Today, Representatives Jim Moran, Gerry Connolly and Senators Jim Webb and Mark Warner wrote Secretary of Defense Robert Gates expressing concern with the recently submitted Army Transportation Plan for the implementation of BRAC Recommendation #133 at Fort Belvoir-Mark Center, Virginia. Citing inaccuracies throughout the plan, the lawmakers call on Secretary Gates to delay the Mark Center move for one year.  

In their letter, the lawmakers highlight significant flaws in the Army’s Transportation Plan, required by the Fiscal Year 2011 National Defense Authorization Act, including:

• The Army’s failure to take into account findings from studies completed by both the Virginia Department of Transportation (VDOT) and the Army’s Military Surface Deployment and Distribution Command (SDDC). The studies reported severe congestion on I-395, I-395 on- and off- ramps, and surrounding roadways when 6,400 defense employees are shifted to Mark Center.

• The Army’s refusal to examine the traffic effects of the relocation beyond .3 miles of the Mark Center. This small radius was a key reason the Department of Defense Inspector General (DOD IG) faulted the Army’s 2008 Finding of No Significant Impact (FNSI) in its recent report; and

• The plan does not satisfy the requirement of Section 2704 of the FY ’11 National Defense Authorization Act, which mandated a Transportation Plan that will preserve existing levels of service at six identified intersections. The Army’s report accepts the most recent VDOT analysis which shows that without the proposed short- and mid-term improvements, five of the six intersections evaluated will experience failing levels of service. 

“The Department [must] consider all options to avoid the severe disruptions to traffic that will affect the nearly 200,000 commuters including Army personnel who travel on I-395 daily,” the lawmakers wrote.  “In particular, we ask that the Department begin preparations to utilize the BRAC deadline extension as modified by H.R. 1540, the House-passed Fiscal Year 2012 National Defense Authorization Act.”

The DOD IG released an April report “Assessment of BRAC 133 Final Environmental Assessment of July 2008 and Transportation Management Plan (TMP) of July 2010, stating the Army mishandled the selection of the Mark Center and recommended the Army complete a new traffic impact analysis. In their letter, the lawmakers note that “the Army’s inability to produce a transportation plan that satisfies the law further highlights the need for the Department to accept the recommendations of the Inspector General and undertake its own comprehensive Traffic Impact Analysis (TIA)…To date, the Army has not accepted the IG’s recommendations.  This is unacceptable.”

The full text of the letter to Secretary Gates is below:

May 26, 2011

The Honorable Robert Gates

Secretary of Defense

U.S. Department of Defense

1000 Defense Pentagon, Room 3E718

Washington, DC 20301

Dear Secretary Gates: 

We write today to express our strong concern with the Department of the Army’s recently submitted Transportation Plan for the implementation of BRAC Recommendation #133 at Fort Belvoir-Mark Center, Virginia.  The plan, required by Section 2704 of the Fiscal Year 2011 National Defense Authorization Act (Public Law 111-383), is partially false and fails to address Congress’s fundamental requirement that “existing levels of service” be preserved at roadways and intersections surrounding the Mark Center site. 

The Army’s report states, “Four separate traffic analyses conducted over the past several years do not show that there will be significant impacts on I-395.”  This assertion is factually incorrect.  The Virginia Department of Transportation (VDOT) "Mark Center (BRAC 133) Access Study" found that even with the intersection improvements and the completion of HOT lanes improvements (which have been cancelled), the additional traffic resulting from BRAC #133 “will produce significant operational deficiencies” on I-395.   In particular:

• Section 8.2.1 of the VDOT study indicates "new trips generated by the Mark Center site ... on the northbound off-ramp to Seminary is projected to double ... which would result in severe traffic congestion along northbound I-395."
   
• Section 8.2.1. also states, “Southbound general purpose lanes on I-395 between King Street and Seminary Road interchanges would experience severe traffic congestion … during both AM and PM peak conditions."

Other analyses by both the Army’s Military Surface Deployment and Distribution Command (SDDC) and VDOT warn that queuing along the on- and off-ramps will negatively impact I-395. 

• According to the Army’s Military Surface Deployment and Distribution Command (SDDC), at the I-395 and Seminary Road interchange, the number of vehicles exiting the northbound ramp due to BRAC #133 will nearly double.  The increase in traffic will overwhelm the capacity of both the turning lane and intersection, resulting in a decline in the level of service from “D” to “F.” 
   
• Section 4.2 of the 2011 VDOT "Mark Center Short/Mid Term Improvements Alternatives Technical Memorandum" concluded that “most of the study area intersections are showing significant delay resulting in recurring congestion.  Queue spill-back from many of the intersections extend to and interfere with upstream intersections or freeway gore areas.”

Further, VDOT explicitly urged the Army to study the impact that selecting the Mark Center as the preferred alternative for BRAC #133 would have on regional roadways.  In a letter from then-Secretary of Transportation Pierce Homer, dated July 30, 2008 (enclosed), VDOT warned that the traffic study completed for the Mark Center solicitation was insufficient. 

The Army’s refusal to examine the traffic effects of the relocation beyond .3 miles of the Mark Center was a key reason the Department of Defense Inspector General (DOD IG) faulted the Army’s 2008 Finding of No Significant Impact (FNSI) in its recent report “Assessment of BRAC 133 Final Environmental Assessment of July 2008 and Transportation Management Plan (TMP) of July 2010.”  The DOD IG found that the Army did not include or sufficiently address several critical travel demand management strategies in its plan  and recommended that it conduct a more technically robust, stand-alone traffic impact analysis, noting the BRAC #133 Environmental Assessment and/or TMP study limits were very narrowly defined.  The IG noted that VDOT regulations require a standard for traffic impact analysis for the affected area radius to be up to two miles.  To date, the Army has not accepted the IG’s recommendations.  This is unacceptable. 

Finally, the Army’s report does not satisfy the requirement of Section 2704, which mandated a Transportation Plan that will preserve existing levels of service at six identified intersections.  Commendably, the Army’s report accepts the most recent VDOT analysis which shows that without the proposed short- and mid-term improvements, five of the six intersections evaluated will experience failing levels of service.  However, the Army’s inability to produce a transportation plan that satisfies the law further highlights the need for the Department to accept the recommendations of the Inspector General and undertake its own comprehensive Traffic Impact Analysis (TIA).  A TIA would either confirm or disprove that the mitigation measures identified in the Army’s 2008 Environmental Assessment are sufficient to maintain a FNSI.  Should the TIA disprove the FNSI, the Army would be required to implement additional mitigation measures to maintain existing levels of service.

The Army’s report to Congress documents that should the Department fully implement BRAC #133 by the end of 2011, the worst levels of traffic congestion will occur at the intersections and roadways surrounding the Mark Center site, including I-395.  It will take up to 24 months to implement the Defense Access Roads-certified short- and mid-term improvements. The proposed long-term improvement, which VDOT has identified as an HOV ramp to Seminary Road, is not expected to be completed until 2016. 

For these reasons, we again urge the Department to consider all options to avoid the severe disruptions to traffic that will affect the nearly 200,000 commuters (including Army personnel) who travel on I-395 daily.  In particular, we ask that the Department begin preparations to utilize the BRAC deadline extension as modified by H.R. 1540, the House-passed Fiscal Year 2012 National Defense Authorization Act.  Thank you for your continued attention to this matter. We look forward to your prompt response.