CSG COMMENTS: NVTA TransAction Plan

September 18, 2022 Honorable Phyllis Randall Chair Northern Virginia Transportation Authority 3040 Williams Drive, Suite 200 Fairfax, VA 22031 Re: Comments on the proposed 2022 TransAction, and recommendation to reject the plan as drafted Chair Randall and NVTA board members: We urge you to review and consider the joint letter of 12 Northern Virginia organizations regarding TransAction 2045. These are not new concerns - we have pointed to the shortcomings for some time. We also urge you to reject this TransAction plan and create a new more effective, affordable and sustainable plan. Staff failed to provide you with a set of bottom-up scenarios to enable you and the public to consider alternative futures. Instead we are given one stapled together list of projects that we cannot afford and that would make our transportation, equity and climate problems worse. Northern Virginia would benefit from a plan that: ● ● ● ● ●

Addresses the land use and housing issues underpinning our key transportation problems; Takes urgent and adequate action on climate change rather than passing the buck on an existential threat; Removes destructive and wasteful projects like new Potomac River highway crossings, the Bi-County Parkway, and too many widenings of suburban arterials; Pursues the pricing and demand management strategies which NVTA itself says are necessary; and Replaces a $76 billion wish list with a more effective – as well as sustainable, equitable and livable – package of investments that prioritize and support the region’s vision for a network of walkable, bikeable, and inclusive transit-oriented communities.

On the following pages are the Coalition for Smarter Growth’s specific comments, which add detail to the points in the joint letter, and demonstrate the serious flaws in the TransAction 2045 plan. We urge you to reject the current plan and to develop a more sustainable, effective, and equitable approach for Northern Virginia.

Sincerely, Stewart Schwartz Executive Director

Bill Pugh Senior Policy Fellow

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1. A $76 billion unconstrained plan is neither realistic nor informative A plan that can’t be built is not a plan, and the perceived results of the plan cannot be claimed if the plan is in no way affordable. TransAction describes its many benefits in the future tense “will”, and urges local governments to work together to build all of the projects in it. This approach does not help Northern Virginia make informed decisions, nor does it address our many other infrastructure needs that TransAction ignores.

The $76 billion cost of TransAction exceeds by four times what the region’s constrained long-range transportation plan, Visualize 2045, estimates Northern Virginia can realistically spend for improved transit, road, and active transportation facilities. And in just five years, the price tag of TransAction increased by over 50%, even accounting for inflation.

TransAction’s price tag versus Northern Virginia system expansion funding in the region’s constrained long-range transportation plan1 Our region has many other needs for limited infrastructure dollars, including upgrading our infrastructure to withstand the impacts of climate change already occurring, addressing the increasing maintenance and repair needs, implementing our climate action plans, addressing the housing crisis, etc. For example, the Commonwealth’s VTrans 2045 analysis shows that Northern Virginia will have 400 more miles of roads at risk of flooding due to climate change – how are we going to pay for needs like that and why does TransAction ignore them?

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Source: Visualize 2045, Appendix A Financial Plan, Table 3. The 2017 TransAction costs were escalated from FY17 dollars to 2021 dollars based on the CPI as a rough order-of-magnitude estimate. The Visualize 2045 Financial Plan uses Year of Expenditure dollars while TransAction project costs are presented in 2021 dollars. Although TransAction includes some projects that extend into Maryland and DC, even if their entire system expansion budgets from the CLRP were added onto Virginia’s, it still wouldn’t cover the cost of TransAction. We acknowledge that the NVTA and TPB plans present financial needs in different formats, so this comparison is intended to show rough magnitudes.

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If NVTA decides to continue with TransAction’s unconstrained $76 billion approach, then it should at least acknowledge the magnitude of the funding gap and the other critical needs for Northern Virginia’s infrastructure dollars.

2. NVTA needs to address the land use and housing issues causing our key transportation problems The National Capital Region Transportation Planning Board says achieving adopted regional housing targets would reduce congestion by 20%. That’s the same amount of congestion reduction that would be achieved IF the entire $76 billion plan were built. Northern Virginia jurisdictions through their MWCOG representatives have endorsed these housing targets, which include locating 75% of new housing in transit-served walkable activity centers and ensuring 75% of it is affordable. Investing in affordable housing close to jobs and transit would therefore be a particularly effective part of a more equitable and sustainable transportation solution.

