December 5, 1995

Stephen J. Long
Environmental Manager
Virginia Department of Transportation
1401 East Broad St.
Richmond, Virginia 23219-1939

Dear Mr. Long:

EPA has reviewed the Draft Purpose and Need (P&N) Statement for the proposed Western Washington By-Pass Major Investment Study (MIS), located in Fauquier, Loudoun, Prince William, and Stafford Counties. EPA also attended the December 5, 1995 Interagency Coordination Meeting where the subject study was presented. The following are our initial comments regarding the purpose and need for this project.

The P&N statement presents information regarding current and projected land use and commuting patterns, population and employment data, and traffic volumes for a large study area that extends from I-95 in Stafford County to the Virginia State line north of Leesburg in Loudoun County.

EPA´s comments fall into two general areas (specific comments are attached). Our first concern lies with the population and employment forecasting used in the study. The forecasts project rates of growth to the year 2020 which are similar to that which occurred in the 1980´s. The economic climate that fostered this growth does not appear to be present today. As these growth rates and specific growth areas are to be used as a basis to justify transportation infrastructure improvements, the data and assumption behind them need to be documented in the MIS.

Our second question addresses the need for north-south travel through the study area. The P&N document does not clearly link the projected rates of growth in the study area with the need for a continuous north-south travel corridor through the study area. For example, no data were presented that indicates the number of trips generated in Fredricksburg that have a destination at the northern end of the study area. In addition, considering the rates of growth projected, expanded mass transit form the central hub of Washington DC may be supportable and reduce overall transportation demand in the study area. This should be evaluated in the MIS.

At the end of the study period, projected north-south travel is only 14% of the total study area travel, moreover the origin and destination of the north-south travel is not indicated. Related to this concern is the observation that this by-pass proposal has no northern linkage back to I-95, thus severely reducing its utility as a north-sough bypass for through traffic.

EPA recognizes that the study area will need transportation infrastructure improvement as a result of population growth and economic development. The MIS should evaluate this need based on forecasting that utilizes the most current economic assumptions and should evaluate multi-modal alternatives that have the potential to meet the need. Specific comments are attached.

Thank you for this opportunity to comment. If you have any questions regarding this letter please feel free to contact Mr. Peter Stokely of my staff at 215-597-9922.

Sincerely,

Roy E. Denmark, Jr.
NEPA Program Manager

cc:
Alice Allen Grimes, ACOE
William Hester, FWS
Bruce Turner, FHWA

With the exception of Rt. 15, no specific, north-south traffic counts were presented and these were concentrated in the northern part of the study area.

The MIS should evaluate the extent that planned north-south road improvements in the northern part of the study area, such as the programmed improvement to Rt. 15 and Rt. 28, will address a north-south need.

Page 47;

Suburban to suburban travel does not necessarily equate to circumferential travel, for example travel from Fauquier to Prince William County is suburban to suburban but it is radial in relation to the DC area, not circumferential. By the year 2020, it is projected that nearly two-thirds of all work trips in the region (DC region not the study area) will stop and start in the suburbs. It is not clear what percentage of this would use a north-south connector versus the existing radial connectors or if this north-south connector needs to span the entire study area in order to meet a north-south need.

Page 48;

Table 603: This table presents total in and total out commuters for each county but not data on where these commuters came from or are going is presented.

Page 49;

Please explain the method used to estimate current and future north-south travel.

Page 50;

If the employee base for Dulles Airport shifts generally westward as predicted how will this influence the need for a north-south connection?

Return toThe List