Pollution of any type, chemical, noise, even certain repeated social injustices, may be considered due cause for corrective action, or in many cases, a no build option. An incineration plant, for example, may not be placed where the fallout from such an appliance can inundate a given population that may already be located in the midst of city smog or other commercial, industrial, or municipal machinery, say, a power generating unit where there would be the possible emission of soot or other hazards.

What is strange about the DEIS is how it uses a concept like this to practice a reverse discrimination on not only a given group, but also on an entire region! It is to be assumed that the victims as defined in the working concept are minority, low-income groups which can be identified by where they are, what they do, and by what they get for doing it. They are a neighborhood. We, on the other hand, are a region comprised of many neighborhoods; a region that has been classified in this report as white, fairly high in income, and well educated with Judeo-Christian religious backgrounds. And because of this, there is no reason whatsoever why the idea of environmental justice should be applied to us, to our region as a whole. We are a blank chapter in PennDOT’s social coloring book where there should certainly be a fair and realistic version of who we are. We are many and varied, mostly white, and scattered all about the income range with all kinds of education. All are welcome! All need suffer because we are classified as more able to take this situation on, or maybe it’s just our turn to be justified in this manner.

In looking to be the arbiter for social justice, PennDOT has, however unwittingly, set in motion a dichotomy made of mobile vs. immobile. The concept bridge that sets apart land ownership, homesteading and community construction is now subject to the momentary visitor being able to be sure of a rapid passage through our efforts –and our lives!

While there are many reasons to be concerned about highway and traffic safety, and about how these things allow us all mobility when we want or need it, there is no reason to assume that more and wider and more complex roadways that traverse our very communities, intruding now upon our homes and lives in ways never imagined, is going to help or improve us. Public transportation modes that are appealing and that actually work surely would. Yet another strange finding within the report tells us, or someone, that our areas have changed throughout the years from a rural to an urban environment. Well, to some extent, in some places, yes they have. The reportage goes on to say that due to this growth and change, our view will not be intimidated by the sudden impact of this project.

In reality, our areas have changed through a distinctly made program of gradualism. Our communities have been built and changed in this way by those of us who live within them. And while they may not at all turns are what each one of us would want them to exactly be, they have nevertheless evolved before us, and we with them. It is a preposterous idea which posits the notion that somehow the imposition of what is the Woodhaven Road Project upon the building we have all done, and the evolution we have witnessed, would be an acceptable finishing touch. There is a difference between a field of cows turned into a development, or a farm becoming a shopping center, or perhaps a wooded area becoming a park, and one day waking to find your home walled up to prevent an endless drone of traffic noise from becoming overwhelming. There is an absolute distinction that stands between evolutionary gradualism and vindictive imperialism.

This DEIS has taken a stand against community and the right of the people who comprise it to develop neighborhoods and institutions as they see fit, in moments of their own choosing. Philosophical gradualism may not be the by-word of each and every day, but it is always present as a notion, if you will, that allows people to connect with their environment and at the same time to change it and understand it. Liking it often takes time which should be ours to take. This is environmental justice.

Human Resources
The DEIS as prepared and presented by PennDOT has little to say concerning the impact of what it proposes upon the human condition of those in its wake. Aside from making statements about the probability that local contractors and workers might stand to benefit from such massive construction, the report does not make mention of people and the investments they have made in homes, families, or communities. The only real concerns are technical questions of pedestrian safety and the like. While important, these items are always there, and always at issue.

The sudden loss of confidence in the stability of a neighborhood, or the plain worry and angst over a crumbling foundation on a home that one has worked for over a lifetime, are not things the DEIS addresses. Frustrations dealing with the un-reality of it all, the simple-minded assumptions that fail to recognize and admit to mistakes do not enter into how PennDOT deals with people. It was, after all, PennDOT who spent millions on a highway to nowhere in the form of Woodhaven Road. And, it is PennDOT who wants to alter our place on this planet in order to move the traffic problems they say they want to solve further down the road –about a mile from where they may occur now.

Lastly, the people of our region gathered their resources in an attempt to create a “Community Friendly Alternative” to any of the alternatives presented by PennDOT. These efforts have been flatly rejected, and one wonders if they ever had been considered at all. There are many reasons why this suspicion exists and every one may hark back to the style and manner of PennDOT and their chief presenter, Mr. Andrew Warren, who merely goes about spreading the confusion which clearly characterizes the internal effort at PennDOT. There is no sense that any of this could ever be considered part of an emotional environment with an impact cost to the landscape of the spirit. On this alone, the DEIS is a failed document.

County Line Road
County Line Road can never be part of an express mode of vehicular travel; certainly not the area from South Buck Road to Huntingdon Pike. This two lane portion of the road is hill-and-dale, and added with that is the presence of many close side streets on the north-eastern or Upper Southampton side. It is even now a dangerous roadway where cars and trucks bound up over a hilly section of the roadway just as one pulls out. County Line is the only way in or out for hundreds of drivers who live within the unique areas adjacent to the PA turnpike. All that I have outlined throughout this review of the DEIS comes swiftly to focus when looking at County Line and what the document presented by PennDOT does not address.

The DEIS is a very slick affair, having pull out maps and plenty of official palaver concerning the righteous needs which PennDOT sees for us. But one thing is always missing – the reality of what it is they are actually going to do –to the world around us, and to us. There is no mention of any technical problems with this road as is, or any of the exacerbations to these problems which would surely be present if the road is widened. There is no inclusion as to safety issues for homes that will be so close to the road. What about truck traffic, noise and vibration? What if a tire breaks off and sails toward us as we work what frontages we will still have? What if something crashes into our homes? Is there any measure of safety at all built into the plan for the road I am looking at? Speed enforcement has never meant much on this road, and while the limit is 40, most vehicles move at 50 or above most of the time! This constant movement causes noise that is already too loud. What will exacerbate such a state to an even greater degree will undoubtedly be the “upgraded” version of this problem roadway. When planned as a four lane highway, County Line will break the sound barrier.

Concrete Sound Walls

Sound walls or sound barriers have been hugely built into the plans for many roadways included within the project area. County Line is one such roadway. Here, the DEIS is very specific, blatant even, in its l iberal use of something that may or may not have an effect on sound propagation, but will most certainly serve to cover, block, shade, and isolate many homesteads with a possibility that such devices worsen the auditory effects of moving vehicles –especially when used in very close proximity to traffic at speed. These effects can be worsened still further by halving the barriers, as in one side of the road and not the other; as in County Line Road.

Over thirty years ago, when County Line was widened on each side of the present two lane area, many things were acceptable that are not so now. Over these years we have learned some things about noise, light, vibration, and many aspects of pollution and pollution control. There have even been many ideas developed just for roadways and what they should and should not do to those near them. In the 1970’s, the average car audio system consisted of an AM radio, and maybe, just maybe, an FM band as well. These units never exceeded a power rating of more than about 12 watts of music power, meaning that the volume would be full up to reach this level.

Today, all car, truck and SUV systems exceed in power, sometimes on the order of hundreds of watts. Then too, there are the specialty systems which can thump their way through the night with thousands of watts. Things have changed. Anyone taking notice of any highway can hear these differences with relative ease. Anyone at home can be startled or even frightened by the sounds emanating from vehicular traffic. Audio systems are just one of many inherent additions in today’s traffic patterns which contribute to shattering noise scenarios.

