CSG comments to VDOT/VDRPT on 495 Southside Express Lanes NEPA Study June 21, 2022 The Coalition for Smarter Growth appreciates the efforts of the Virginia Department of Transportation (VDOT) and the Virginia Department of Rail and Public Transportation (VDRPT) to improve mobility within the I-495 corridor between Springfield and Maryland. However, to truly address the needs of the study area communities on either side of the Woodrow Wilson bridge and the metropolitan region, VDOT will need to take a broader and more holistic approach consistent with the National Environmental Policy Act (NEPA). The study approach is flawed from the outset by an overly narrow Purpose and Need and set of alternatives, and by pushing a transit alternative outside of the primary legally required NEPA study. We worry that, like previous VDOT studies, the Purpose and Need inappropriately presumes that the preferred approach will be a Public-Private toll lane project and that this has also influenced the narrow set of alternatives. Finally, the alternatives must include a comprehensive transit, land use (transitoriented development) and TDM alternative (including bike routes, and parking pricing) that addresses the racial and economic inequity of the east-west divide in jobs and housing. Instead of siloed and parallel transit and highway expansion studies, VDOT must evaluate within a single study a range of alternatives that include transit, transportation demand management (TDM), transitoriented land use, tolling with HOV that does not expand overall lane capacity, and options that support the needs of low-income commuters – in addition to the Express Lanes extension alternative. The current proposed approach is not acceptable as it does nothing to address the underlying land use issues causing the mobility and accessibility challenges in this corridor, and it also fails to address the need to significantly reduce corridor greenhouse gas emissions and toxic air pollutants. While VDOT needs to identify alternatives that can be implemented in the short- to mid-range timeframe, it also needs to consider mid-to-long-term solutions and not preclude them by ignoring land use and the adverse induced demand impacts of highway expansion. Information Presented at Public Meetings Suggest a Narrow, Siloed Project Purpose Parallel Transit/TDM and Highway Studies It is still unclear why there are separate studies for improving mobility in the same corridor. NEPA requires study of the range of alternatives to address the purpose and need. VDOT intends to develop alternatives by this Fall; however, there is no information readily available online regarding the DRPT transit study (see Attachment to this comment). It is hard to imagine that the transit and TDM needs will
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be fully analyzed and alternatives developed by this Fall that can inform the development of alternatives for VDOT’s NEPA study. VDOT needs to provide more information on how the two studies will develop coordinated alternatives that are fully explored in the NEPA process. Study Goals Four of the six study goals show images of highway lanes or cars. The Improve Safety goal appears to show a construction worker. The only goal that appears to address an underlying need is Improve Travel Reliability, with a stopwatch icon suggesting travel times. VDOT must more fully articulate the draft goals. The overall impression is that the goal of the study is to identify ways to move cars at higher speeds in the corridor and that Extending the Virginia Express Lanes is the predetermined preferred alternative. Below we list additional goals that address needs in the corridor and that should be part of this study. Current Conditions The “Current Conditions” board only focused on vehicle volumes, speed and congestion. These are narrow symptoms of the underlying problem causing peak direction travel delays, which is the east-west jobs-housing imbalance. Census data over the last two decades has shown that Prince George’s County and Charles County have the longest average commutes in the region reflecting the jobs/housing imbalance. This underlying problem is further exacerbated by the lack of a rapid transit connection between Alexandria/Fairfax and Prince George’s County. The current conditions analysis needs to also address commute times for Prince George’s County residents, income levels of commuters on either side of the bridge, affordable housing supply on each side of the river relative to jobs, transit travel times across the bridge to major employment centers in Virginia and Maryland, travel across the bridge due to lack of specific community services in Prince George’s and the eastern District of Columbia, and the breakdown of travelers in the corridor by trip purpose, general origin/destination and time of day. Goals Travel Options CSG agrees that an important goal of the study is to identify and develop alternatives that provide more travel options in the corridor. We understand these options to include rapid transit (with dedicated or priority right-of-way) and improved pedestrian and bicycle facilities, as well as more local bus routes and higher service frequency, HOV lanes, and HOT lanes. The Woodrow Wilson Bridge was reconstructed and purposely designed to accommodate Metrorail, both within its cross section and structurally. P.O. Box 73282 × Washington, DC 20056 × smartergrowth.net