Visualize 2045 showed a larger increase in the numbers of jobs accessible by transit than by automobile, despite the plan investing twice as much in highway and road expansion. This was due in large part to the benefits of future transit-oriented development. Imagine how much more job access could improve if all NVTA jurisdictions prioritized putting housing and jobs in compact, mixed-use, walkable activity centers with existing or planned transit.

3. TransAction fails on climate change - both in 2030 and in 2045 Sustainability is a core value of NVTA but TransAction fails to address the region’s largest source of planet warming emissions in any meaningful way. The draft plan: ●

Ignores the significant 2030 reductions needed, and doesn’t mention key climate plans and studies from our own region that clearly spell out the changes necessary in our transportation system and land use by 2030 and beyond.

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Increases per capita VMT 4% above the future baseline, when the region needs to reduce per capita VMT over 20% by 2045 in addition to rapid EV adoption, to achieve adopted climate targets.2

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Inappropriately takes credit for a 54% GHG emission reduction from increased electric vehicle adoption, because the analysis excludes this electric vehicle adoption from future baseline “No Build” conditions (for example, chart on page 22 of the draft summary plan). TransAction includes a small $51 million investment in electric vehicle charging

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Level of per capita VMT reduction needed in California by 2045 in addition to its ambitious EV adoption policies to meet state climate targets (California Air Resources Board 2022 Draft Scoping Plan). In addition, the TPB’s Climate Change Mitigation Study of 2021 found that only scenarios which achieve per capita light duty VMT reductions in the range of 15-20% by 2030 would achieve the levels of on-road transportation emissions needed in the region’s 2030 Climate and Energy Action Plan. Likewise, RMI has found that the U.S. must reduce per capita light duty VMT by 20% below 2019 levels by 2030 in addition to very rapid adoption of EVs (25% of light duty vehicles on the road).

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stations over the life of the plan, which while helpful, is not moving the needle relative to the scale of the overall charging infrastructure need or the state and federal rebates, clean cars, consumer preferences and tech advances driving electric vehicle adoption.

The real story is that TransAction fails to reduce emissions below future baseline conditions. Excluding TransAction’s electric vehicle assumptions, emissions go up 1.7% relative to future No Build baseline as a result of building TransAction’s many highway and arterial expansion projects and failing to address auto-oriented land use policies.

Assuming the small investment in EV charging stations marginally helps reduce emissions, the emission reductions and increases of the $76 billion dollar plan are essentially a wash.3 Leaves Northern Virginia far from 2050 carbon neutrality with a 54% decrease in emissions by 2045. The TPB set a goal to achieve an emission reduction in that ballpark by 2030.4 Pays only token attention to significant investments needed to electrify vehicle fleets (buses, trucks, and cars) and provide necessary charging infrastructure: $51 million over 23 years. While we applaud the NVTA for including charging infrastructure in TransAction, the plan doesn’t quantify the needs. This recommended amount appears to be very little, especially compared to the vast sums invested in highway expansion.

Fails to mention the major investments needed to upgrade our existing transportation infrastructure to handle the extreme weather already occurring and getting worse with climate change.

A new approach to TransAction must address the 2030 and 2050 greenhouse gas reduction targets, showing what Northern Virginia needs to do to reduce on-road transportation emissions fast enough, and proposing a package of projects and programs that can achieve them.

4. TransAction continues to include destructive major new highways that need to be removed TransAction incorporates some good “top-down” regional projects – a coordinated bus rapid transit network, for example – but also some destructive ones – like the Bi-County Parkway and major new highways from Loudoun and Prince William across the Potomac into rural areas of Maryland, that together would form a substantial portion of the controversial Outer Beltway.

In our “On the Wrong Road” report, CSG showed that the enormous package of highway and arterial widening projects in the last TransAction plan (similar to the current version) would increase road capacity and driving far faster than population growth in places like Prince William and Loudoun counties and even significantly in Fairfax County.

