ARLINGTON COALITION FOR SENSIBLE TRANSPORTATION (ACST)
POSITIONS ON THE I-66 "SPOT IMPROVEMENTS" (10/27/08)
On October 27, 2008, the Virginia Department of Transportation (VDOT) held a public hearing to receive comments on its proposed design for three "spot improvements" along westbound I-66 in Arlington. Several project documents are posted for downloading.
Please submit written comments, opposing project construction, by Nov. 12, 2008, VDOT's comment deadline. Address your e-mail to firstname.lastname@example.org
1) Take No Decision to Widen Without an Adopted Comprehensive Corridor Plan. Twice previously, in October 2001 and in May 2004, the National Capital Region Transportation Planning Board had authorized VDOT to conduct funded multimodal corridor studies, but the first study was never initiated in 20 months, and the second study, dubbed "Idea-66", was clearly manipulated to recommend the third westbound travel lane requested by Congressman Frank Wolf. In fact, the March 2005 Final Report of VDOT's Idea-66 Study clearly showed that expanded HOV hours and/or automated tolls--permanently ensuring uncongested travel--and enhanced bus service—alternatives with no significant roadway construction--are each superior overall to another westbound travel lane.
More recently, the Virginia Department of Rail and Public Transportation (DRPT) has initiated a third multimodal corridor study (bus-transit study) for I-66 inside the Beltway. DRPT should broaden the scope of this study to evaluate how shoulder busways, expanded HOV hours, and/or automated tolls would impact I-66 and regional traffic and the viability of transit alternatives.
2) VDOT's March 2005 Idea-66 Final Report made a sham of the Idea-66 public process. None of the three "spot improvements" that VDOT has since advanced were clearly discussed anywhere in that report, although VDOT had already scoped this "spot improvement" project internally.
3) VDOT's Categorical Exclusion (CE) document is inappropriate and seriously flawed. Adding another freeway lane for a total of 4.3 miles is plainly an effort to significantly expand I-66 capacity for free SOV travel. That is most evident for "Improvement #2" which would create four westbound travel lanes for 1.5 miles, double the number agreed to under the Coleman Decision. The CE's claims of an adequate public process, of a lack of feasible and better interim alternatives, and of no substantial public controversy are all clearly false. In addition, the proposed extension of entrance and exit ramps for 1.1 to 1.7 miles is not required for safe traffic operations along westbound I-66.
4) The Commonwealth Transportation Board should drop "Improvement #3" (the still-unfunded easternmost segment) from VDOT's Six-Year Improvement Program because it would have the least benefits, even to reduce congestion for SOVs, and would create a new westbound bottleneck at the low-volume Glebe Rd exit, where three westbound lanes would decrease to two.
5) The Commonwealth Transportation Board should drop "Improvement #2" (the westernmost segment) from VDOT's Six-Year Improvement Program because it would undesirably expand freeway capacity for SOVs; increase traffic congestion elsewhere (including eastbound I-66); promote urban sprawl, global climate change, and foreign oil dependence; decrease ridesharing, transit use, and Metrorail fare revenues; and increase cut-through traffic on Lee Highway and Washington Blvd in Arlington to enter and exit I-66 in East Falls Church.
6) The Commonwealth Transportation Board should drop "Improvement #1" (the middle segment) from VDOT's Six-Year Improvement Program because narrowing the travel lanes and reducing safety shoulders would seriously degrade motorist safety and the clearing of traffic incidents. This segment would also create a new westbound bottleneck at the low-volume Sycamore St exit, where three westbound lanes would drop down to two, and the increased exiting traffic would endanger pedestrians walking to the East Falls Church Metro station.
7) VDOT has skirted The National Environmental Policy Act (NEPA) by ignoring effective alternatives to these particular "spot improvements". NEPA mandates that all federally funded projects adequately consider all reasonable alternatives to the proposed "action" as well as all significant impacts on the natural and human environment, but VDOT's pursuit of "interim spot improvements" and the specific "improvements" being pursued are "arbitrary and capricious". VDOT evidently concocted the three "spot improvements" by late 2004 or early 2005 as a way to spend Rep. Frank Wolf's pending $27.6 million federal earmarks by skirting NEPA requirements. To at least minimally comply with NEPA, VDOT must fully and fairly study alternative feasible spot improvements and prepare at least an environmental assessment document for its proposed action.
For example, to improve highway safety, police enforcement, incident management, and emergency evacuations and to possibly move buses when the travel lanes are congested, VDOT could simply provide a continuous 12-ft wide inside paved shoulder, instead of discontinuous third-lane segments with substandard, narrow inside shoulders at some locations. Alternatively, or in addition, VDOT could advance shorter on-ramp extensions and/or provide extra police enforcement locations as superior spot improvements.
8) VDOT has failed to properly analyze the many negative Impacts of its proposed "improvements". VDOT used a flawed traffic-modeling process to rationalize the proposed spot improvements, rather than a valid trip-generation model to appropriately forecast traffic impacts at the following locations: a) along each widened I-66 segment and the connecting freeway segments immediately east and west, b) along eastbound I-66 (where traffic congestion is already worse), and c) at nearby connecting intersections (including on Lee Hwy, Glebe Rd, Sycamore St, and Route 7). In addition, VDOT must show how creating two new westbound bottlenecks (at the low-volume Glebe Rd and Sycamore St exits) and narrowing safety shoulders would affect traffic congestion, safety, and incident management. By inducing new auto trips and auto-dependent development while not improving or incentivizing non-auto travel, the proposed construction would increase noise, water, and air pollution, including climate change carbon dioxide emissions.
Arlington Coalition for Sensible Transportation
PO Box 5574, Arlington VA 22205-5574