March 20, 2024

Hon. Christina Henderson, TPB Chair
National Capital Region Transportation Planning Board
777 North Capitol Street NE, Suite 300
Washington, DC 20002-4239

Dear TPB Chair Henderson and Board members,

The Coalition for Smarter Growth is very disappointed that the special process and accountability voted on by the TPB board in 2021 for Visualize 2050 has not materialized. 

To meet the requirements of Board resolution R19-2021 and improve Visualize 2050, we ask you to direct staff to do an assessment of the package of projects compared to Visualize 2045 and key TPB performance measures and strategies, and require agencies to review the results and reconsider projects before proceeding with the air quality conformity analysis. 

In summary:

1. The conformity inputs package fails to comply with the TPB Board’s direction
   • Projects lack required information on GHG emissions and TPB priority strategies
   • A number of project descriptions make unsupported or contradictory claims or have incorrect information
   • TPB’s zero-based budgeting checkmark evaluation yields results for many projects that contradict TPB policies and strategies
2. Too many proposed projects increase carbon emissions to meet TPB, COG, state and local climate goals.
3. Public comments in 2023, 2022, 2021 and 2020 have all called for a departure from the Visualize 2045 approach, yet this project list maintains the status quo for much of the region; and 
4. The TPB board should pause the air quality conformity and take necessary steps to comply with its resolution and address TPB goals before proceeding. We propose steps to take.

1. The Conformity Inputs Package fails to comply with Board Resolution R19-2021

We appreciate the new public comment period held last year, local meetings held by Fairfax and Prince William counties, and the project changes considered. But for most projects, there’s no evidence of compliance with the Board’s resolution for a Zero-based budgeting process, required consideration of scenarios, or required information on how projects support regional goals like greenhouse gas (GHG) reduction.  

1. Required project information on GHG reduction and TPB priorities is missing 
   • No agencies provided required statements to explain how their projects reduce GHG emissions or explain how they implement TPB priority strategies.
   • Nearly half of the highway and arterial widening projects claimed to help the region meet its target to cut GHG emissions of cars and trucks 50% by 2030, despite well established evidence that these types of projects generally increases emissions.
2. Unsupported and incorrect project information – some examples: 
   • A number of projects built long after 2030 claim to help the region meet its 2030 GHG goal (e.g., widening Fairfax County Parkway in 2045, Frederick Freeway new interchange built in 2040, Ox Road widening in 2045, Braddock Rd widening in 2045, Indian Head Highway new interchanges in 2040, etc.) 
   • The major regional project, MD I-495/270 Toll Lanes, provided project description sheets with multiple additional corridor segments outside of those indicated in the project titles and the TPB March 1 staff memo summarizing project changes. The corrected project descriptions were still not available to the public as of March 20. 
   • The Frederick freeway widening and interchange project north of Frederick claims to support Metrobus and BRT. 
3. TPB’s zero-based budgeting checkmark evaluation yields contradictory results 

TPB staff’s checkmark evaluation is based on vague federal planning factors checked off by the sponsor agencies, not actual TPB policies. Many of the project results don’t make sense given TPB’s priority strategies. Some examples:

• Widening the already eight-lane Chain Bridge Road through Tysons Corner, while the area tries to become more walkable and transit-friendly, gets a perfect 8 out of 8 checkmarks in meeting regional goals. 
• Georgia Avenue NW bus lanes and safety improvements only gets 2 out of 8 checkmarks in meeting regional goals.
• Graham Park Road capacity reduction – adding bike lanes and a missing sidewalk and taming traffic near a middle school in Prince William County only gets 3 checkmarks
• 23 road widening projects – over a third – get checkmarks from TPB for “Environmental Protection,” despite being inconsistent with the activities that TPB’s policy framework lists for that goal.