In order to better isolate us from these sounds, PennDOT uses sound barrier and absorption walls. In the case of turnpikes or major highways where traffic is somewhat removed from the living or working space, these may suffice, however, the use of these walls when traffic is in very close proximity to homes or businesses is often not always desirable. This is because when used on both sides of a highway, these walls will reverberate, thus creating a hollow sounding roar caused in part by the Doppler effect which in turn rebounds from either outside wall to the buildings beyond. Not having this full coverage presents another situation entirely, and that situation can be devastating for the structure in front of the roadway where the only barrier wall is across the road! This leaves the opposite wall as a reflective radiator or propagation driver. It also positions traffic directly before the home and neighborhood without any protection whatsoever.

Now, of course, without any barrier, the sounds are amplified. For those under cover of the opposite side barrier, sounds may, or may actually not, be resolved to a lower level. In any event, they will be subjected to the wall as an aesthetic nightmare. PennDOT feels that there is an alternative in the form of absorptive wall material. Still, there would be a wall and problems with sound still prevalent. The example used by PennDOT is in fact aimed at County Line. Here, because of the adjoining streets and homeowner driveways, it is recommended, but not feasible, to use barriers on both sides of the roadway. One side would have them, while one would not. Absorptive material, so they say, might solve the problem.

As above, the single sided approach has problems, the same problems in fact would appear simply because while some rebound would be stalled with the wall area acting less as a radiator, the proximity to the source, remember the vehicles making the noise, would suffice to introduce the same amount of noise to those without the wall. Each vehicle, with its attendant rolling friction and exhaust note, and possible audio system leakage, is a plentitude of noise. It is, in fact, a point source. As such it t will not be mitigated by a free standing absorber in space. If anything, there may be present a more accurate rendition of the vehicle due to the catchments around it, in other words, letting it speak for itself. But in reality, very little mitigation is possible in this manner. So that leaves homes on my side of the road with nothing. Certainly no wall can be desirable, but relentless, awful noise is not either.

To its credit, the DEIS does explain the rating standards for sound propagation and what is acceptable and what is not. These standards are produced by both PennDOT and the Federal Highway Administration. Almost all of the roads in question are failing when it comes to noise delivery in the present and as projections to 2026 with “improvements” provided by the Woodhaven Road Project. The problem herein is this: The standards for noise pollution indicate that County Line needs protection on both sides. If this can not be accomplished due to previously sighted architectural problems with this roadway, then there would clearly be a violation of standards set by both PennDOT, and the Federal Highway Administration. Taken as a whole, County Line Road is not suitable for the task assumed for it in either the project plan or the DEIS and is not likely to be. By definition then, this road would be in direct violation of standards set to define and rectify noise pollution for those forced to live directly and indirectly near it. County Line Road, and any road within the project area that falls categorically into this context, should therefore not be included in it.

Conclusion
Here I am, looking out toward what could become the project area. This is a horror story prescribed by plan and written out in the form of the DEIS with all of its omissions and spin. All of this is an impossible drama for those of us forced to contemplate it as reality. While our efforts to come across with another plan alternative were based on the need for certain improved areas, intersections, light timing, and most of all a logical traffic flow where possible, we wanted to participate with both a recognition of some problems, and a subsequent understanding that our homes and lives and communities are ours –not PennDOT’s. As things stand today, June 4, 2003, the current traffic on County Line causes my home to shake. For the most part this is harmless and can only be perceived by observing plant foliage flutter to the seismic beat, however, during heavy traffic, or when large trucks are speeding by, it can be felt. While this condition has been there over many years, and has been inconsequential overall, there are places where it has left its marks. What will happen when there are twice the number of lanes, and one of these will be about 14’ closer with more heavy trucks, perhaps passing one another? And, we are talking about a masonry home of sturdy construction, as is the case with many of the homes within the project area.

After the deed is done and the shade from trees no longer there is gone, I must figure on having to pay for installing central air conditioning and running it all season rather than opening widows to the noise and diesel fumes. There will be increased home and auto insurance costs as well, all at a time when many of us may have fixed incomes! How can an agent of the state assume so much about who we are and what is ours? One statement in the DEIS proclaims that people may begin moving away from our region because of traffic congestion. This is an odd statement to make, but it is part of the trickster’s twist found in this report. I have never thought of moving, or of not being able to stay in the home in which I have lived since 1951 – until now. I have consulted with more than one real estate firm, and so have some of my neighbors, many of whom are third generation residents. It is interesting to note that most of them do not live, as I do, directly on County Line. The enormity of the project, even as an idea, is taking a toll on us all. PennDOT is many things. It is made of hard working people who keep roads clear and maintain traffic patterns, and yes, they come up with ideas for new road projects and highways, or ways in which to improve ones that already exist. There are clerks and management people who register our cars and issue plates. There is much important work for this organization. But there is another side as well, a side that acts out a role as would despotic rulers.

What this proposal could do, and what thinking about the consequences does, is akin to the kind of aguish which must surely accompany the horrific moments in nations where amputations are inflicted on peoples who differ with the occupying army during civil conflagration. They are offered alternatives, a foot, or an arm, or both arms, short sleeves or long? PennDOT is cutting into our lives while ironically telling us to choose which method from ones offered only by them. PennDOT is an agency of the state of Pennsylvania, and as such it has been given, or has taken, the right to exact with single minded purpose a single ended plan for transportation which consists of nothing but roads, more and bigger roads to be exact. This very well could be in response to poor planning, or mistakes of the past, whatever the reason, the answer they have is not a solution anymore. It has not worked. If left intact, the only homeowners who may be safe from them would be those inside what are now considered developments, or possibly gated communities. Those of us unfortunate enough to be situated along or near state roads are reminded always of “right-of-way”, the merits of which can be debated elsewhere.

This privilege of the state is also a line drawn with public works in mind, not always roads. Whatever the state does with this ground, it can not consequently overlap into the lives of those before it to the degree that this project proposes. I have only touched on some aspects of the DEIS. I will leave drainage, light pollution, and community displacement to others. Anyone examining this proposal will find that, as is the case above with mobility vs. property and community rights, or the immobile aspect of real estate, there is now a second dichotomy. Here, in our own communities of Huntingdon Valley, the Southamptons and those areas of Philadelphia included in the project, we will have to live with the ideology which PennDOT will enforce with massive earthworks and controlling media like sound walls. The communities we want will be environmentally spoiled in a process designed to make way for those developing outside settlements who feel deprived of more rapid access. I see this as being partially driven along economic lines as well as social engineering at its worst, driving the value of our lives and properties down. Region vs. region will be the end result. And is it not ironic that PennDOT will have set this in motion with a bogus goal of tying them together with a project cost of one hundred million dollars or possibly more? This is nothing more than an attempt to transfer and transfigure environmental dilemma from one place to another.

The demand for environmental justice is now. The state of Pennsylvania must start doing things differently. There must be recognition of the rights of communities and property owners. And PennDOT needs a top-level reorganization and a connection to responsible government that listens to the people with environmental justice for all as a major feature. PennDOT may see me as a dramatist in my own right. My reply would be that I am merely an observer, a forced witness to their project plan. While I do have a stake in what happens, I am as moved for others as I am for myself. Picture Huntingdon Pike with blacktop spread over the trees. Imagine the backs of houses there, blocked from a view of anything other than looming walls. County Line would be much the same, minus one wall.

I have used analogies of tyrants and invading armies because that is how this project has presented itself. When I speak of the toll exacted on us because of this situation, I mean to say it is absolutely like that of confronting any terrorist organization would be, especially one that is overt and appearing to be state sanctioned. As with many who have tried to lord over others with powers of devastation, they have presented their social plan as an urgent, absolute need, in the form a big book. The Woodhaven Road Project should be dumped. Some form of the “Community Friendly Plan” as presented by the TCC should be adopted; otherwise, we will have to go on understanding this project as an attack on our property and communities, and an assault on our persons. Without this acceptance of an alternative, PennDOT will simply have to get out of the road.

