn’t there right now.

Photo courtesy of Washington Business Journal

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Virginia Pushes For ‘Outer Beltway’ That Critics Say Isn’t Needed

Opponents of the so-called "Outer Beltway" say that Virginia traffic numbers show that the new roadway isn't needed.

Virginia transportation officials are pressing ahead with plans for a major north-south highway connecting I-95 in Prince William to Rt. 7 in Loudoun County, even as VDOT figures show the far greater demand for lane capacity lies on east-west routes, with the exception of Rt. 28 where it intersects I-66.

The Virginia Department of Transportation has released its traffic study for the proposed ‘north-south corridor of statewide significance,’ a 45-mile, multilane highway running west of both Dulles Airport and Manassas Battlefield and also connecting I-66 and Rt. 50. The study, based on population and job growth projections, found that if the new highway—the bi-county parkway—is not built traffic would increase significantly on some north-south routes. (The study’s executive summary is below.)

“By 2040 we anticipate the bi-county parkway is going to have 45,000 to 61,000 cars per day using the facility between Route 66 and Route 50,” said Maria Sinner, VDOT’s transportation and land use director in Prince William County.

Without the new highway “Gum Spring Road, Virginia Rt. 659, anticipates to increase in traffic anywhere from 70 percent to 203 percent,” Sinner said. “Rt. 15 is going to increase an additional 11 to 20 percent higher, depending on the segment.”

The debate over where Virginia should focus its congestion relief efforts centers on mountains of VDOT statistics showing which roads have the most traffic. Opponents of the proposal to spend an estimated $1 billion to construct another north-south highway—referred to by critics as an “outer beltway”—point to these figures to support their argument.

In Prince William, Rt. 15 (from Rt. 234 to the Loudoun County line) carries about 15,000 vehicles per day, according2011 VDOT traffic tables. Two other north-south routes, Rt. 234 (from Rt. 29 to Rt. 659) and Rt. 659 (from Rt. 234 to the Loudoun line), carry even fewer cars daily.

The major east-west route in Prince William in the general study area of the north-south corridor, however, is significantly more crowded.  I-66 (from Gainesville to Rt. 234) carries about 60,000 vehicles per day. The exception is the north-south Rt. 28 and its 54,000 daily vehicles. Rt. 28 carries traffic into Fairfax County to I-66 where travelers either turn onto the interstate for east-west movement or continue on Route 28.

“If they are saying that they need this road because of the pressures on Rt. 28 then this investment would be a complete failure, because their own [study] shows there is minimal effect on Rt. 28 north of I-66 if this road were to be built,” said Stewart Schwartz of the Coalition for Smarter Growth, a vocal opponent of the proposed bi-county parkway. VDOT’s traffic study found that Rt. 28 would see a one to two percent increase in traffic if the new highway is not constructed.

In Loudoun County, the north-south Rt. 659 carries between 8,000 and 16,000 vehicles per day, depending on the segment, while the east-west roadway Rt. 50 carries between 15,000 and 40,000, depending on the segment. Again, Rt. 28 in Loudoun is a north-south highway that carries as much traffic as the east-west routes, but Schwartz says those cars are traveling to job centers near and east of Dulles Airport. The proposed “outer beltway” would lie west of Dulles.

“If you look at current traffic numbers immediately around where this highway would be built around Manassas Battlefield, the traffic volumes north-south are very low, and the dominant traffic problem that we all recognize is on roads like I-66 and Rt. 50,” he said.

State transportation officials say they are attempting to tackle both east-west and north-south issues, pointing to plans to expand I-66 along with its interchanges at Rts. 15 and 28. It’s not an either-or proposition.

“We need to do both,” Sinner said.

Supporters of building the 45-mile highway in the “corridor of statewide significance” also argue a new north-south highway can improve east-west traveling. A driver in Loudoun or western Fairfax trying to get to I-95 today might take Rt. 267 east to I-495 to I-95. A better connection south to I-95 would alleviate that east-west movement, this argument goes.

