October  2, 2023

Mr. Nick Nies, AICP
Virginia Department of Transportation
VDOT 495 Southside Express Lanes Study NEPA Project Manager
9030 Stony Point Parkway, Suite 220
Richmond, VA 23235

(via email to 495southsideexpresslanes@VDOT.Virginia.gov)

Re: Comments on 495 Southside Express Lanes Study, Preliminary Alternatives & Screening

Mr. Nies:

The Coalition for Smarter Growth submits the following comments on the Preliminary Alternatives and Screening Evaluation presented by VDOT in September 2023 for its 495 Southside Express Lanes study.

In summary:

• VDOT’s purpose and need statement – “extend and provide continuity of the Express Lanes system” –  is biased, leading to a foregone conclusion, and is inconsistent with the National Environmental Policy Act direction to evaluate alternatives. 
• VDOT handicapped the Transit and TDM preliminary alternatives by only creating piecemeal, separate elements that were each evaluated individually, rather than also creating an effective and comprehensive Transit (facilities and service), TDM, and TSM alternative that would perform well in the screening evaluation. VDOT (and DRPT’s study) also failed to include transit-oriented land use and housing recommendations in regional/local plans that would be effective components of alternatives.  
• VDOT is rushing its study before WMATA can complete its current study of Metrorail in the corridor.
• If VDOT advances only highway expansion concepts, as its screening suggests, the public will not have information to compare the traffic and environmental impacts among alternatives for widening versus alternatives for transit and TDM. 

We ask that VDOT pause the 495 Express Lanes study to revise the Purpose and Need; develop meaningful transit, TDM and transit-oriented land use alternatives; and allow WMATA to complete its ongoing study. Our detailed comments follow.

Detailed Comments:

1. VDOT’s study uses a foregone conclusion – purpose of the study is to “extend the Express Lanes” – and this violates the intent of the NEPA process – VDOT’s stated purpose of the project is to “extend and provide continuity of the Express Lanes system” and the first screening criterion for selecting an alternative is “system continuity” of the Express Lanes. While VDOT staff said they have not made a decision yet on which project alternative they will pursue, the entire study is biased by their Purpose statement. By your defined purpose it is impossible for a rail transit/TOD/TDM alternative or a bus/TOD/TDM alternative to advance for detailed evaluation. A Purpose which would have been properly focused on the customer should have been something like “to move more people and provide alternatives to sitting in congestion.” This would have created a fairer and more objective playing field for considering alternatives to be evaluated. The public at meetings we attended included many people who called out VDOT on its flawed circular logic that runs counter to the intent of NEPA. 
   
2. Express Lanes don’t significantly reduce congestion in the general purpose lanes, but VDOT won’t admit that or provide data on this from its existing Express Lanes – A number of people at the meetings raised this issue and asked VDOT to provide data from the existing 90+ miles of Express Lanes – to what extent they reduce congestion in the general purpose (non-tolled) lanes. VDOT staff would not directly respond to this comment or commit to providing this data, which should be readily available.
   
3. VDOT’s Transit and TDM alternatives were not developed to the same level of detail as the alternatives to add lanes for cars – this reflects VDOT failing to take these seriously from the start  
   
   • The preliminary alternatives for adding general purpose lanes and express lanes showed detailed cross-sections for all three segments of the project corridor. Meanwhile, transit and TDM alternatives only had random photos borrowed from other places rather than diagrams to illustrate these concepts. The “Standalone Transit” concept used a photo from some country with cars driving on the left next to a bus lane.
   • The rendering showing how Metrorail could be accommodated in the future was based on the 2 Express Lanes alternative; no other alternatives were shown to illustrate how they might accommodate Metrorail in the future. 
   • VDOT failed to consider a TDM alternative that prices existing lanes and that could study measures such as exemptions or discounts for low-income drivers. 
   • VDOT staff couldn’t answer basic questions about the Transit and TDM alternatives and referred questions to DRPT regarding its study. When we asked VDOT staff during the in-person open house what bus services and TDM measures (besides park-and ride-lots) were included in their Transit alternative, they referred us to the DRPT representative. When one of us asked the DRPT representative in person what transit service elements and TDM measures VDOT was including in its study, he referred us back to VDOT staff. The separation of the two studies isn’t appropriate because a full range of transit alternatives and comprehensive and equally detailed analysis of those alternatives should be part of the primary environmental study.

4. VDOT handicapped the Transit and TDM preliminary alternatives by only creating piecemeal, separate elements that were each evaluated individually, rather than also creating an effective and comprehensive Transit (facilities and service), TDM, and TSM alternative that would perform well in the screening evaluation – 
   The slide deck is very vague on this, but VDOT staff at the Alexandria public meeting finally confirmed to us that indeed there is no additive Transit and TDM concept that combines all features. 
   • VDOT’s bus lane alternative (“Standalone Transit”) includes no expanded bus services. Meanwhile, its expanded bus service alternative (“Transit TSM/TDM”) includes no dedicated or priority transit lanes. VDOT excluded and failed to evaluate in its screening a preliminary alternative that combines both.
   • VDOT continually cited the DRPT study but didn’t use that study to construct its alternatives, and VDOT staff couldn’t answer basic questions on the relationship of the DRPT study and VDOT study.
   • The separated and very limited transit, TSM, and TDM alternatives of course don’t score well in VDOT’s subjective screening. There is no comprehensive, transit and TDM alternative – and none consider the potential of transit-oriented land use plans in the corridor. DRPT completed a separate study on transit needs in the corridor and issued recommendations, yet VDOT wouldn’t say whether it will follow them.
     