Section 2
Prepared by James L.O'Neill
Spokesperson for the Tri-County Coalition, Inc.

After an in-depth review of the May 2003 Draft Environmental Impact Study, it is evident that this project is fundamentally flawed. This document establishes that there is no basis for the Project Needs as currently defined for the Woodhaven Road Project relative to the current build alternatives offered and the level of collateral damage that will result from PENNDOT’s invalidated and unneeded proposed actions in the Project Area. According to the DEIS, there will be negligible negative impacts relative to the studied environmental elements: air and noise pollution, soil contamination, water pollution, floodplains, historic structures, wildlife, wetlands and forested acreage.

We request the DEIS acknowledge that any of the current build alternatives will have devastating impact on our communities.

We request that appropriate additional studies be conducted, analyzed and the findings are properly disclosed to all stakeholders in the project area.

We request that an independent consultant conduct these studies, as the decades long working relationship under contract between PENNDOT and McCormick Taylor and Associates may impede proper resolution for this project.

We request that the Federal Highway Administration’s Fiscal Year 2003 Performance Plans for Environmental Stewardship and Streamlining are upheld as stated on page 10: “The FHWA is committed to ensuring that highway improvement projects are delivered that preserve and enhance communities and protect the natural environment. Transportation plans and operations must address community concerns and the social impacts of transportation facilities.” (Refer to section labeled “Referenced Documents”)

We request that all employees of PENNDOT, all companies and all agencies they partner with regarding this project, from this point forward, work in the true spirit of cooperation with the Tri-County Coalition. This request was prompted by a disturbing hardcopy of an e-mail found in the Public Involvement technical files. PENNDOT forwarded their own comment regarding a resident’s objections via email to McCormick Taylor and Associates, Inc. The words of the comment “Let the countdown begin.” raise serious questions regarding PENNDOT’s and MTA’s capacity to help bring this project to a fair resolution. (Refer to section labeled “Reference Documents”.) Our first encounter with U.S. Corp of Army Engineer’s employee, Ms. Jacqueline Winkler, on June 26, 2003 was off-putting. As we were introduced by Tim O’Brien of PENNDOT, Ms. Winkler’s greeting was: “Oh, you’re the enemy…”

We request that PENNDOT begin to work along with the impacted communities to achieve an acceptable solution for the successful resolution of this legacy project.

The Draft Environmental Impact Statement /Section 404 Evaluation

is Submitted pursuant to 42 U.S.C. 4332 (2) (C)

by the Pennsylvania Department of Transportation: Federal Highway Administration and the Pennsylvania Department of Transportation and Cooperating Agencies: US Army Corp of Engineers, US Environmental Protection Agency
and the Pennsylvania Department of Environmental Protection

THE ABOVE CODE STATES: Sec. 4332. - Cooperation of agencies; reports; availability of information; recommendations; international and national coordination of efforts

2) All agencies of the Federal Government shall:

(C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on

(i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.

Relative to the above code:

Q1- PENNDOT please explain letter iii – Relative to your five proposals, what is: the alternative to your proposed action documented?

Q2- PENNDOT please explain letter iv – Relative to your five proposals, what is: the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity documented?

Q3 - PENNDOT please explain letter v – Relative to your five proposals, what is: any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented documented?

Q6 - PENNDOT please confirm, if the answer to question 5 is yes, then a new expressway terminus was created and extended west + - 2 miles up to the Lower Moreland Township/Montgomery County border instead of remaining in the Somerton section of Philadelphia?

Therefore, if either of these 2 current build alternatives, (referenced in question 5 are constructed) – it is accurate to say the new expressway extension will now end at the entrance to Huntingdon Valley in Lower Moreland Township as a result of this road construction? It will bring I-95 traffic into this community, similar to Evans Street - which brings I-95 traffic to Somerton/Philadelphia on Byberry Road.

ES – ii
Per the statement under figure ES-2: “This project would create a facility that would provide a transition between the six-lane limited-access Woodhaven Road/PA 63 Expressway and the free-access local roadways to which it would be connected. As part of the proposed improvements, the routing of PA 63 would be re-examined.”

Q7– PENNDOT please answer, if the above statement could be paraphrased as follows: “This project would construct a new expressway extension FROM Evans Street, the current expressway terminus of the Woodhaven Expressway in Somerton/Philadelphia; TO Byberry Road and Philmont Avenue, the new expressway terminus in Lower Moreland Township/Montgomery County, and all vehicles, including tractor trailer trucks when exiting the expressway will initially feed onto the local neighborhood streets in Huntingdon Valley/Lower Moreland through Westwood section of Somerton/Philadelphia”?

Q8 - PENNDOT please explain, how the new expressway terminus will be connected to the free-access local roadways since it is not connecting to any particular highway?

Q9 - PENNDOT please explain, what is particular proposed actions you are referring to according to the statement: – “As part of the proposed improvements, the routing of PA 63 will be re-examined”?

Q10 - PENNDOT please identify, the Traffic Study, the date it was conducted and what page relevant data can be located which should have provided the basis for the initial examination of the routing of PA 63 if the routing of PA 63 is to be re-examined; in addition to information regarding when the routing of PA 63 will be re-examined?

Q11- PENNDOT please explain what the projected impacts of the rerouting of PA 63 could be if it is completed without the Woodhaven Expressway Project ever being completed

Q12- PENNDOT please explain what the projected impacts of the rerouting of PA 63 could be if it is completed with the Woodhaven Expressway Project, regardless of whether the Woodhaven Expressway Project is completed before, after or during the rerouting of PA 63?

Q13- PENNDOT please explain why diagrams and/or specifications for the rerouting of PA 63 were not documented in the DEIS as well as mention of the studies regarding the potential impacts from the rerouting of PA 63?
Q14 a, b, c, d, e, f and g - PENNDOT please confirm:

a) What would the length be (in miles) of a rerouted PA 63?
b) Where would it originate?
c) Where would it terminate?
d) How many townships in Montgomery County or Bucks County will be physically impacted?
e) What would be the closest existing turnpike exit, or entrance?
f) Where would any future turnpike exits or entrances be possibly located?
g) How do local township officials feel about this rerouting?

Therefore, the DEIS, over 350 pages long, recognizes all of the potential negative impacts of the current build alternatives as presented by PENNDOT, yet, the rerouting of PA 63, which will involve a highly residential area, and could have a series of potential negative impact of it’s own, has only been mentioned in one sentence on page ES-ii. It should be said that the full scope of this project has not been properly disclosed and the impacts remain to be seen.

After reading the DEIS, it can be stated that the western intersection of the proposed new section of County Line Road (from Bustleton Avenue to Philmont Avenue) exists inside the current Project Area. The eastern intersection of the proposed new section of County Line Road is non-existent and is not in the Project Area per the Project Area Map.

Q15- PENNDOT when is the estimated completion date for the above mentioned construction of County Line Road between Bustleton Avenue and Philmont Avenue?

Q16- PENNDOT please explain, if it is logical to conclude that this new section of County Line road will be value-added to the roadway network, as there must be a valid reason to construct this new section of roadway and explain this roadway will be an asset?

Q17- PENNDOT please explain, how the ‘turning movements’ where derived in the June 2002 DVRPC Traffic Study - as indicated on page B-4, figure B-2 and page B-5, figure B-3 re: the intersection of Bustleton Avenue and County Line Road. In particular, the vehicles that are documented as driving eastbound on a non-existent section of County Line Road between Bustleton Avenue and Philmont Avenue?

Q18- PENNDOT please explain, if it is logical to conclude, the new intersection of County Line Road and Philmont Avenue is an integral component of this new section of County Line Road as it relates to improving traffic flow and distribution at adjacent existing intersections in the Project Area?

