Reject VDOT's Environmental Assessment for I-395 HOV Ramp at Seminary Road Until Shortcomings Are Addressed

Petition Asserting That There Are Very Significant Shortcomings in VDOT’s
“Environmental Assessment for the Proposed I-395 HOV Ramp at Seminary Road”
Dated December 20, 2011
and that
The Environmental Assessment Should Be Rejected as Inadequate
Until Those Shortcomings are Fully Addressed

1. WHEREAS, on December 21, 2011, the Virginia Department of Transportation (“VDOT”) approved for public availability its “Environmental Assessment for the Proposed I-395 HOV Ramp at Seminary Road”; and

2. WHEREAS there are numerous relevant matters which do not appear to have received thorough consideration; and

3. WHEREAS, in supporting their original request for a Categorical Exclusion (“CE”), VDOT repeatedly stated that a comprehensive Environmental Assessment (“EA”) would delay the project by 12-14 months; yet the EA now provided took roughly one third of the time that a comprehensive one was to take; and

4. WHEREAS primary justifications for the proposed ramp are stated to be (a) the “high volume of (BRAC-133) employee travel (on I-395) originating from the south” and (b) that “up to forty percent of employees would utilize I-395 as the primary access road to the site from points south”, neither assertion is supported by factual data; and

5. WHEREAS the EA takes no account of existing I-395 traffic which will be drawn to the Seminary Road exit when it becomes the first and only available HOV exit from I-395 between Franconia/Springfield Parkway and the Pentagon; and

6. WHEREAS the “study area” fails to take into consideration the impact that the proposed ramp will have on nearby intersections, many of which VDOT has previously documented as about to have (if not already having) failing levels of service (“LOS”) even before the addition of yet more vehicles drawn by the proposed ramp; and

7. WHEREAS it appears illogical that the northbound I-395 ramp to Seminary Road operated at a LOS D in 2009 but in the “No Build” option is projected to improve to LOS B by 2015 and remain at LOS B for 20 years beyond that; and

8. WHEREAS, apart from “relieving congestion” on the (two) I-395 on and off ramps, the only stated purpose (and implied purview) of the EA was to “address the need for adequate transit vehicle and High Occupancy Vehicle access to the Mark Center” which is, in fact, but one of innumerable, significant current and future traffic generators in the area; and

9. WHEREAS, despite the foregoing, the EA later states that “without improved access to Mark Center…the surrounding freeway network will not be able to handle this additional traffic…” offering false hope when VDOT’s own EA for the HOT lanes concluded “the level of service will deteriorate to ‘F’ throughout most of the (I-395) corridor”; and

10. WHEREAS, despite VDOT asserting that it is the BRAC-133 facility that precipitates the need for the ramp, representatives of the Department of Defense have stated they do not view BRAC-133 as having precipitated any need for the ramp and are thus not prepared to contribute to its funding – logic which VDOT does not appear to challenge; and

11. WHEREAS no assessment has been made of Mark Center’s ability to cope with additional large (van and bus) “High Occupancy Vehicle access” despite reports that the Transportation Center is already unable to cope adequately with the currently-existing demands; and

12. WHEREAS the only options considered were (a) the ramp connecting to east and west Seminary or (b) the ramp connecting only to west Seminary or (c) no build. No other I-395 interchanges nor any high capacity transit options were evaluated despite NEPA’s stated requirement that an EA “look at alternative means” to achieve the objectives; and

13. WHEREAS it is difficult to reconcile the statement that “construction…would result in the removal of the trees, shrubs and other vegetation increasing the visibility of the roadway” with the subsequent assertion that “there would be no effect to the character of the study area”; and

14. WHEREAS it is difficult to reconcile inevitably increased traffic throughout the area with VDOT’s statement that there will be “no adverse impacts to ambient air quality”; and

15. WHEREAS, despite the request of area homeowners, no effort has been made to project the impact that the ramp, the lost trees and the erection of sound walls will have on property values; and

16. WHEREAS characterizing the area as one of “dense urban development consisting of high-rise residential…the high-rise Mark Center…and businesses” is not consistent with the opinions of local residents who view their neighborhoods as suburban with numerous single family homes and cul de sacs; and

17. WHEREAS the numerous development plans for extensive new projects in the area do not support the state-ment that “With the exception of Mark Center, most other planned development projects in the study area vicinity are small”, which leads one to question how valid VDOT’s projections of future area growth/congestion are; and

18. WHEREAS many members of the public disagree with the statement that there has been “Early and continuing coordination with the general public…to determine the scope of the environmental documentation, level of analysis, potential impacts, and mitigation measures and environmental requirements”; and

19. WHEREAS NEPA requires that an EA consider the “cumulative impact” of “past, present and reasonably foreseeable future actions”, VDOT has refused to do so despite there being many such actions of major conse-quence including (a) VDOT’s own HOT Lanes project (b) VDOT’s intent to create an I-395 northbound “auxiliary lane” from Duke Street to Seminary Road without conducting any environmental assessment whatsoever and (c) VDOT’s apparent intent to also consider an I-395 southbound “auxiliary lane” from Seminary Road to Duke Street, presumably also without conducting any environmental assessment; and

20. WHEREAS no attempt has been made to evaluate the impact on I-395 traffic of recent significant reductions in Metro subsidies for federal employees or as a result of intended significant increases in Metro fares; and

21. WHEREAS, several years ago, the City Council of Alexandria passed a resolution requesting VDOT to “eliminate from further consideration…a High Occupancy Vehicle ramp at Seminary Road”, based upon staff’s review that “indicate(d) the primary destinations of HOV traffic (which would use) HOV ramps at Seminary Road (would be) Crystal City, the Pentagon and Potomac Yard…conveying substantial cut through traffic…filter(ing) through the local street network”; and

22. WHEREAS VDOT and our Commonwealth seemingly continue to place their focus on building ever more roads in our region while (a) the vast preponderance of information which the public sees and hears stresses that high capacity transit is the only viable “solution” to our traffic congestion and (b) the Governor states that we need a broader vision for transit and promotes his “Super NOVA” transit study; and

23. WHEREAS the community was advised to submit concerns, questions and suggestions it had about this project to VDOT by September 12, 2011, but to date has received no response; and

24. WHEREAS the Mayor of the City of Alexandria, on behalf of its impacted residents, requested that VDOT’s public hearing be conducted in an open discussion forum/format, but VDOT declined to do so;

NOW THEREFORE BE IT RESOLVED THAT:

(a) The December 21, 2011 Virginia Department of Transportation “Environmental Assessment for the Proposed I-395 HOV Ramp at Seminary Road” be rejected as incomplete based upon its failure to address the numerous issues enumerated above; and

(b) VDOT be requested/directed to address the above shortcomings and resubmit the revised Environmental Assessment for reconsideration by the affected public and the Federal Highway Administration; and furthermore

(c) Should the numerous deficiencies of the Environmental Assessment not be thoroughly addressed and satisfactorily resolved, then the Federal Highway Administration should NOT issue any Finding of No Significant Impact but rather insist that either
a. an Environmental Impact Statement be prepared for this project or
b. the “no build” option be the one chosen.