Fairfax The following letter was addressed to Aubrey Layne, Virginia Secretary of Transportation.
This letter [dated July 21] is to respectfully request that you terminate plans to place a toll on I-66 inside the Beltway to fund the walking trails, bike paths and other multi-modal projects inside the Beltway described in your March 12, 2015 public presentation on this subject. Instead, I request these plans be replaced with different and much improved plans to address the chronic congestion problems on this corridor. I hope the creation of new and improved plans would include substantial interaction with members of the General Assembly from Northern Virginia, not just local government officials.
VDOT's own figures show approximately 900,000 hours of time is wasted by Northern Virginians every business day due to traffic congestion. Governor McAuliffe speaks often about the "New Virginia Economy.” An essential element of improving economic growth in Virginia is to reduce the 900,000 figure as rapidly as possible, so that more of the people's time might be spent on economic activity among other things. Ensuring that transportation projects in Northern Virginia would be selected on the basis of merit, and congestion reduction in particular, is why I thought the General Assembly enacted H.B. 599 (2012) and H.B. 2 (2014) with strong bipartisan votes. It is therefore surprising that the Administration's plans for I-66 inside the Beltway were not evaluated to determine the expected congestion reduction impact, if any, prior to making a public announcement in March. You may recall that I recommended doing do in my June 24, 2014 memo to you.
As you may know, the Northern Virginia Transportation Alliance, which consists of leading business organizations, has characterized the McAuliffe Administration's plans for I-66 inside the Beltway as "Fire! Aim! Ready!" noting a lack of analysis and data to support key assumptions. Also, as you know, the Loudoun County Board of Supervisors recently voted unanimously to oppose the plans.
I share these sentiments, and my concerns about the plans include but are not limited to the following three issues. I would appreciate and value a response to the questions and requests for information that are presented in this letter, and the alternative concepts recommended at the conclusion.
Additional Capacity Is Needed Now on I-66 Inside the Beltway, Not Decades from Now
The need to widen I-66 inside the Beltway now, not in 10 to 25 years as the McAuliffe Administration has proposed, is intuitively obvious to all but the congestion-deniers. Tolling without expanding capacity on a road so badly in need of capacity improvements is an idea that is way out of step with public sentiment. Tolls have been established on I-495, I-95, and are planned for I-66 outside the Beltway, all coincident with vehicle capacity expansion. It seems peculiar, to say the least, that tolls would be added to I-66 inside the Beltway without additional vehicle capacity, Keep in mind this corridor has significant congestion regularly on weekends and mid-day on weekdays, not just during traditional weekday peak periods. By putting off the issue of widening the road, the Administration's proposal ignores the congestion problem outside of peak periods. The plans are so far afield that not even fixing the chronically congested intersection of the Dulles Toll Road Connector (eastbound) and I-66 is included in the plans.
Moreover, making it easy for traffic to travel a mile or so eastbound inside the Beltway in the morning and westbound in the evening to park and ride at the West Falls Church Metro station (which has plenty of available parking), without being subjected to HOV restrictions or a future toll, is one of the most obvious and least expensive ways to promote the use of transit in Northern Virginia. But this is also not part of the Administration's plan, Calls for more multi-modal options along the I-66 corridor ring rather hollow by ignoring this opportunity.
Coincidentally, as I am sure you know, mismanagement at the Washington Area Metropolitan Transit Authority has led to a very recent proposal to reduce service on the Orange Line, which parallels I-66. This comes after peak period weekday service was already reduced by 42 percent a year ago to accommodate the transfer of train cars to the Silver Line. Any additional reduction in service on the Orange Line will likely result in more traffic congestion on I-66, making vehicle capacity expansion even more necessary.
The Plan Lacks Transparency and the Facts Necessary to Evaluate its Merits or Lack Thereof
Information about key toll and congestion impact parameters was not presented at the March kickoff meeting. These include the price range of proposed tolls, the impact of tolls on traffic volume and congestion on I-66 and the Northern Virginia transportation system as a whole, the specific times of day that tolls would be imposed, and the number and cost of the projects that would be funded with the toll revenue and the amount of expected revenue. Public information meetings have been held about the project, but the public is being kept in the dark without this essential information.
Assuming the Administration believes there are projects that should be funded by the toll, what happens when these projects are completed and the toll revenue keeps flowing?
Given the nature of the proposal, I am concerned that, depending on yet unknown toll pricing and timing, the plans might create rather than reduce congestion by diverting traffic to U.S. 50, U.S. 29, Rt. 7, I-495, or neighborhood streets in Arlington, McLean, and Falls Church. After all, if it is assumed that tolling would reduce congestion on I-66, but no additional road capacity would be added, then this can only mean that some existing traffic would no longer use I-66 and go elsewhere instead. Does the
Administration believe that the traffic that would no longer use I-66 inside the Beltway would convert to carpooling, transit or bicycles? If not, the plans would not reduce congestion, only re-arrange it.