Q19- PENNDOT please explain, if it is logical to conclude, the new intersection of County Line Road and Philmont Avenue is an integral component of this new section of County Line Road as it relates to alleviating vehicular congestion and delay at adjacent existing intersections in the Project Area?

Q20 – PENNDOT please explain, if the construction of this new intersection, coupled with the connection of County Line Road to Bustleton Avenue on the east side of Bustleton Avenue, could improve traffic flow or distribution in the ‘Woodhaven Road Project Area’ even though this particular intersection in not inside the boundaries of the subject Project Area?

Q21 – PENNDOT please explain, if the construction of this new intersection, coupled with the connection of County Line Road to Bustleton Avenue on the east side of Bustleton Avenue, could improve traffic flow or distribution in the ‘Woodhaven Road Project Area’ even though this particular intersection in not inside the boundaries of the subject Project Area?

Q22- PENNDOT please explain, why ‘traffic turning movement counts’ and other Traffic Studies, were not conducted for this new intersection of County Line Road and Philmont Avenue? Is it because the intersection does not technically reside within the boundaries of the Project Area?

Q23 - PENNDOT please confirm, what is the driving distance (in miles) on Philmont Avenue between the new intersection of County Line Road and Philmont Avenue, and the existing intersection of Philmont Avenue and Bustleton Avenue?

Q24 – PENNDOT please explain, how the existence of this new intersection could improve traffic flow and/or distribution in the ‘Project Area’ even though this particular intersection in not technically inside the boundaries of the Project Area?

Q25 - a, b, c, and d- PENNDOT please explain, in your best estimate, what the new LOS ratings would be for the intersections of Bustleton Avenue and County Line Road AND Bustleon Avenue and Philmont for:

a). Woodhaven Expressway Alternative
b). Byberry Road Upgrade
c). Bustleton Avenue Alternative Mod.
d). Bustleton Avenue Alternative

Another understated and unstudied element, this new section of County Line Road could improve the traffic conditions in this part of the roadway network and could as a result, improve traffic conditions in parts of the Project Area. Besides the importance of County Line Road and Bustleton Avenue, Philmont Avenue as stated on page 2-20 of the DEIS: 2.4 Transportation Network: “Philmont Avenue is also an important north-south route serving the community.” It would have been beneficial to learn how the study of the key section of roadway could have improved the traffic conditions in this area, and it is unfortunate that it’s potential merit was not studied in the June 2002 Traffic Study. Our federal agencies need to understand that cumulatively, smaller improvements across the Project Area, if studied appropriately, could reduce the perceived need to have such invasive road widenings.

Q27- PENNDOT if your answer is no, please provide data to support that claim.

Q28 - PENNDOT if your answer is yes, please provide data to indicate what the relative impact will be on the local roadway network- since there would be less vehicle miles driven since vehicles will not need to travel Byberry Road to access I-95 at peak hours?

Q29 - PENNDOT is it logical to conclude that the re-introduction of mass transportation (SEPTA regional rail) adjacent to the Project Area will attract “X” % of residents from INSIDE the Project Area?

Q30 - PENNDOT if your answer is no, please provide data to support that claim.

Q31 - PENNDOT if your answer is yes, please provide data to indicate what the relative impact will be on the local roadway network- since there would be less vehicle miles driven since vehicles will not need to travel Byberry Road to access I-95 at peak hours?

Q32 - PENNDOT please explain why the restoration of SEPTA’s Regional Rail Fox Chase/Newtown wasn’t studied in the June 2002 Traffic Study?

Q33 - PENNDOT could one of the reasons for SEPTA’s Fox Chase/Newtown Regional Rail Line not being studied be due to the fact that it is not physically located inside the boundaries of the Project Area?

Q34 - PENNDOT do you realize that two of the train stops for the Fox Chase/Newtown Regional Rail Line include Bryn Athyn and Huntingdon Valley, are the train stops for the residents of Bryn Athyn Borough and Lower Moreland Township – communities in and around the Project Area and they would probably use this restored rail line?

Again, a transportation improvement such as this Fox Chase/Newtown Regional Rail Line, is overlooked and is not considered valuable enough as a source of traffic relief on it’s own. What judge and jury decided that a collection of smaller scale improvements could not be studied in conjunction with highway improvements? It is logical to say that small positive impacts from various improvements could add up to a significant alleviation of traffic woes. With the re-introduction of SEPTA’s Fox Chase/Newtown Regional Rail Line, a new customer base from both the project and non-project areas would surface, which could reduce the amount of vehicles miles driven in the roadway network in the Project Area. It would have been beneficial to see how the re-introduction of the this rail line could have improved the traffic conditions in this area, and it is unfortunate that it’s potential merit was not studied in the June 2002 Traffic Study. Our federal agencies need to understand that cumulatively, smaller improvements across the Project Area, if studied appropriately, could reduce the perceived need to have such invasive road widenings.

Q35 – PENNDOT please explain why the Rt. 1 Build Alternative never made it to the ‘detailed analysis’ stage of the evaluation process?

Q36 – PENNDOT what was the date that you received the Tri-County Coalition’s Rt. 1 Build Alternative?

Q37 – PENNDOT what was the date that the DEIS content was approved to go to print?

Q39 – PENNDOT when did you receive the Tri-County Coalition’s Addendum to the Rt. 1 Build Alternative?

The direction of vehicular travel that the Rt. 1 Build Alternative would be redirecting from Rt. 1 South would be for vehicles traveling eastbound on the Woodhaven Road/PA 63, not westbound.

People who were not familiar with the details of the Rt. 1 Build Alternative, and were reading about it for the first time in the DEIS, were given inaccurate information. It is a disservice to the Rt. 1 Build Alternative. It is a disservice to the general public since they were presented inaccurate information on which to base their thoughts to prepare their testimony.

Q40 - PENNDOT what is the probability that a percentage of people were reading the specifications for the Rt. 1 Build Alternative in the DEIS for the first time?

Q41- PENNDOT please explain how you plan to properly communicate the above-mentioned error which flawed the concept of the Rt. 1 Build Alternative in the DEIS document.

The Rt. 1 Build Alternative is a series of strategic intersection improvements in the Project Area.

PENNDOT, the following statement was taken from the your website, www.woodhavenroad.com regarding intersections:

“While traffic volumes provide a measure of activity on a roadway network, it is also important to evaluate how well a network can accommodate traffic by comparing peak hour traffic volumes with available roadway capacity. Intersections are usually the most critical points in a roadway network. It is at intersections that conflict exists between through, crossing and turning traffic, and where vehicle congestion and delay is most likely to occur. Factors that affect average vehicle delays at both signalized and non-signalized intersections include:

a) The width of the approach;
b) The number of lanes;
c) The available time a signal remains green;
d) Turning volumes;
e) The percentage of trucks using the intersection; and
f) The coordination of traffic signals

Q42 - PENNDOT, please provide data that supports your claim that the Rt. 1 Build Alternative, a series of intersection improvements, would not reduce vehicular congestion and delay in the study area based on the statement above reinforcing the importance of intersections in a roadway network?

Q43 - PENNDOT please explain why the Rt. 1 Build Alternative and the No-Build Alternative, comparatively speaking, are BOTH described as alternatives that do not meet project needs as they relate to ‘reducing vehicular congestion and delay’. The Rt. 1 makes improvements. The No-Build does not and is described on page ES-ix: “Although the No Build alternative does not meet project needs, it provides a baseline reference for comparison to the other alternatives that are being studied in detail”?

Q44 – PENNDOT is it accurate to state the No-Build Alternative was not used as a baseline reference for comparison to the Rt. 1 Build Alternative (per the No-Build Alternative paragraph on page ES-ix)?

