Widening I-66 is far from insignificant

As we discussed last week, the Virginia Department of Transportation will be presenting environmental review documents to justify widening I-66 from two lanes to three lanes for significant portions between Rosslyn and West Falls Church. The environmental review documents are in the form of a Categorical Exclusion, which under NEPA means that the widening would not have a significant effect on the environment, significantly reducing public involvement in the environmental review process.

I believe that this exclusion is based on a misapplication of a FHWA regulation, treating an extended third lane of the interstate the same as a much shorter “weave lane” that is used to bridge between an entrance lane and an exit lane. I encourage interested people to attend the public meeting and object to the project on these grounds.

The public meeting is Monday, October 27, 7:00 pm at Washington Lee High School in Arlington.

The National Environmental Policy Act (NEPA) controls environmental review for Federal projects. It’s what causes agencies to have to produce Environmental Impact Statements, Environmental Assessments, and to seek public comment on such projects. A much abbreviated environmental review is available for projects that meet certain criteria. This is called a Categorical Exemption, defined as follows:

“Categorical exclusion” means a category of actions which do not individually or cumulatively have a significant effect on the human environment and which have been found to have no such effect in procedures adopted by a Federal agency in implementation of these regulations (Sec. 1507.3) and for which, therefore, neither an environmental assessment nor an environmental impact statementis required. (emphasis added)

And “effects” is defined as follows:

(a) Direct effects, which are caused by the action and occur at the same time and place. (b) Indirect effects, which are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems. (emphasis added)

I heard back from the District Environmental Manager from VDOT concerning the use of a Categorical Exemption (CE) for the I-66 spot improvements project. They cited a regulation containing this language:

The applicant shall submit documentation which demonstrates that the specific conditions or criteria for these CEs are satisfied and that significant environmental effects will not result. Examples of such actions include but are not limited to:

1. Modernization of a highway by resurfacing, restoration, rehabilitation, reconstruction, adding shoulders, or adding auxiliary lanes (e.g., parking, weaving, turning, climbing).

The I-66 project doesn’t seem to fit any of those except possibly adding an auxiliary lane. If it were a shorter project, this might be considered a “weaving lane”, which is a lane between an entrance and an exit ramp that allows oncoming and outgoing traffic to merge across each other. However, the three spot improvement sections are 1.06, 1.4 and 1.6 miles long each, much more than enough length for any weaving lane that I’m familiar with. I’m going to ask my friend who’s a traffic engineer.

I recommend that anyone attending the public meeting to concentrate their comments on the idea that the environmental review appears to be cut short by inappropriately considering these to be short, limited improvements as opposed to a third lane construction for an interstate highway.

Cross-posted on Infosnack.org.