Travel options for pedestrians and bicyclists also must include more options for north-south travel across the barrier created by I-495 as well as easier east-west travel along the corridor west of the Wilson Bridge. Addressing the corridor’s land use imbalance The east-west jobs and housing divide is the root cause of the peak-direction congestion in the corridor. The long-term viability of any solution to improving mobility and accessibility along the I-495 southside corridor (as well as the northside corridor between Maryland and Virginia) depends on addressing the land use imbalance. A major study like this one shouldn’t take a myopic narrow view that the underlying issue is simply road capacity and pricing. Multiple regional studies have shown that addressing the east-west jobs-housing divide would provide the greatest benefits to the region in terms of mobility, equity, and sustainability. TPB’s Long-Range Plan Task Force Study showed that Optimizing Regional Land Use Balance and Travel Demand Management were the best performing strategies; and TDM even outperformed the Express Travel Network in addressing regional bottlenecks like 495 southside. Likewise, WMATA’s ConnectGreaterWashington study found that addressing the region’s land use imbalance and focusing job growth at transit stations in Prince George’s County and the eastern District of Columbia in particular would greatly improve regional mobility, job accessibility, and sustainability. A coordinated land use and transit strategy would reduce regional congested auto travel by 32% by 2040, while boosting the number of households with access to transit by 54% and the number of jobs accessible by transit by 39%, compared to the region’s adopted long-range transportation plan. Reducing Greenhouse Gas Emissions The National Capital Region Transportation Planning Board (TPB), Fairfax County, the City of Alexandria, Prince George’s County, and the United States all have adopted goals to reduce greenhouse gas emissions by 50% by 2030 relative to 2005 levels. TPB’s newly adopted greenhouse gas reduction goal is specific to the on-road transportation sector. Each of these local governments and the region also have adopted goals to shift more trips from cars to other modes and/or to reduce VMT. Reducing transportation emissions to meet these levels of reductions requires both transitioning to electric vehicles and reducing VMT growth, as demonstrated by TPB’s Climate Change Mitigation Study of 2021 and by multiple national studies and in other states. Even with an ambitious transition to electric vehicles the region must reduce per capita VMT by 15-20% by 2030 and more beyond that to meet science-based climate targets that limit warming to safe levels. Under the region’s adopted transportation plan Visualize 2045, which includes 893 new lane miles of highways and arterials, per capita VMT would only decrease by 3% by 2045. Even with managed lanes, P.O. Box 73282 × Washington, DC 20056 × smartergrowth.net
these capacity expansions don’t contribute to the needed scale of reduction of greenhouse gas emissions due to their induced VMT. 1 More significant land use, transit, TDM, pedestrian and bicycle strategies, and less highway expansion, is needed to achieve the region’s greenhouse gas reduction goal for the transportation sector and overall multi-sector goal. While VDOT conducted a recent pilot interstate corridor greenhouse gas analysis (Virginia I-95 Pilot Project Greenhouse Gas Analysis), CSG believes that there are too many gaps and flawed assumptions in this study to meaningfully inform regional transportation planning. For example, the study did not fully examine induced demand or account for changes in land use caused by the highway capacity expansion alternatives2, and while it assumed a major shift toward electrification for cars and trucks, it did not similarly assume this for rail by 2045. So VDOT’s I-95 analysis findings should not be applied to the 495 Southside project. To help the communities in the project corridor and the metropolitan region meet their greenhouse gas reduction targets, this project needs to contribute to the