Q45 - PENNDOT, please explain if the Rt. 1 Build Alternative would have been given a “Detailed Analysis” (instead of just a preliminary analysis per FigureES-3); would the No-Build Alternative have been used as a baseline reference for comparison to the Rt. 1 Build Alternative?

Q46 - PENNDOT please explain the possibility of the Rt. 1 Build Alternative being able to address the Project Needs in a greater capacity than the No-Build Alternative?

Q47- PENNDOT, please provide the name of the person/persons who analyzed the Rt. 1 Build Alternative?

The second bulleted statement (in the DEIS) for a reason for dismissal says: “Would not improve traffic and pedestrian safety.”

a) The Rt. 1 Build Alternative does not permit the introduction of additional tractor-trailer truck traffic into the Project Area.
b) The Rt. 1 Build Alternative does not raise speed limits in the Project Area.
c) The Rt. 1 Build Alternative suggests utilizing the right- of -way for bike paths that would be removed from Byberry Road.
d) The Rt. 1 Build Alternative will add green turn arrows to intersections as needed, thus minimizing the amount of vehicles queuing in the middle of a given intersection.

Q48 - PENNDOT please provide data that will support your claim that the Rt. 1 Build Alternative would not improve traffic and pedestrian safety IF the Rt. 1 Build Alternative was built to specification?

Q49 - PENNDOT please explain, if it is logical to conclude that the Rt. 1 Build Alternative could improve traffic and pedestrian safety better than the No-Build Alternative?

Again, another concept for alleviating traffic conditions, without ravaging the Project Area; the Rt. 1 Build Alternative, created by a citizen’s group, was overlooked and not considered valuable enough to be worthy of detailed analysis – and dismissed all together. This alternative is a series of key intersection improvements that could improve traffic conditions in the Project Area. Our federal agencies need to understand that cumulatively, a combination of smaller, less invasive improvements across the Project Area could reduce the perceived demand for such invasive road widenings.

a) evaluating expanding parking lot capacity at SEPTA R3 regional train stations inside the Project Area
b) constructing a new mass transit line from center city Philadelphia to NE Philadelphia outside the Project Area

Q50- PENNDOT what was the consensus when the studies determined that project needs would not be met through one particular transit alternative and was therefore dismissed?

Q51- PENNDOT how could one particular transit alternative be expected to address all of the Project Needs?

Q52- PENNDOT please explain, is one of the strategies to address the Project Need to reduce vehicular congestion and delay -achieved by reducing the traffic volumes on Byberry Road, especially between Bustleton Avenue and Evans Street?

Q53- PENNDOT please explain, how could any mass transit line located on Rt.1 be expected to satisfy this Project Need in particular, since Rt. 1 is east of Byberry Road, and motorists who would utilize this mass transit line, would travel east on the heavily congested portion of Byberry Road to access the new NE Phila. Rapid-Transit Line?

Q54- PENNDOT, what was the cost to conduct this particular study?

Q55– PENNDOT please confirm if any mass transportation improvements/alternatives and other various strategies were ever considered to be studied in the June 2002 Traffic Study in conjunction with each of the current build alternatives (since they were dismissed as stand alone alternatives)?

Q56– PENNDOT if your answer is yes, what were the key findings of the study that led to it’s dismissal?

Q57- PENNDOT if your answer is no, why wasn’t the concept of mass transportation improvements/alternatives and other various strategies evaluated in the Traffic Study BEFORE it was decided that it did not warrant any study?

Q58 – PENNDOT, please explain why various studies are implemented to explore concepts that would probably not satisfy project needs; BUT studies are not implemented that include a combined range of ideas, alternatives & improvements, that could cumulatively result in beginning to satisfy Project Needs, and lay the ground work to explore in greater detail what was most successful?

Q59 - PENNDOT please comment on my statement: “Combinations of Road Transportation Improvements, Congestion Management Strategies and Transit Alternatives could be expected to alleviate congestion to varying degrees BUT should not be expected to totally and completely relieve traffic congestion.”

According to this section, the two separate transit alternatives were dismissed since they would not relieve congestion on Byberry Road as stated in the DEIS page ES-v: “Therefore, a major transit investment in this corridor would not relieve congestion on Byberry Road.” In contrast to the reoccurring references to Byberry Road, page ES-ii documents the “Project Need” relating to congestion across a much broader area and states: “Vehicular Congestion and Delay Impeded Travel in the Project Area… Transportation improvements must reduce congestion and delay in the Project Area.”

Q60- PENNDOT please explain why Byberry Road in Philadelphia was a determining factor on whether an alternative was deemed feasible or whether an alternative was dismissed?

Q61- PENNDOT please explain, what was the purpose of evaluating the construction of additional parking spaces at various SEPTA R3 regional rail station parking lots throughout the project area?

Q62 – PENNDOT please explain the methodology used to determine what the proper quantity of additional parking spaces needed to be created to achieve the purpose of the study?

Q63- PENNDOT please explain, what the benefit of constructing additional parking spaces could be as it relates to the project need to “reduce vehicle congestion and delay in the project area”?

Q64- PENNDOT please explain the process used to determine how the most efficient use of funds relative to satisfaction of Project Need was derived?

Q65 – PENNDOT please explain what is meant by the statement on page 3-57: “Other commitments of the Woodhaven Road Project will be pursued as separately programmed improvements”? Separately from what?

Q66- PENNDOT please explain why only one out of 2 train stations are going to be improved in the actual Project Area; the Forest Hill Station on Byberry Road and not Somerton Station at Bustleton Avenue and Philmont Avenue, as stated on page 3-57?

Q67- PENNDOT is it logical to conclude, that expanded parking lot capacity for the 2 train stations located inside the Project Area for SEPTA R3’s could increase the amount of mass transit users and therefore reduce the amount of vehicle miles driven since a percentage of those mass transit users were motorists that would have needed to travel Byberry Road to access I-95 during peak hours?

Q68 - PENNDOT please explain why you are not planning to improve the 3 other stations that are very close to the Project Area’s border line, that being the Trevose Station, Philmont Station and Bethayres Station?

Q69 - PENNDOT is it logical to conclude, that expanded parking lot capacity for the 3 train stations located outside the Project Area for SEPTA R3’s could increase the amount of mass transit users and therefore reduce the amount of vehicle miles driven since a percentage of those mass transit users were motorists that would have needed to travel Byberry Road to access I-95 during peak hours?

Q70 – PENNDOT please explain, if the additional parking spaces were going to be accomplished by constructing additional parking levels over the existing parking lot, and if so how may levels?

Q71- PENNDOT, if your answer is no, how were these additional parking spaces going to be created and why wasn’t the concept of above grade parking levels addressed?

Q72- PENNDOT please confirm, do Philadelphia zoning regulations permit parking levels to be constructed?

Q73- PENNDOT please confirm, if zoning played a role in the dismissal of this improvement?

Q74 – PENNDOT, please explain the lack of vision for not wanting to considering the potential merits of expanded parking capacity with other combinations of transportation improvements that could be studied in conjunction with the current build alternatives?

Again another basic transportation improvement, expanded parking capacity at train stations, was dismissed. Originally studied as a stand alone transit improvement, it was dismissed from further study because expanded parking lots alone would not reduce congestion and delay in the Project Area. That is not a surprise. Because of that determination, the project scope was cut in half- from two train station parking lots expansions, to only one train station parking lot expansion – with no intention on expanding the other two parking lots less than 1 mile away from the Project Area! Common sense tells us if parking lot capacity was expanded at various locations, more motorists would utilize mass transportation. In particular, the R3 line which has stops at 3 locations in center city Philadelphia, therefore, Byberry Road would have less vehicle miles driven on it since these vehicles would be now parked at train stations throughout the Project Area and not traveling to I-95. Our federal agencies need to realize that cumulatively, a combination of smaller, less invasive improvements across the Project Area could reduce the perceived need for such invasive road widenings.