5. The TDM alternative doesn’t actually include TDM measures – The only types of solutions listed for the TSM/TDM alternative are TSM measures: ramp metering, extension of acceleration/deceleration lanes, and active traffic management (dynamic speed limits, queue warnings). For Transit and TSM/TDM, the only type of measure listed is park-and-ride lots. VDOT doesn’t even list the types of TDM elements recommended by DRPT in its study, which albeit were mostly limited traveler information measures. VDOT staff couldn’t answer questions about what other types of TDM measures they were considering and just referred the public to the separate DRPT study.   
   
6. VDOT failed to study the alternatives that the region’s MPO found most effective. – The National Capital Region Transportation Planning Board’s (TPB) 2017 Long-Range Plan Task Force, Phase II Assessment of Regional Initiatives found that Travel Demand Management and Regional Land Use Balance were the two most effective strategies at addressing a range of regional mobility needs, such as improving travel times, improving job access, and fixing regional bottlenecks like the Woodrow Wilson Bridge beltway crossing – more effective than an Express Toll Lanes network strategy they modeled. However, VDOT did not develop preliminary alternatives for either strategy. DRPT also failed to study the Balanced Land Use strategy its study, and DRPT’s TDM recommendations did not include the full suite of tools that TPB has studied and that could be used to improve 495 corridor travel. 
   
7. Unclear accommodation of Metrorail on WW Bridge sometime in future after Express Lanes and ramps are built and toll concession contract signed – At the end of the multiyear debate over the Woodrow Wilson Bridge, the region was promised Metrorail on the bridge (which was engineered to hold the weight and right of way was reserved). While VDOT said the project won’t preclude future Metrorail across the Woodrow Wilson Bridge, it seems very unlikely that TransUrban (or other firm) would give up two express out of four lanes for the rail. VDOT showed a picture of an Express Lane later converted to Metrorail tracks but this presumably would involve significant cost to retrofit, require substantial payment to the contract P3 operator, and may face challenges in designing around the Express Lane ramps and lane entrance/exits.
   
8. Broad impacts to adjacent neighborhoods and communities and the environment are not addressed so the public can’t see the impact of adding up to four travel lanes compared to other alternatives – Numerous speakers at public meetings expressed concern about the Express Lanes dumping traffic into Old Town Alexandria, worsening the Route 1 interchange, creating a bottleneck in Maryland, impacting adjacent neighborhoods, and worsening noise and heat island impacts from the expanded highway footprint and volumes. If VDOT only advances highway expansion alternatives, as its screening suggests, the public will not have information to compare the traffic and environmental impacts among different alternatives. 
   
9. Screening results are biased and often flawed, but VDOT doesn’t provide any memorandum that describes how it arrived at these conclusions.  Here are the screening criterion and our objections to VDOT’s evaluations:
   
   1. System Continuity –
      • The Express Lanes should receive a “Yellow” because there is no continuity – or Maryland plan for continuity – on the Maryland side of the Woodrow Wilson bridge. 
      • Standalone Transit Lane should receive a “Yellow” for providing continuity with Express Lanes transit priority lanes. 
        
   2. Reduce Congestion and Improve Reliability –
      • VDOT gave all of its alternatives that add lanes for cars a “Green,” ignoring the decades of evidence on induced demand that means congestion returns within a few years. This has been demonstrated not only for general purpose lane capacity additions, but also for express toll lanes projects that add lane capacity.
      • This “Green” rating for Express Lanes also ignores the fact that under VDOT’s Express Lane business model, the general purpose lanes continue to experience congestion and the vast majority of drivers use the general purpose lanes. 
      • The Express Lanes alternatives should have received “Yellows,” and the General Purpose Lane alternatives should have received “Reds.” 
        
   3. Improve Safety –
      • VDOT scored all of its alternatives to add lanes for cars as fully improving safety, “Green.” However, when asked in the two public meetings we attended how the Express Lane and General Purpose Lane alternatives improved safety (especially given that the alternatives remove or reduce shoulders), VDOT staff simply responded that reducing congestion improves safety. We know from the pandemic, when crash rates rose as congestion fell, that this is simply not true – higher speeds and more lanes can lead to more crashes. We also know that congestion returns due to induced demand. The public asked VDOT to share safety data from its existing Express Lane facilities, but VDOT staff would not commit to providing this available data. The Express Lanes and the General Purpose Lane alternatives should have received “Yellows” for safety, or “Reds” unless VDOT provides data confirming their assertions. 
      • The Standalone Transit and Transit TSM/TDM alternatives should also have received “Yellows” rather than “Reds,” as transit is documented to be a safer mode than travel by car by an order of magnitude, and more people would be traveling by the safer transit modes.    
        