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Plan has1.7% increase in emissions above No Build when excluding EV adoption. Plan only has a small investment in charging infrastructure: $51M over 23 years (trucks, bus, car charging total in projects #458, 459, 460). So it’s unlikely to see how that small investment could significantly decrease emissions. Looks like a wash (plan does not increase/decrease emissions relative to No Build).

4 TPB’s GHG reduction goal is relative to 2005 levels, while NVTA calculates its reduction relative to the 2017 base year. However, total TPB region on-road GHG emissions in 2005 and 2017 was similar (just above 20M MTCO2e, see TPB’s CCMS, Final Report, Figure ES-2).

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NVTA itself acknowledges the self-defeating aspect of highway expansion due to induced driving. Its Technology Strategic Plan, page 28, states that: “Expanding infrastructure capacity, especially highway capacity, presents multiple challenges in mitigating this congestion (due to the phenomena of induced demand) and achieving NVTA’s goals of equity, sustainability and safety, although it will likely remain an important option.”

While TransAction includes a large total dollar value of transit projects, in practice, the NVTA has allocated most of its regional funding through the Six-Year Program to expanding highway and road capacity. A better approach is to remove the destructive and unaffordable new highway projects from TransAction.

5. Incentives and Pricing Scenario suggests ways to achieve near-term mobility and climate goals without the $76 billion price tag NVTA’s Technology Strategic Plan says the region should 1) reduce VMT relative to passenger trips to reduce congestion, 2) that we can’t do this through expanding highway capacity because of induced demand, so 3) NVTA needs to “develop pricing mechanisms that manage travel demand and provide sustainable travel options.” (page 40, Strategy #5) The 2022 TransAction provides a good scenario analysis of what such road and parking pricing mechanisms could look like and includes discounts for low-income drivers and free transit. The incentives and pricing, with equity provisions, achieve largely the same improvements as the TransAction plan and its 429 projects.

TransAction – because of induced demand and its failure to address land use – does not achieve NVTA’s own recommended strategy for improving congestion, which is to reduce the ratio of VMT to Passenger Miles Traveled (see page 28 of the Technology Strategic Plan). This ratio in future No Build 2045 conditions is 0.725 and after spending $76 billion implementing TransAction, it would be 0.724, virtually unchanged.

Pricing strategies, paired with better land use and housing near transit, electric vehicles, and supportive transit, local street network, and bike/pedestrian investments, would be more effective and could be implemented more feasibly and quickly than an unconstrained plan.

5. TransAction makes safety claims without data and too often prioritizes high-speed auto travel on wider and wider roads TransAction on page 23 says that the proposed network (IF it could be built) improves safety without providing the data. Despite safety being a core value, the performance measures for “Potential for Safety and Security Improvements” and “Quality of Access to Transit and the Ped/Bike Network” are not yet available. The public comment period is ending on September 18th without this important information being shared. A second comment period may be warranted and this information should be made available to the NVTA board before it votes on the plan.

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Many proposed arterial expansion projects would increase the numbers of lanes, while seeking to maintain high vehicle speeds, making crossing distances even longer and increasing risks for pedestrians. While CSG applauds the trail, bicycle and pedestrian improvements in the plan, too many of these are conditioned on major arterial expansions and accompanying auto-oriented small area plans and zoning that separate land uses and make trips by walking and biking longer, less convenient, less pleasant, and undercut safety improvements.

6. Modeling Transit-only versus Highway-only scenarios needs to be replaced with real scenarios that address the land use underpinning these investments Modeling all of the proposed transit investments and proposed highway and road expansion separately but with the same baseline land use does not provide useful information. The lack of transit-supportive land use plans in parts of the middle ring and especially in the outer ring suburbs does not allow the proposed transit investments in these areas to perform as they should.

Also, the simplistic transit-only scenario excluded the proposed local street grid projects and pedestrian and bike improvements in TransAction that are needed to support transit-oriented development and the transit projects, and would help generate higher transit ridership.

CSG and other Northern Virginia organizations have repeatedly requested an integrated and comprehensive, transit-oriented land use, housing, and pricing/demand management scenario with a more feasible and supportive project list. This would provide valuable information to NVTA, and this current plan should be re-done with such an approach.

— Thank you for soliciting stakeholder feedback and for reviewing our comments. Please let us know if you would like to discuss further these recommendations for improving TransAction.

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