January 13, 1997

Reply to: Eastern Virginia Regulatory Section 9504575-15

Mr. Earl . Robb, Environmental Engineer
Virginia Department of Transportation
1401 E. Broad Street
Richmond, Virginia 23219

Dear Mr. Robb

This letter is in reference to the Western Washington Transportation Corridor Study being conducted by the Virginia Department of Transportation (VDOT). It is our understanding that the current sturdy is a Major Investment Study (MIS), and that Federal Highway Administration (FHWA) has not initiated the preparation of an environmental document under the National Environmental Policy Act (NEPA).

At the interagency meeting conducted by VDOT on December 4, 1996, a presentation was made of the current status of the Western Transportation Corridor Study. In a letter to VDOT dated December 13 1996, we indicated that we would not be able to provide comments in response to the information provided before January 15, 1997. This letter provides our comments.

The MIS alternatives analysis considered the No Build, Transportation Systems Management/Travel Demand Management (TSM/TDM), expanded transit systems, upgrade/link of existing and/or planned roadways (U/LEPR), and numerous alignments for a new roadway facility (NF). It was stated at the December meeting that it is anticipated that the Advisory Committee for the study will soon make a recommendation to the Commonwealth Transportation Board concerning the preferred alternative(s). At the time of the meeting, it was not known whether the Committee would recommend one or several alternatives.

We have reviewed the numerous Technical Memoranda prepared for this study which were submitted to our office. The study area is very large, and since the MIS is a planning study, numerous assumptions have been made, and most of the impact analyses have been conducted in very broad terms. We understand that the corridors analyzed for the various alternatives were assumed to be one mile wide, and that ultimate impacts are anticipated to be considerably less that the current estimates. However, even if the impact estimates are considered to be inflated, we have considerable concerns about the wetland impact estimates for the NF options, which range form 319 to 448 acres for the various NF alignments. The potential for these kinds of impacts indicate that very careful consideration must be given to alternatives which avoid these potentially significant impacts.

Also of concern are the estimates of stream crossing for the NF options, which range from 12 to 16. In addition, several of the segments evaluated of the new facility options have the potential to impact a public water supply. The NF options all will be close to rare, endangered or threatened species. Existing residential structures near the NF options range from 1,312 to 2,080. The estimated cost is $1.2 billion to $1.3 billion.

Compared to the NF options, the U/LEPR options have the potential for significantly less impact. Wetland impacts are estimated to range from one to 30 acres, depending on the U/LEPR option. None of these options are expected to impact public water supplies, and stream crossings range from note to eight. Existing residential structures near the U/LEPR options are also considerably fewer than for the new facility options, ranging from 69 to 253. The estimated cost is $57 million to $477 million.

For a project with the potential for these kind of significant impacts to the human environment, it is critical that the need for the project and the benefits to result from the project be clearly demonstrated and documented. The primary needs identified in the study area are to (1) address a lack of adequate transportation facilities to meet projected demand, particularly north-south suburban to suburban travel demand and (2) to provide additional access from the west, northwest and southwest to the Washington Dulles International Airport. These stated needs have served as the framework for our review of the transportation analysis provided.

A review of the Traffic and Transportation Technical Memorandum raises several questions concerning the purpose and need and the potential benefits of a project in the study window.. Tables such as S-2 and S-3 show traffic will use all of the U/LEPR and NF options. Table S-4 shows that this diversion of traffic from other roadways will to some extent reduce Vehicle Hours of Travel (VHT) and Vehicles Hours of Delay (VHD). However, it is stated on page S-vi that "Although these appear to be a large number of hours, they represent less that one percent of the approximately nine million daily vehicle hours "expended" in the Metropolitan Washington region as a whole in 2020." It is stated on page 32 that "While these appear to be a large number of hours they are relatively a small percent of the regional vehicle hours for the urban area." These statements suggest that the improvement sot VHD and VHT man not be significant and may not contribute much in the way of justification for the anticipated significant impacts to homes and natural resources.