Q75- PENNDOT, please explain how that particular location for the park- and- pool was determined?

Q76- PENNDOT, please explain why you would construct this park- and -pool near one of the intersections that is located between the intersections indicated below, as stated on page 7 in the June 2002 Traffic Study: “These vehicles exit the expressway then proceed to Byberry Road where the heaviest traveled portions are between Bustleton Avenue and Evans Street, ranging from 26,400 to 32,000 vehicles per day?”

Q77– PENNDOT, please comment on the fact that alternatives and transit improvements were dismissed because they would not reduce vehicle congestion and delay on Byberry Road; and now you are planning to build a parking lot that will attract additional vehicles into the most congested portion of the Project Area?

Q78A- PENNDOT, is it logical to conclude, that if a park-and-pool was constructed west of Bustleton Avenue and Byberry Road, instead of east as planned, less vehicles would be traveling on Byberry Road between Bustleton Avenue and Evans Street; and the construction of a park-and-pool on the west side would prevent traffic from traveling on the portion of Byberry Road as mentioned on page 7 of the June 2002 Traffic Study?

Q78B- PENNDOT, please explain how the location for the park and pool near Worthington Road was determined when the list of Possible Park and Pool locations (Refer to section called “Referenced Documents”) has many other options that could have been considered?

Q79- PENNDOT, please explain what exactly was meant by the “Meeting Minutes prepared by McCormick Taylor and Associates, Inc. dated June 16, 1997” and documented on page 2 in the list of questions asked and addresses: “How many parking spaced will be there be at the proposed park and pool lot?” under the question, there was a notation in parentheses: This lot could “kill the project”? (Refer to section called “Referenced Documents”)

It is disturbing to learn how this project has unfolded; as more information is read, the more self serving this project becomes. Think about this simple fact: The most congested portion of the Project Area, will have a magnet that attracts more vehicles built right inside it. All traffic improvement should be sensitive toward the highly regarded and repeatedly proclaimed Project Needs. Dismissed build alternatives, dismissed transit improvements, down-sized improvements, improvements not studied in the Traffic Study in conjunction with the current build alternatives, as discussed in this document, in addition to this so-called improvement - create an irony, easy to understand but not easy to accept.

ES- xiii Table ES-1 Summary of Alternatives and Project Needs: Does the Alternative Satisfy the Project Needs?

Q80 - PENNDOT please explain the role of the “Evaluation of Project Need” report and what next steps in the critical path of a project timeline are contingent upon having a completed “Evaluation of Project Need” report?

Q81 - PENNDOT please confirm if the DEIS page ES-xviii, section H, Technical Support Data, is accurate in listing the “Evaluation of Project Need” report being dated June 1992?

Q82 - PENNDOT, please explain what is meant by the statement on the preface page of the June 1992 Evaluation of Project Need that reads as follows: “The information provided in this report serves to document the need for this project”?

Q83 - PENNDOT, is it accurate to state that this report is over a decade old?

Q84 - PENNDOT, why would you be referring to a report from 1992, conducted approx. only 3 years after the March 1989 Traffic Study which documents traffic forecasts for 1995, that have yet to materialize in 2002 - as you continue to work on the Woodhaven Road Project in 2003?

Q85 - PENNDOT, please confirm if is accurate to state that in 1997, five years after the June 1992 Evaluation of Project Need report, the Project Area was expanded into Bucks and Montgomery County, the extent of new road construction and existing road widenings increased since the Design Year was pushed out to the year 2026?

Q86 - PENNDOT, please explain what is meant on page 52 in the June 1992 Evaluation of Project Need report, in the sixth bulleted statement that reads as follows: “Improve the quality of life for local residents”? What about the quality of life for regional residents that are going to be shafted by the expressway you now want to build to Lower Moreland’s doorstep?

On page ES-ii, the first bulleted statement says: “The Byberry Road Bridge Over the CSX – Trenton Line Tracks is Structurally Deficient … A structurally sound bridge over the CSX – Trenton Line tracks must be provided, even in the No Build Alternative.”

While… the third bulleted statement on the same page says: “Traffic and Pedestrian Safety … Transportation improvements improve conditions that affect traffic and pedestrian safety.”

These statements appear to be in direct conflict with each other as they are planned to both occur in the entire Project Area simultaneously.

On page 1-4, based on the meetings held in 1983, it is reported the public voiced strong objections to the bridge and only supported replacing the bridge after the completion of the Woodhaven Expressway Project. To address the concerns of the Somerton Civic Association, the PUC ordered that the temporary bridge be posted with a 3-ton weight limit which restricted all but passenger vehicles from crossing it.

Q87 - PENNDOT, please explain what is meant by temporary structure? Does it mean that it can be retrofitted? If so, what it the negative impact of driving across a retrofitable bridge as opposed to one that is permanent? (Since all bridges are inspected every 24 months?)

Q88 - PENNDOT, please explain the definition of ‘structurally deficient?

According to the June 2003 Study conducted by The Road Information Program (TRIP) entitled “Showing Their Age: Pennsylvania’s Deficient Bridges”, in the Executive Summary on page 1, the first bulleted statement reads: “25% of the state’s bridges are structurally deficient, showing significant deterioration to decks and other major components. The classification of a bridge as ‘structurally deficient’ does not mean a bridge is unsafe. Pennsylvania’s bride safety inspection program, which inspects bridge on a 24-month cycle, ensures each bridge is safe for vehicles weighing less than the posted weight limit.”

Q89 - PENNDOT, please explain why in all occurrences of the words ‘structurally deficient’ in the DEIS, the Traffic Study and the website, there has been no clarification that the bridge IS SAFE for appropriately weighted vehicles?

Q90 - PENNDOT, please explain why ALL alternatives, even the No-Build alternative will include the reconstruction of the CSX train bridge?

Q91 - PENNDOT please explain why the subject of the impact of the re-introduction of tractor trailer truck traffic was not explained in the DEIS?

According to the TRIP page 3, the seventh bulleted statement reads: “88 percent of the $297 billion worth of commodities delivered annually from sites in Pennsylvania are transported on the state’s bridges and highways.”

Q92 - PENNDOT what negative impact has the weight restrictions on the CSX bridge to prohibit trucks had on the delivery percentage of commodities being transported by tractor trailer trucks in Pennsylvania?

Q93 A - PENNDOT where you instrumental in coordinating meetings or communicating in any way on behalf of the Somerton Civic Association and the PUC, since the PUC listened to the concerns of a particular group of people regarding the bridge? Moving forward will you assist the communities in working with the PUC again? Build alternatives will be more palatable with the knowledge there would be no tractor trailer truck traffic on new or widened roads?

Q93 B - PENNDOT please explain the reason why Somerton Civic Association is agreeable to the bridge replacement – but not until the project is completed? Will trucks have access to Byberry Road in their neighborhood between Trina Drive and Bustleton Avenue?

Q93 C - PENNDOT please confirm if Byberry Road is planned to be realigned in all build scenarios to prevent tractor trailer trucks from accessing Byberry Road between Bustleton Avenue and the bridge itself and that is why Somerton Civic Association is agreeable to the bridge replacement?

Q94 - PENNDOT please confirm what type, the names, and the various toxicity levels of the of hazardous materials that these tractor trailer trucks be permitted to transport?

Q95 - PENNDOT please explain what route you forecast the truck drivers will take as they approach the stone train bridge near Mason’s Mill Road, where there is a height clearance of only 9’-7”? Is there a remote possibility that they will use secondary streets, a condition that occurs in Somerton – because Lower Moreland streets were not intended to serve this increased level of traffic – especially truck traffic.