You, I and many others have worked hard to end "politics as usual” with respect to transportation policy and bring more transparency and accountability to the process of selecting and funding transportation projects with the people's money. A key element of this process is to ensure that projects are selected based on merit according to objective criteria. The plans for 1-66 inside the Beltway presented so far don’t do this. Regrettably, this project looks a lot like politics as usual.
With respect to H.B. 2, I’m told there is an opinion shared by some in the McAuliffe Administration that the nature of this project somehow exempts it from the requirements of H.B. 2. If this is the Administration's position, I would appreciate and value a legal analysis on this point. Even if this were true, the McAuliffe Administration should want to score this proposal according to H.B. 2 anyway as a demonstration of its commitment to the principle of project selection based on merit.
Please allow me to call attention to the fact that the provisions of H.B. 599 apply to “all significant transportation projects” in Northern Virginia. This legislation was not amended or superseded by H.B. 2; I would appreciate and value an explanation regarding why the Administration is proceeding with plans for I-66 inside the Beltway without having first performed an analysis pursuant to H.B. 599 as required by law. If there is some ambiguity about this provision of law, please let me know,
The Administration's proposal also ignores the fact that 30 percent of the portion of H.B. 2313 (2013) tax revenue dedicated to Northern Virginia is allocated to localities for transportation and can be used at their discretion, including for walkways, bike paths, and multi-modal options. On top of this, Fairfax County approved $100 million in bonding authority in 2014, misnamed "transportation,” of which $86 million is dedicated to walkways and bike paths. I would appreciate and value an explanation regarding why the revenue already available to localities in Northern Virginia for walkways, bike paths, and other multi-modal options is not sufficient, and that toll revenue is needed.
Similarly, 70 percent of the portion of H.B. 2313 tax revenue is allocated to the Northern Virginia Transportation Authority, which can fund roadway and multi-modal projects along the 1-66 corridor inside the Beltway. Why is this existing tax revenue, plus the revenue collected by the state from H.B. 2313 and prior legislation, not sufficient and toll revenue necessary?
A related issue is who would pay the toll and who would benefit from it. While I will await the completion of the appropriate analysis, it would seem likely that many, if not most of the expected toll payers live outside the Beltway, while the projects that would be funded by the toll would benefit mostly those living inside the Beltway, if true, this raises a fundamental issue of fairness. Likewise, it is unfair for motorists to pay a toll to drive on a road that tax dollars have already paid to build and maintain.
Assigning the Northern Virginia Transportation Commission and not the Northern Virginia Transportation Authority or the CTB to Spend Toll Revenue Doesn't Make Sense
After years of having no money to spend on transportation projects, the Northern Virginia Transportation Authority was put into business with a portion of the tax revenue from H.B. 2313. While the Authority still has significant progress to make in order to meet the expectations of H.B. 2313, it has established a project selection process that is funding all modes of transportation in Northern Virginia, including along the I-66 corridor, and has established processes to facilitate project implementation. NVTC has none of this in place, but has a substantially overlapping membership of localities including certain elected officials who attend both NVTC and NVTA meetings. (Disclosure: I am a member of the NVTC).
So I'm sure you can understand why I'm surprised by your willingness to give the NVTC, and not the NVTA or the Commonwealth Transportation Board, the role of spending toll revenue as noted in your March 25, 2015 letter to the heads of government in Arlington, Fairfax County, and Falls Church. Choosing NVTC would create a redundant and unnecessary local government bureaucracy at the NVTC to do what the NVTA and the CTB are already doing. No well-run business would organize its decision making processes in this way. Decision making with public money should not be designed to a lower standard. My concern is amplified by the fact that the NVTC is not subject to the project selection-by-merit approach used by the NVTA and the CTB. I would appreciate and value your explanation of why the NVTC was chosen among the alternatives.
In conclusion, I would be happy to work with you and your team to develop new plans for I-66 inside the Beltway. Rating project options according to H.B. 599 and H.B. 2 should be among the first steps taken, so that state and local decision makers, as well as the public, can evaluate the options based on expected congestion reduction relative to cost. Options for evaluation should include several scenarios, such as widening I-66 inside the Beltway by one or two lanes in each direction, all the way to the Potomac River, as well as part of the way through Arlington. The analysis should also include the congestion reduction impact of fixing the I-66/Dulles Connector intersection, and removing HOV restrictions between the West Falls Church Metro station and the Beltway, with direct access to the station from I-66.
Given the proximity of I-66 to Washington, D.C. and important national security assets in Northern Virginia, the analysis should also examine the degree to which different scenarios would be expected to improve regional mobility and save lives in the event of a homeland security emergency in Washington or Northern Virginia, as specifically referenced in H.B. 599.
lf our collective purpose is to put merit and objectivity ahead of politics as usual, then we should neither hesitate to evaluate these kinds of options pursuant to H.B. 599 and H.B. 2, nor fear the results.