Honorable Phyllis Randall Chair
Chair Randall and NVTAboard members:
Sincerely,
● Takes urgent and adequate action on climate change rather than passing the buck on an existential threat;
Northern VirginiaTransportationAuthority
● Addresses the land use and housing issues underpinning our key transportation problems;
September 18, 2022
● Removes destructive and wasteful projects like new Potomac River highway crossings, the Bi County Parkway, and too many widenings of suburban arterials;
Re: Comments on the proposed 2022TransAction, and recommendation to reject the plan as drafted
We urge you to review and consider the joint letter of 12 Northern Virginia organizations regardingTransAction 2045 These are not new concerns we have pointed to the shortcomings for some time. We also urge you to reject thisTransAction plan and create a new more effective, affordable and sustainable plan. Staff failed to provide you with a set of bottom up scenarios to enable you and the public to consider alternative futures Instead we are given one stapled together list of projects that we cannot afford and that would make our transportation, equity and climate problems worse Northern Virginia would benefit from a plan that:
Stewart Schwartz Bill Pugh Executive Director Senior Policy Fellow
3040 Williams Drive, Suite 200 Fairfax, VA22031
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● Replaces a $76 billion wish list with a more effective as well as sustainable, equitable and livable package of investments that prioritize and support the region’s vision for a network of walkable, bikeable, and inclusive transit-oriented communities.
● Pursues the pricing and demand management strategies which NVTAitself says are necessary; and
On the following pages are the Coalition for Smarter Growth’s specific comments, which add detail to the points in the joint letter, and demonstrate the serious flaws in theTransAction 2045 plan We urge you to reject the current plan and to develop a more sustainable, effective, and equitable approach for Northern Virginia.
The $76 billion cost ofTransAction exceeds by four times what the region’s constrained long-range transportation plan, Visualize 2045, estimates Northern Virginia can realistically spend for improved transit, road, and active transportation facilities And in just five years, the price tag ofTransAction increased by over 50%, even accounting for inflation
1 Source: Visualize 2045,AppendixAFinancial Plan,Table 3.The 2017TransAction costs were escalated from FY17 dollars to 2021 dollars based on the CPI as a rough order-of-magnitude estimate. The Visualize 2045 Financial Plan usesYear of Expenditure dollars while TransAction project costs are presented in 2021 dollars.AlthoughTransAction includes some projects that extend into Maryland and DC, even if their entire system expansion budgets from the CLRPwere added onto Virginia’s, it still wouldn’t cover the cost of TransAction. We acknowledge that the NVTAand TPB plans present financial needs in different formats, so this comparison is intended to show rough magnitudes.
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Aplan that can’t be built is not a plan, and the perceived results of the plan cannot be claimed if the plan is in no way affordable.TransAction describes its many benefits in the future tense “will”, and urges local governments to work together to build all of the projects in it.This approach does not help Northern Virginia make informed decisions, nor does it address our many other infrastructure needs thatTransAction ignores.
TransAction’s price tag versus Northern Virginia system expansion funding in the region’s constrained long range transportation plan1
1 A$76 billion unconstrained plan is neither realistic nor informative
Our region has many other needs for limited infrastructure dollars, including upgrading our infrastructure to withstand the impacts of climate change already occurring, addressing the increasing maintenance and repair needs, implementing our climate action plans, addressing the housing crisis, etc For example, the Commonwealth’s VTrans 2045 analysis shows that Northern Virginia will have 400 more miles of roads at risk of flooding due to climate change how are we going to pay for needs like that and why doesTransAction ignore them?
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Sustainability is a core value of NVTAbutTransAction fails to address the region’s largest source of planet warming emissions in any meaningful way The draft plan:
2. NVTAneeds to address the land use and housing issues causing our key transportation problems
Visualize 2045 showed a larger increase in the numbers of jobs accessible by transit than by automobile, despite the plan investing twice as much in highway and road expansion This was due in large part to the benefits of future transit oriented development. Imagine how much more job access could improve if all NVTAjurisdictions prioritized putting housing and jobs in compact, mixed-use, walkable activity centers with existing or planned transit.