As stated in the “June 1992 Evaluation of Project Need” report as prepared by McCormick Taylor & Associates, Inc. on page 7, it is stated: “The weight restriction on the bridge has provided some minimal relief from the truck traffic which previously used the bridge; replacement of the bridge would re-introduce this truck traffic onto Byberry Road.”

Q96 - PENNDOT relative to the statement above in the “June 1992 Evaluation of Project Need” report, please provide the page numbers from the “April 1989 Traffic Study” that forecasts addresses the existence of tractor trailer truck traffic in the Project Area?

Q97- PENNDOT please explain the methodology used to determine how the average daily traffic volumes were forecasted to factor in the increased tractor trailer truck traffic crossing the CSX bridge into the Project Area?

Q98 - PENNDOT please explain how this tractor trailer truck traffic resulting from the “Project Need: to replace the CSX train bridge”, will create the proper conditions for another “Project Need: to improve pedestrian and vehicular safety” to be possible since these trucks will initially be routed onto the new expressway for a short distance and they will then have to exit from this expressway onto Byberry Road and Philmont Avenue into highly residential areas as it relates to the safety well being of the groups of people below? How will your transportation improvements affect pedestrian and vehicular safety?

a) For motorists? b) For pedestrians? c) For Bicyclists? d) For Property Owners? e) For Renters?

Unfortunately, massive road construction and road widenings are not the only unsavory element to this project; unrestricted tractor trailer truck traffic will become a harsh reality – even though it is attempted to be minimized by McCormick Taylor & Associates by stating only minimal relief is being experienced from the current 3-ton weight restriction! (The limit prohibits 18- wheelers from accessing Byberry Road!) For the convenience of the trucking industry and at the expense of the Quality of Life for many residents in the Project Area; tractor trailer truck traffic will be given full access to our communities. Tractor trailer trucks will no longer be required to use the PA 63 Detour (in place for nearly 25 years and only 1.24 miles south of Byberry Road) to Red Lion Road. Fueled by PENNDOT’s passion to build the expressway – it will become convenient for 18 - wheelers to travel to and through our communities, on this new high capacity expressway.

Q100 - PENNDOT please identify what the circumstances were that led to Byberry Road’s lanes being reduced in Philadelphia and what local civic leaders had knowledge of these modifications?

Q101 - PENNDOT please explain if it is logical to conclude that if Byberry Road’s current limited road capacity was restored to a higher capacity road, that there could be a reduction in vehicular congestion and delay?

Q102 - PENNDOT is it accurate to state that nearly all references to problem areas for congestion and delay are referring to Byberry Road between Evans Street and Bustleton Avenue?

Q103 - PENNDOT is it accurate to state that the most congested portion of the Project Area is Byberry Road between Evans Street and Bustleton Avenue?

After reviewing Table ES –1 and studying the extent of the new road construction in the four build alternatives, the methodology PENNDOT used to promote certain build alternatives unfolds. Per PENNDOT, not constructing the expressway in the Right of Way between Bustleton Avenue and Philmont Avenue would not separate regional and local traffic on that 0.6 mile portion of Byberry Road, would not improve ‘traffic collection and distribution’ AND not would improve ‘pedestrian and vehicular safety’. This was the reason why the word ‘partially’ was inserted into four cells in this table. This word which is being used as a rating, is meant to represent a ‘flaw’ in the 2 build alternatives. (Refer to chart)

This statement sums it up: ”The new alignment would remove regional traffic from Byberry Road, thus improving safety for vehicles and pedestrians, and traffic collection and distribution". Since the Bustleton Avenue Alternative, which has the expressway built to Bustleon Avenue (Partial Expressway) and not Philmont Avenue (Full Expresway), and only receives a grade of ‘partially’ on 2 project needs, supports the statement that only building the expressway to Bustleton Avenue only partially satisfies the Project Needs for:

a) Traffic Collection and Distribution
b) Pedestrian and Vehicular Safety

Using the concept of a ‘mix of regional and local traffic’ for only a 0.6 mile portion of Byberry Road has resulted in 50% of the Project Needs for 50% of the current build alternatives to appear to be flawed by being rated as only partially satisfying Project Needs. This is a very weak reason to tarnish the viability (by giving a lower rating) of the remaining, much less invasive build alternatives.

Q104 - PENNDOT please explain, why on page 2 of the June 2002 DVRPC Traffic Study states: “Since all of the alternatives are expected to relieve congestion and reduce delays on Byberry Road, the choice becomes one more of a preference that a necessity.”

Q105 - PENNDOT is it logical to compare Table ES-1 to a ‘report card’ for the current PENNDOT build alternatives; since the words: ’fully’ and ‘partially’ were used to grade each alternative for it’s merits in each of its four classes of Project Need.”?

Q106 - PENNDOT please explain where it is stated as a ‘Project Need’ that the traffic that is being collected and distributed on Byberry Road CANNOT be a both mix of local traffic and regional traffic and must be separated from each other?

Q107 - PENNDOT please explain if it is not stated as a ‘need’ that the traffic must be separated, then on what is the BASIS that traffic must be separated from each other?

Q108 - PENNDOT please explain, what is the definition of local traffic and regional traffic?

Q109 - PENNDOT please explain, what are the negative impacts of having regional traffic drive next to local traffic on the short 0.6 mile portion of Byberry Road between Bustleton and Philmont? (This is the portion of Byberry Road that would have a mix of traffic in the event that the expressway was not built between Bustleton and Philmont through the Somerton’s Westwood Community.)

Q110 - PENNDOT please explain, how you can define “territory” relative to the range (in miles) a motorist may drive within his/her (local) territory BEFORE he/she leaves his/her (local) territory and enters into a different community’s (regional) territory?

Q111 – PENNDOT do you agree that whether classified as regional traffic OR classified as local traffic; that the concept of having a mix of this traffic was a factor that resulted in 2 out of 4 ‘Project Needs’ being charted on Table ES-1 as being ‘partially’ fulfilled?

Q112 - PENNDOT please explain the claim that Byberry Road will be used for local traffic only between Bustleton Avenue and Philmont Avenue as per this statement: “the new alignment would remove traffic from Byberry Road…” Since traffic studies forecast volumes of traffic based on forecasted employment, forecasted economic trends, forecasted population growth, to commit to use the word would – is indeed an assumption.

Q113 a, b, and c - PENNDOT please confirm if the possible trip destinations are feasible?

a. The route for the motorists who live in Philadelphia south of Bustleton Avenue and travel west on Byberry Road.
b. The route for the motorists who live in Bucks County north of Bustleton Avenue and travel west on Byberry Road.
c. The route for the motorists who live in Montgomery County and travel north or south on Bustleton Avenue.

Q114: a, b and c- PENNDOT please confirm the possibility that the motorists listed below will be able to engage in trip destinations on Byberry Road between Philmont Avenue and Bustleton Avenue?

a. The motorists who live in Philadelphia south of Bustleton Avenue that need to travel west on Byberry Road.
b. The motorists who live in Bucks County north of Bustleton Avenue that need to travel west on Byberry Road.
c. The motorists who live in Montgomery County and will need to travel north or south on Bustleton Avenue.