   4. Consistency/Compatibility with Regional Plans –
      • Fairfax County and Alexandria transportation plans do not call for HOT lanes or widening of 495 from Springfield to Maryland. The increased VMT related to widening 495 would be counter to the local plans, which emphasize transit and alternatives to driving.
        • Fairfax County Transportation Plan shows 495 Southside as an Enhanced Public Transportation Corridor with HOV lanes but no HOT lanes. It also does not call for further widening.
        • Alexandria Mobility Plan (AMP) – emphasizes alternatives to driving, mobility options, and reducing car dependency. One of its performance indicators is reducing Vehicle Miles Traveled. It does not specifically address 495 or recommend more HOT lanes facilities. In the AMP, these only come up in the context of how signage, information and examination of toll rates on existing highway and HOT facilities could potentially help reduce in-town cut-through traffic. The City’s June 2022 letter to VDOT emphasized these points.
        • Fairfax County Community-Wide Energy and Climate Action Plan – for Transportation planning, its strategy is to “Support sustainable land use, active transportation, public transportation, and Transportation Demand Management to reduce Vehicle-Miles Traveled.” The 495 widening and Express Lanes proposal is not consistent with this strategy.
        • Prince George’s County has not supported recent Express Lanes proposals on I-495.
      • The region’s adopted long-range transportation plan, Visualize 2045, includes the current study but does not propose HOT or Express Lanes in the I-495 Southside corridor.
      • Overall, regional and local plans include a mix of strategies and recommendations that overall prioritize non-single occupant travel modes, Metrorail and bus transit on dedicated lanes, balanced land use, and rapidly lowering greenhouse gas emissions in transportation decisions. While TPB includes “Expand the express highway network, with rapid transit, and allow carpool/vanpool ride free” as one of its seven aspirational initiatives, the rest of TPB’s priority strategies in its policy framework emphasize system improvements that do not expand roadway capacity for private cars and instead emphasize transit, walking and biking, safety, technology, demand management, and transit-oriented and balanced land use.
      • Given these objectives in regional and local plans, there is no plausible explanation for VDOT to score Transit and TDM alternatives as “Red,” adding General Purpose lanes to 495 as “Yellow,” and the Express Lanes alternatives as “Green.”  
      • VDOT’s materials don’t indicate which plans in the region it consulted and how it decided on the screening.  
        
10. The study fails to consider greenhouse gas mitigation and VDOT’s preferred solution would exacerbate the climate problem – TPB adopted a target to reduce on-road greenhouse gas emissions 50% below 2005 levels by 2030. According to TPB’s Climate Mitigation Study, the region has to significantly reduce per capita vehicle miles traveled to reach this goal, even with rapid vehicle electrification. Even for the more moderate adopted regional COG and local Fairfax County, City of Alexandria and Prince George’s County GHG reduction targets (that seek 50% reduction across all sectors), these areas must reduce per capita light duty VMT by about 20% by 2030 from pre-pandemic levels in addition to achieving 50% light duty EV sales by that time. Highway widening projects – even with express toll lanes – contribute to induced demand and higher VMT, as found in a review of the empirical research by the National Center for Sustainable Transportation. 
    
11. CSG appreciates VDOT’s consideration of pedestrian and and bicycle infrastructure improvements along the 495 southside corridor – Improved connectivity across and along 495, more connections between neighborhoods and commercial areas, more direct and enhanced pedestrian and bicycle facilities to the Van Dorn Metro station are needed. Note that further widening the footprint of 495 makes challenging pedestrian connections under and over the roadway even longer, and dark, noisy underpasses (such as at Van Dorn St) are often deterrents to pedestrians. We ask that relevant community stakeholders and pedestrian and bicycle advocacy groups, and local government pedestrian and bicycle coordinators be involved in developing and evaluating alternatives.    
    
12. Public won’t get to comment on the detailed alternatives and their performance until after VDOT’s decision to pick an alternative – According to the schedule presented, VDOT will make its decision on the project next summer and that will be the next public involvement opportunity. That is simply too late. VDOT has provided far too little information about their modeling and the performance data for the alternatives, and has excluded worthwhile alternatives from consideration, as described above. VDOT should both provide additional information during this current public comment period and provide another round of engagement after more information is available on the alternatives – doing so prior to narrowing their range of alternatives.

In conclusion, we ask that VDOT pause the 495 Express Lanes study to revise the Purpose and Need; develop meaningful transit, TDM and transit-oriented land use alternatives; and allow WMATA to complete its ongoing study. 

Thank you for the opportunity to comment. 

Stewart Schwartz
Executive Director

Bill Pugh, AICP CTP
Senior Policy Fellow

cc:

• City of Alexandria Mayor and City Council, transportation staff, and state Delegates and Senators
• Fairfax County Board of Supervisors, transportation staff, and state Delegates and Senators
• Prince George’s County Executive, County Council, transportation staff, and state Delegates and Senators
• Todd Horsley, Virginia Department of Rail and Public Transit
• Maryland Department of Transportation State Highway Administration
• Sandra Jackson, Federal Highway Administration, representative to the National Capital Region Transportation Planning Board