November 27, 1996
Ken Wilkinson
Virginia Department of Transportation
1401 East Broad St.
Richmond, Virginia 23219-1939
Thank you for the opportunity to review the Major Investment study (MIS) for the Western Transportation Corridor Study (WTCS) located in Stafford, Fauquier, Prince William and Loudoun Counties. We have been provided the Purpose and Need Statement, the Description of Alternative, the Natural Resource Technical Memorandum, the Traffic and Transportation Technical Memorandum and the Executive Summaries for each of the nine studies performed. As the MIS nears completion some preliminary conclusions are warranted.
EPA has previously provided (December 18 1995 and April 12 1996) comment on the Purpose and Need for this proposal. We expressed concern regarding the level of need for north-south travel for the entire corridor, particularly the western build corridors. The final Purpose and Need statement reinforced our conclusions that there is only limited need for north-south travel along the western build corridors. The strongest need for transportation improvement is the already developed northern and eastern portions of the study area.
EPA recognizes that the data presented in this MIS is broad in scope. However, considering that the scope and accuracy of the data is consistent throughout the study area, some comparisons and general conclusions can be made from the information provided. For example, a New Facility Alternative (NFA) has the potential to directly impact up to ten time the wetlands area, cross ten times the flood plain area, increase the potential for Threatened and Endangered Plant (T&E) impacts by 2.5 times, and potential threaten the Lake Manassas public water supply when compared to the Upgrade/Link Existing and/or Planned Roadway Alternative (ULA). Secondary impacts, such as increased development pressure on farmland, rural communities and the over taxed wetland filtering system of the Chesapeake Bay were not evaluated in this MIS. The cost of a New Facility Alternative could be as much as $1.5 billion.
Considering the land use component of this study, it seems the benefit of a NFA will be largely focused in eastern Loudoun County and it may stimulate growth patterns that are not consistent with the other counties land use plans. The NFA will increase dependence on the automobile, vehicle miles traveled (VMT), air emissions and may encourage expensive and potentially unsustainable growth patterns . Considering the traffic area, it appears the ULA adequately serves the need where it is needed, in the already developed northern and eastern portions of the study area.
Therefore from our review of this Major Investment study, of the alternative studies, the alternative that warrants selection as the investment strategy when considering the project purpose and need, traffic and transportation patterns, construction costs and the potential environmental impacts, appears to be the ULA.
The ULA connects the northern portion of the study area with I-95, provides a southern and western access route to Dulles Airport, handles similar traffic volumes as the NFA, and results in construction costs that are one-third the NFA. The ULAÕs potential environmental impacts, including the potential impacts to the Lake Manassas water supply, wetland losses and the potential to promote urban sprawl are far less. The NFA does not appear to be justified for a Major Investment when considering the information presented in the MIS.
None of the alternatives studied in this MIS include a mass transit component. EPA views this as a serious shortcoming of this MIS. This is particularly relevant when the conclusion is that a Major Investment appears warranted in the densely populated northern and eastern portion of the study area. It is this portion of the study area that would most likely support a major investment in mass transit. This portion of the study area has been identified y the Washington Regional Network (WRN) report A New Approach Integrating Transportation and Environment in the National Capital Area (May 1993) as capable of supporting four or more transit-oriented communities and the related infrastructure. These would be part of a larger transit plan for the metropolitan area that has been modeled in the year 2010 to reduce VMT and associated air pollution by 11.5% and increase average daily highway speeds by 13%. This WRN type of Major Investment would continue to foster economic growth but do so in a more environmental sustainable manner. EPA urges VDOT to investigate the feasibility of these concept in the WTCS MIS.
Thank you for this opportunity to comment. Additional comments are provided in an enclosure to this letter. I you have any further questions or concerns please contact Mr. Peter Stokely of my staff at 215 566-2720.
Sincerely,
Roy E. Denmark, Jr.
NEPA Program Manager
cc: Federal Highway Administration, Virginia Office
Corps of Engineers, Norfolk District
U.S. Fish and Wildlife Service, White Marsh, VA
EPA Technical Comments, WTCS MIS.
1. From A-6 in the Purpose and Need Statement. Home based work trips in the WTCS (roughly equivalent to the NW, C, SW sections of the region as defined in the P&N) in the final study year (2020) is approximately 413,075 trips (roughly 10% of the travel in the region). Of the 413,075 home based work trips, approximately 9% stay in the WTCS and would benefit from improved north-south travel , 91% of these trips move eastward out of the WTCS study area with a full 15% traveling all the way to Washington DC. It appears that bulk of the travel needs is radial to Washington DC with a relatively smaller north-south need that needs addressing. Considering this relatively moderate level of north-south need it seems that some additional east-west transit alternatives would be warranted for study in the WTCS.
2. This MIS should outline how the planned roadway improvement s and the data/results and year 2020 conclusions from the directly adjacent Rt. 66 MIS would influence the traffic patterns thus conclusions in the WTCS. How would the construction of metro rail to Dulles Airport impact the WTCS?
3. To further disclose the impact of the WTCS on local roads, estimates of traffic changes to I-66 east of Rt. 28, Rt. 50 east of 606, Rt. 7 east of 659, and all of Rt. 7100 and Rt. 267 should be included in this study.
4. The complete avoidance of impacts to the water supply of Lake Manassas or any other public water supply should be included in the 1996 Evaluation Criteria.
5. Disclose the status of planning for the Dulles Airport western access that this study is intended to support.
6. Address the issue of compatibility of the effected counties land use plans and the secondary impacts of increased development pressure on wetlands, farmland, woodlands, and T&E species habitat.
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