Moreover, planners say the case for a new north-south highway in Northern Virginia is obvious when you consider the impact of job and population growth in the region in 20 to 30 years.

Schwartz counters those projections fail to make a convincing case. “A lot of the projections are based on horse trading in between the counties and optimistic thinking.”

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Read the original article at WAMU >>

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

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. 

Should Virginia Build Another Highway? Study for “Outer Beltway” Released

Plans for a major highway in Northern Virginia are taking shape. Officials say the billion-dollar road would spur growth, but opponents say that premise is flawed.

The Virginia Office of Intermodal Planning and Investment state has released a study to the influential, 17-member Commonwealth Transportation Board (CTB) of a limited access, north-south highway between I-95 in Prince William County and Rt. 7 in Loudoun County, arcing west of Dulles International Airport.

The 600-foot wide “corridor of statewide significance” will eventually extend 45 miles by building upon existing infrastructure, carrying car commuters and express buses to meet forecasted job and population growth. Both counties have in their comprehensive master plans the additional lane capacity, although land use disputes may arise in towns with property in the planned corridor.

“We are in the visioning stage. We have very little money in this project. We have only put $5 million dollars on the project to date,” said Deputy Secretary of Transportation David Tyeryar, who presented the corridor study to the CTB last week. The board is expected to accept the study at its next meeting in May.

“We are still in a phase where we are meeting with the transportation departments of the localities and the landowners and trying to determine a vision for the corridor,” Tyeryar added.

As Transportation Nation has reported, a north-south corridor could theoretically serve multiple purposes: help existing residents avoid traffic congestion, provide lane capacity for expected new residents and businesses, and help turn Dulles Airport into the East Coast’s premier freight hub.

“It’s going to be essential that this route eventually be established and hopefully built,” said Gary Garczynski, the CTB’s Northern Virginia representative and long-time real estate developer. “I’ve been around for 40 years in Northern Virginia and when you see the population and employment figures in this study… you need to have the vision to say we are going to need these roads.”

But studies have shown that building new roads doesn’t necessarily alleviate traffic, and opponents are marshaling objections to the estimated $1 billion price tag as well as the state’s employment and population forecasts in western Prince William and eastern Loudoun.

“Much of the growth projections are based upon plans of the local jurisdictions, not necessarily based upon some sort of demographic and economic analysis,” said Stewart Schwartz, the executive director of the Coalition for Smarter Growth, which favors transit-oriented projects to road building.

“We just raised taxes for transportation, but we didn’t do it to throw away the money. And we have such significant needs in Northern Virginia on the key existing commuter corridors, the funding of Dulles Rail, and fixing I-66,” Schwartz added.

The coalition’s director is also concerned about the public process, accusing the CTB of acting like a “rubber stamp” for Virginia road projects.

“One of the things we’re starting to think we need is an independent transportation planning agency separate from the Virginia Department of Transportation,” Schwartz said.

The CTB would be irresponsible to ignore the need to better move people and goods in Northern Virginia, Garczynski said. “The population and the employment growth is going to happen whether we build the road or not.”

 Read the original story at Transportation Nation >>

A North-South Highway for Northern Virginia

The McDonnell administration has unveiled its vision for a north-south highway and other improvements to Virginia’s newest Corridor of Statewide Significance. The McDonnell administration has unveiled a recommended alignment for a limited access highway to be built as the backbone of the North-South Corridor of Statewide Significance in Northern Virginia. The 45-mile circumferential highway would start at Interstate 95 in the south, swing west of Dulles International Airport and terminate at Route 7 in the north. The route would following existing highways, roads and projects contained in the comprehensive plans of Prince William County and Loudoun County. In a brief presentation of the proposal yesterday to the Commonwealth Transportation Board, Deputy Secretary of Transportation David Tyeryar justified the project on the grounds that it would help Dulles airport compete in the air cargo arena and would serve an area on the fringe of metropolitan Washington whose population is expected to grow by hundreds of thousands over the next three decades.

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

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

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