2. Too many proposed projects increase GHG emissions for the region to meet TPB, COG, state and local climate goals 

• The proposed project list is similar to that in Visualize 2045, which fell far short of meeting our climate targets. While some local jurisdictions removed a few road widening projects, other highway expansions were added. Almost no new transit projects are in the plan. 
• Decades of evidence show that road and highway expansion increases GHG emissions, yet almost half of the road widening projects insist they will help TPB meet its ambitious 2030 GHG target. 
• TPB’s Climate Mitigation Study showed that to meet GHG targets, the region needs to reduce car dependence in addition to achieving fast adoption of electric vehicles. 
• Visualize 2045 would only achieve a reduction in per capita passenger car vehicle miles traveled (VMT) of 5% by 2045. TPB’s Climate study showed that an approximate 20% reduction is needed by 2030, with deeper reductions by 2050, in combination with rapid adoption of electric vehicles to achieve the COG 2030 Climate and Energy Action Plan. Numerous studies elsewhere in the US have arrived at similar numbers. Even deeper reductions of per capita VMT and faster electrification would be needed to achieve TPB’s GHG reduction target adopted in 2022. 
• Local climate action plans in our region require similar action.
• TPB and national studies show feasible ways to get the region close to its GHG targets. It’s doable but we can’t get there with this Visualize 2050 approach.

3. Public comments have called for a departure from the Visualize 2045 approach, yet this project list maintains the status quo in much of the region

• Public involvement results for Visualize 2050 call for less road expansion, and more transit, ped/bike facilities and safer streets  – according to the TPB staff summary of 2023 public involvement for Visualize 2050, of the almost 1,000 project comments, the “overarching themes” were:
  • “strong negative sentiment towards roadway widening and expansion projects”
  • “strong positive sentiment towards passenger rail expansion and improvements, bus improvements, bicycle and pedestrian infrastructure improvements, and BRT projects”
  • “support for roadway improvements that include traffic calming features but desires for more bicycle, pedestrian, or bus infrastructure improvements”
  • “advancement toward climate goals” and “reducing car dependence” 
• These main public comment themes are similar to those received in 2022 and 2021 on Visualize 2045.  
• The 2020 Voices of the Region scientific survey of the region’s residents also found that residents are more concerned about climate change than congestion, support bus lanes and more space for walking and biking, and that future generations will thank us more for clean transportation, transit, walking, and biking investments than for wider roads.
• Some jurisdictions have project packages that support this approach and applaud the transit, pedestrian, bicycle and safe local complete streets projects.

4. Recommended steps to fix Visualize 2050 before starting the Air Quality conformity modeling:

1. Project sponsors provide the required information for their projects and fix errors and obvious inconsistencies in their results.
2. TPB staff develop a quantitative assessment of the collective list of proposed projects, and compare these data with the last plan Visualize 2045’s regionally significant projects and key TPB goals, targets, priority strategies, and performance measures. This assessment could include easily calculated metrics such as:
   • # miles new highway and arterial lanes
   • # miles of new dedicated bus lanes
   • # miles of road diets (reduced lane capacity)
   • # miles of new rail track
   • # new rail stations
   • Total project costs for roadway capacity expansion
   • Total project costs for transit network expansion
   • Land use goal assessment – comparison of recent (construction data for 2019-2023) and planned (Round 10) development patterns versus COG/TPB goals for locating 75% of new housing and jobs in High Capacity Transit station areas and in Activity Centers.  
3. Analysis based on above metrics of how the new projects in total are likely to perform with respect to TPB’s GHG target, safety targets, and priority strategies (e.g., Expand BRT and Transitways; Reduce travel times on all bus services; Move more people on Metrorail and commuter rail; Improve walk and bike access to transit)
   • Available tools like the SHIFT calculator are available for quick analysis. 
4. Reconsideration of projects for submission into plan by TPB member agencies based on these results.

Visualize 2050 is the region’s last long-range plan that can shape whether the region, states, and localities meet 2030 greenhouse gas targets and support the 2030 COG housing targets. The urgency of the climate crisis, our housing challenges, failed road safety targets, and equity needs are why this board voted for Resolution R19-2021.

Thank you for your attention to this issue.

Bill Pugh, AICP CTP
Senior Policy Fellow
Coalition for Smarter Growth