region’s per capita VMT reduction and not increase it through induced demand due to road capacity expansion. Alternatives that need to be studied Single managed lanes alternative currently proposed by VDOT The public information display boards suggest a narrow, predetermined focus on extending the Express Lanes as the driving purpose for the study: ● No Build ● Extending the Express Lanes ○ With design options for different access points to the new Express Lanes Additional alternatives needed In addition to the above alternatives, the following alternatives need to be included in the study: ● Tolling and HOV with no net addition of lanes (either general purpose or managed) ○ With study of options for low-income commuter toll exemptions or discounts 1
TPB’s Climate Change Mitigation Study review of national literature and best practices found that: “When adding capacity instead of converting existing capacity, HOV lanes induce new vehicle travel in urbanized areas. Regional simulation modeling studies suggest that the additional VMT will at least partially offset any emissions benefits resulting from smoother traffic flow, and in many cases will completely offset the emissions benefits. These conclusions are also supported by project-level analyses of emissions impacts of HOV and express lane additions reported in recent project environmental documents.” pp. 61-62, TPB Climate Change Mitigation Study of 2021: A Review of Climate Action Plans and Literature on Transportation Greenhouse Gas Emissions Reduction Strategies and Their Effectiveness – Report, July 2021) 2
“Latent demand effects (i.e., the phenomenon in which people travel more because more capacity is available or level of service improves) appear to be largely but not fully captured in the TPB model. The model accounts for trips to more distant destinations, decisions to take longer but faster routes, and mode shifts (e.g., from transit or rail to auto). However, it does not account for any changes in land use patterns that may further disperse destinations, or for shifts in trip patterns across different time periods.” page 1-6, Virginia I-95 Pilot Project Greenhouse Gas Analysis Memorandum, January 2022.
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Transit, TDM and TOD alternative (includes additional jobs at TOD locations on the east side of region as well as additional affordable housing on the west side) BRT and rail alternatives
Note that Metrorail across the Woodrow Wilson Bridge was a promise made in the final agreements to construct the bridge and the bridge was designed to accommodate this weight. WMATA’s Blue, Orange, Silver Line Capacity and Reliability Study found that the Blue Line to National Harbor alternative had the highest benefits and the second highest cost effectiveness of the alternatives studied. Thus, this transit alternative needs to be incorporated into the alternatives considered in VDOT’s study, and included with a transit-oriented and balanced east-west land use alternative. Analysis The environmental resource impact analyses need to study these factors: Non-tailpipe Air Quality Impacts of Cars and Trucks The air quality analysis needs to consider that even as the car and truck fleet transitions to battery electric or other types of electric vehicles, that the non-tailpipe pollution will persist and could significantly increase in the corridor. The particulate pollution from tires, brakes and other sources is significant, and for heavier battery electric vehicles is expected may be greater than for lighter internal combustion engine vehicles.3 If VMT increases in the corridor, then this pollution would also increase. The potential environmental justice implications would also need to be considered. Induced Demand, including impacts on VMT and GHG Any addition of lane capacity will need to fully assess the induced demand impacts in the medium and long-term. Modeling incorporation of increased telework rates from pre-pandemic levels Forecasting of future travel demand should consider a range of telecommuting scenarios to understand the implications for peak period traffic volumes.
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See: OECD (2020), Non-exhaust Particulate Emissions from Road Transport: An Ignored Environmental Policy Challenge, OECD Publishing, Paris, https://doi.org/10.1787/4a4dc6ca-en; and recent research covered in Damian Carrington (June 3, 2022) “Car tyres produce vastly more particle pollution than exhausts, tests show”, The Guardian.
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Attachment: Web Searches for Study of Transit and TDM Alternatives in I-495 Southside Corridor as of June 17, 2022
P.O. Box 73282 × Washington, DC 20056 × smartergrowth.net
P.O. Box 73282 × Washington, DC 20056 × smartergrowth.net