The National Capital RegionTransportation Planning Board says achieving adopted regional housing targets would reduce congestion by 20%.That’s the same amount of congestion reduction that would be achieved IF the entire $76 billion plan were built Northern Virginia jurisdictions through their MWCOG representatives have endorsed these housing targets, which include locating 75% of new housing in transit served walkable activity centers and ensuring 75% of it is affordable Investing in affordable housing close to jobs and transit would therefore be a particularly effective part of a more equitable and sustainable transportation solution.
● Ignores the significant 2030 reductions needed, and doesn’t mention key climate plans and studies from our own region that clearly spell out the changes necessary in our transportation system and land use by 2030 and beyond
If NVTAdecides to continue withTransAction’s unconstrained $76 billion approach, then it should at least acknowledge the magnitude of the funding gap and the other critical needs for Northern Virginia’s infrastructure dollars.
● Increases per capita VMT4% above the future baseline, when the region needs to reduce per capita VMTover 20% by 2045 in addition to rapid EV adoption, to achieve adopted climate targets.2
3. TransAction fails on climate change - both in 2030 and in 2045
2 Level of per capita VMTreduction needed in California by 2045 in addition to its ambitious EV adoption policies to meet state climate targets (CaliforniaAir Resources Board 2022 Draft Scoping Plan) In addition, theTPB’s Climate Change Mitigation Study of 2021 found that only scenarios which achieve per capita light duty VMTreductions in the range of 15-20% by 2030 would achieve the levels of on-road transportation emissions needed in the region’s 2030 Climate and EnergyAction Plan Likewise, RMI has found that the U S must reduce per capita light duty VMTby 20% below 2019 levels by 2030 in addition to very rapid adoption of EVs (25% of light duty vehicles on the road)
● Inappropriately takes credit for a 54% GHG emission reduction from increased electric vehicle adoption, because the analysis excludes this electric vehicle adoption from future baseline “No Build” conditions (for example, chart on page 22 of the draft summary plan) TransAction includes a small $51 million investment in electric vehicle charging
Anew approach toTransAction must address the 2030 and 2050 greenhouse gas reduction targets, showing what Northern Virginia needs to do to reduce on road transportation emissions fast enough, and proposing a package of projects and programs that can achieve them
stations over the life of the plan, which while helpful, is not moving the needle relative to the scale of the overall charging infrastructure need or the state and federal rebates, clean cars, consumer preferences and tech advances driving electric vehicle adoption The real story is thatTransAction fails to reduce emissions below future baseline conditions. ExcludingTransAction’s electric vehicle assumptions, emissions go up 1.7% relative to future No Build baseline as a result of buildingTransAction’s many highway and arterial expansion projects and failing to address auto-oriented land use policies. Assuming the small investment in EV charging stations marginally helps reduce emissions, the emission reductions and increases of the $76 billion dollar plan are essentially a wash.3
In our “On the Wrong Road” report, CSG showed that the enormous package of highway and arterial widening projects in the lastTransAction plan (similar to the current version) would increase road capacity and driving far faster than population growth in places like Prince William and Loudoun counties and even significantly in Fairfax County
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4 TPB’s GHG reduction goal is relative to 2005 levels, while NVTAcalculates its reduction relative to the 2017 base year However, totalTPB region on road GHG emissions in 2005 and 2017 was similar (just above 20M MTCO2e, seeTPB’s CCMS, Final Report, Figure ES 2)
● Pays only token attention to significant investments needed to electrify vehicle fleets (buses, trucks, and cars) and provide necessary charging infrastructure: $51 million over 23 years While we applaud the NVTAfor including charging infrastructure in TransAction, the plan doesn’t quantify the needs This recommended amount appears to be very little, especially compared to the vast sums invested in highway expansion.
TransAction incorporates some good “top down” regional projects a coordinated bus rapid transit network, for example but also some destructive ones like the Bi County Parkway and major new highways from Loudoun and Prince William across the Potomac into rural areas of Maryland, that together would form a substantial portion of the controversial Outer Beltway
● Leaves Northern Virginia far from 2050 carbon neutrality with a 54% decrease in emissions by 2045 TheTPB set a goal to achieve an emission reduction in that ballpark by 2030.4
4. TransAction continues to include destructive major new highways that need to be removed
3 Plan has1 7% increase in emissions above No Build when excluding EV adoption Plan only has a small investment in charging infrastructure: $51M over 23 years (trucks, bus, car charging total in projects #458, 459, 460) So it’s unlikely to see how that small investment could significantly decrease emissions Looks like a wash (plan does not increase/decrease emissions relative to No Build)
● Fails to mention the major investments needed to upgrade our existing transportation infrastructure to handle the extreme weather already occurring and getting worse with climate change.