It is stated on page 34 that the "build alternatives do relieve traffic on other north-south roads." It is also stated (page 37) that "some roadways would have an increasing traffic if a build alternative is selected." It would appear that the best way to assess the relationship of all of the data and measures of effectiveness and understand the real effects of the roadway is to scrutinize the levels of service (LOS) projected for h regional roadways in 2020, with and without the various options. That information is provided for at least some regional roadways in Table 14 on page 41.

The information in Table 4-14 suggests several conclusions. First of all, for many of the regional roadways, it appears that the LOS are not significantly affected by any of the options. The LOS for Rt. 7 west of Rt. 659 and Rt. 15 north of Leesburg is projected to be LOS F with or without any improvements. The LOS for I-95 north of Prince William is expected to be LOS E with or without the introduction of U/LEPR or NF options. The following roadways are projected to exhibit the same acceptable LOS under the baseline scenario and with the introduction of any of the U/LEPR or NF options; for I-66 west of Rt. 28 (LOS D for all), Rt. 15 south of Rt. 50 (LOS A to C), I-95 south of Rt. 234 (LOS C for all), and Rt. 234 west of I-95 (LOS C for all).

Route 50 east of Rt. 15 improves from LOS F to LOS D or E with the introduction of the NF options, and remains as LOS F with the U/LEPR options. However, Rt. 50 west of Rt. 606 declines from LOS C under the Baseline to LOS D or E with the NF options, and remains as LOS C or D with the U/LEPR options. Rt. 606 north of Rt. 50 declines from LOS D to LOS F under several of the NF and U/LEPR options. It should also be noted that although the LOS F occurs under the baseline and all of the build options for Rt. 7 west of Rt. 659 and Rt. 15 north of Rt. 5, the volume to capacity rations (V/C) which serve as the basis for determining the LOS, decline with the introduction of most of the build options.

The above summary of the LOS information does not appear to support a position that the build alternatives which have been considered are justified by the significant impacts. The information also appears to demonstrate the the U/LEPR options, which are projected to have significantly less impact to the human environment that the NF options, provide effects on the regional traffic network similar to the effects of the NF options.

Our review of the documents prepared as part of the MIS concludes that the less damaging U/LEPR options warrant selection as the investment strategy when considering the stated purpose and need, the results of the traffic analysis, costs, and potential impacts to socioeconomic and natural resources. Since these options connect existing roadways, it would also be expected that they would minimize the potential for secondary impacts in the form of induced development when compared to the construction for a new facility. However, as stated above, it is not at this time clear from the traffic analysis that the impacts of even the U/LEPR alternatives have been justified.

We concur with the statements made by the Environmental Protection Agency in their letter dated November 27, 1997, that mass transit options should have been given full consideration as part of the MIS, They should not be eliminated if they cannot fully address the concerns alone, but rather, mass transit should be considered as a potential component of all the other options

Thank you for your cooperation in this matter. Should you have any questions, you may contact Ms. Alice Allen-Grimes at (757) 441-7219.

Sincerely

William H. Poore, Jr.
Chief, Regulatory Branch

Copies Furnished:

U. S. Fish and Wildlife Service, White Marsh
Environmental Protection Agency, Philadelphia
National Marine Fisheries Service, Oxford
Virginia Department of Environmental Quality/Water Division, Richmond
Virginia Marine Resources Commission, Newport News
Federal Highway Administration, Richmond
County Administrator, Prince William County
Director of Planning, Prince William County
County Administrator, Loudoun County
Director of Planning, Loudoun County
County Administrator, Fauquier County
Director of the Department of Community Development, Fauquier County
County Administrator, Stafford County
Director of Planning, Stafford County
Rappahannock Area Development Commission, Fredericksburg
Fredericksburg Area Municipal Planning Organization, Fredericksburg

CF: Permits, File Allen-Grimes
Konchuba
Poore


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