Pricing strategies, paired with better land use and housing near transit, electric vehicles, and supportive transit, local street network, and bike/pedestrian investments, would be more effective and could be implemented more feasibly and quickly than an unconstrained plan.
The 2022TransAction provides a good scenario analysis of what such road and parking pricing mechanisms could look like and includes discounts for low income drivers and free transit The incentives and pricing, with equity provisions, achieve largely the same improvements as the TransAction plan and its 429 projects
TransAction because of induced demand and its failure to address land use does not achieve NVTA’s own recommended strategy for improving congestion, which is to reduce the ratio of VMTto Passenger MilesTraveled (see page 28 of theTechnology Strategic Plan).This ratio in future No Build 2045 conditions is 0 725 and after spending $76 billion implementing TransAction, it would be 0 724, virtually unchanged
5. TransAction makes safety claims without data and too often prioritizes high-speed auto travel on wider and wider roads
5. Incentives and Pricing Scenario suggests ways to achieve near-term mobility and climate goals without the $76 billion price tag
TransAction on page 23 says that the proposed network (IF it could be built) improves safety without providing the data Despite safety being a core value, the performance measures for “Potential for Safety and Security Improvements” and “Quality ofAccess toTransit and the Ped/Bike Network” are not yet available.The public comment period is ending on September 18th without this important information being shared Asecond comment period may be warranted and this information should be made available to the NVTAboard before it votes on the plan.
WhileTransAction includes a large total dollar value of transit projects, in practice, the NVTA has allocated most of its regional funding through the Six-Year Program to expanding highway and road capacity.Abetter approach is to remove the destructive and unaffordable new highway projects fromTransAction.
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NVTA’s Technology Strategic Plan says the region should 1) reduce VMTrelative to passenger trips to reduce congestion, 2) that we can’t do this through expanding highway capacity because of induced demand, so 3) NVTAneeds to “develop pricing mechanisms that manage travel demand and provide sustainable travel options ” (page 40, Strategy #5)
NVTAitself acknowledges the self defeating aspect of highway expansion due to induced driving. Its Technology Strategic Plan, page 28, states that: “Expanding infrastructure capacity, especially highway capacity, presents multiple challenges in mitigating this congestion (due to the phenomena of induced demand) and achieving NVTA’s goals of equity, sustainability and safety, although it will likely remain an important option.”
CSG and other Northern Virginia organizations have repeatedly requested an integrated and comprehensive, transit-oriented land use, housing, and pricing/demand management scenario with a more feasible and supportive project list.This would provide valuable information to NVTA, and this current plan should be re done with such an approach
Also, the simplistic transit-only scenario excluded the proposed local street grid projects and pedestrian and bike improvements inTransAction that are needed to support transit oriented development and the transit projects, and would help generate higher transit ridership
6. Modeling Transit-only versus Highway-only scenarios needs to be replaced with real scenarios that address the land use underpinning these investments
Thank you for soliciting stakeholder feedback and for reviewing our comments. Please let us know if you would like to discuss further these recommendations for improvingTransAction
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Modeling all of the proposed transit investments and proposed highway and road expansion separately but with the same baseline land use does not provide useful information.The lack of transit supportive land use plans in parts of the middle ring and especially in the outer ring suburbs does not allow the proposed transit investments in these areas to perform as they should
Many proposed arterial expansion projects would increase the numbers of lanes, while seeking to maintain high vehicle speeds, making crossing distances even longer and increasing risks for pedestrians. While CSG applauds the trail, bicycle and pedestrian improvements in the plan, too many of these are conditioned on major arterial expansions and accompanying auto oriented small area plans and zoning that separate land uses and make trips by walking and biking longer, less convenient, less pleasant, and undercut safety improvements.