Q115 - PENNDOT, why does the June 2002 Traffic Study results make a mountain out of a molehill - by creating a false impression that a common traffic condition (regional and local traffic on the same road) a condition that will always exist at various times and locations with varying degrees, is truly detrimental to traffic collection and distribution? It can be deduced that the determining factor, in essence, is only a 0.6 miles portion of Byberry Road between Bustleton Avenue and Philmont Avenue. And why does PENNDOT follow that lead, and use these negligible impacts as a means to create a disparity between the alternatives? Can it be said that PENNDOT needed something like this to latch onto – and therefore result in our legislators and certain civic groups, looking to the build alternatives that include the full expressway as our savior to deliver us from all traffic woes? Surely anyone with a conscience would never opt to build a new expressway through a residential area of single family homes and deliver such irrevocable harm IN EXCHANGE FOR trying to keep some unknown amount of vehicles from a different neighborhood from driving on that 0.6 mile portion of Byberry Road?

Q116- PENNDOT please identify the Traffic Study and page numbers and explain the methodology used to determine how the DVRPC Traffic Studies evaluated the trip destinations for local and regional traffic, the average daily traffic volumes for local and regional traffic, and the traffic turning movement counts for local traffic and regional traffic which MUST analyze this split, provide the data and explain it’s results?

Q117- PENNDOT do you agree the claim of the negative impact of this ‘traffic mix’ played a pivotal role in the scoring of build alternatives which resulted in high scores for ‘fulfillment of project need’ for the most invasive of the current build alternatives?

Q118- PENNDOT do you concur that there are two sides to the traffic mix concept, with the first side being the impact that is briefly mentioned in the DEIS on page ES-x and ES-xii: “Due to the mix of regional and local traffic on Byberry Road west of Bustleton Avenue and the widening of Byberry Road, the need to improve traffic and pedestrian safety is only partially addressed” ?

Q119- PENNDOT on the other side of the traffic mix concept; have you considered the irony regarding the MAJOR negative impact that will be directed toward one community (Westwood, which is highly residential with single family homes) by trying to prevent the MINOR negative impact to another community (West Somerton, which is both commercial and residential – single family, twins and apartment buildings) AND what that impact would be to Westwood when you construct a new 4 or 2 lane above-grade expressway through the middle of their neighborhood in the ROW in exchange for not widening the existing Byberry Road?

Q121- PENNDOT, please explain why the limited capacity of the two-lane roadways in Lower Moreland would not be incompatible with volumes of traffic just as Somerton’s two-lane roadways are said to be incompatible?

Q122- PENNDOT are you aware that the residential properties on Byberry Road in Huntingdon Valley also have driveways perpendicular to Byberry Road just like the residential properties in Somerton?

Q123- PENNDOT are you aware that Lower Moreland is a highly residential area, with only 2 commercial properties on Byberry Road -one gas station and one flower shop?

Q124- PENNDOT please explain what are the zoning restrictions along Byberry Road in Lower Moreland?

Q125– PENNDOT, please confirm what the ratio of commercial properties to residential properties are along Byberry Road in Philadelphia?

Q126- PENNDOT please confirm if it is accurate to say that Byberry Road in Philadelphia has considerably more commercial businesses than Byberry Road does in Lower Moreland?

Q127- PENNDOT please explain why there are 2 lanes of ‘on-street parking’ on Byberry Road in Philadelphia?

Q128- PENNDOT please explain why there are no lanes of ‘on-street parking’ on Byberry Road in Lower Moreland?

Q129- PENNDOT please provide data that documents a consistent utilization of both ‘on-street parking’ lanes on Byberry Road in Philadelphia to justify the existence of these on-street parking lanes to justifiably remain on Byberry Road in Philadelphia?

Q130- PENNDOT please explain why there bicycle lanes on Byberry Road in Philadelphia?

Q131- PENNDOT please explain why there are no bicycle lanes on Byberry Road in Lower Moreland?

Q132- PENNDOT please explain why the bicycle lanes on Byberry Road in Philadelphia end at Philmont Avenue?

Q133- PENNDOT, where are the bicyclists traveling to and what happens to their trip when the bicycle lanes end at Philmont Avenue?

Q134- PENNDOT please provide data that documents a consistent utilization of both ‘bicycle’ lanes on Byberry Road in Philadelphia to justify the existence of these bicycle lanes so they may justifiably remain on Byberry Road in Philadelphia?

Q135- PENNDOT please explain if the on-street parking and bicycle lanes were removed from Byberry Road in Philadelphia, how many additional driving lanes could be created on Byberry Road without needing to condemn any property along Byberry Road?

Q136 –PENNDOT please explain what impact a higher- capacity Byberry Road in Philadelphia would have on the Project Needs?

Q137- PENNDOT, please explain why the character of Somertonian’s homes on Byberry Road are held in high regard (as stated on page 1-11: “This volume of traffic is not incompatible with the limited capacity of the two lane roadways but also the residential character of Byberry Road), while the sheer existence of Lower Morelanders’s homes on Byberry Road are totally ignored?

Q138- PENNDOT, please explain why the concerns consistenly expressed in the DEIS, focus on Somerton? For example, on page 1-8: “These roads are not intended to serve this increasing level of traffic”. Page 1-11: “This volume of traffic is not incompatible with the limited capacity of the two lane roadways but also the residential character of Byberry Road.” Page 1-4: “To address the needs of the Somerton Civic Association…” Page 1-5: “Within the Project Area, Byberry Road passes through a primarily residential neighborhood with a high pedestrian volume. Also an elementary school with sports fields is located on Byberry Road between Worthington and Bustleton.”

Q139- PENNDOT, please answer what the average price of a home purchased in Lower Moreland Township is, compared to the average price of a home purchased in Somerton?

The list below, taken from www.montcopa.org is a list of ASSESSED values of homes in Lower Moreland along Byberry Road in the Project Area. Assessed values are lower that actual resale value.Homes along a road are valued lower that homes not along a road.The numbers below support the fact that Lower Moreland Township is a high-quality community, complete with residential character, as exemplified by the assessed values of these homes in Montgomery County.

“Property Assessments for Residences on Byberry Road in Huntingdon Valley, LM”

410001582006 25 006 -011 COR 06/66 2,150,000 410001786009 50 029 -031 PENNDOT 01/53 32,780E 410001777009 90 007 -005 01/61 189,870 410001774003 94 007 -006 01/67 221,910 410001583005 101 006 -050 09/86 1,328, 870 410001771006 106 007 -138 08/95 260,450 410001768009 144 007 -007 03/84 183,500 410001765003 228 007F-041 08/01 153,690 410001764004 230 007F-082 09/94 252,350 410001579018 235 006I-001 06/96 208,200 410001763005 244 007F-081 05/88 228,660 410001579036 247 006I-037 10/86 207,310 410001762006 250 007F-049 09/96 179,320 410001579009 259 006I-002 11/00 177,660 410001576003 267 006I-003 01/02 120,630 410001759009 268 007F-018 10/96 295,820 410001573006 275 006I-004 12/00 137,620
410001756003 280 007F-059 03/91 132,740 410001567003 295 006I-005 10/79 157,850 410001566004 305 006I-058 03/87 220,420 410001753006 320 007F-070 07/87 153,150 410001564006 321 006I-038 06/74 149,570 410001579054 327 006I-039 06/02 229,390 410001561009 333 006 -00605/92 0 410001561207 333 006G-021 07/99 170,010 410001561108 357 006G-020 04/96 247,020 410001750009 368 007E-062 07/89 194,780 410001558003 375 006 -026 09/88 228,700E 410001555006 403 006 -037 01/60 202,870 410001747003 410 007E-061 07/99 144,690 410001744006 416 007E-065 10/76 141,790 410001552009 421 006 -033 01/69 190,000 410001741009 424 007E-056 11/88 131,730 410001738003 430 007E- 08/01 313,770 410001540003 467 005 -057 01/67 173,290 410001537006 473 005 -022 01/89 173,650 410001534009 495 005 -021 11/73 166,580 410001531003 515 005 -050 06/98 168,280 410001528006 533 005 -037 01/97 210,750 410001525009 551 005 -036 11/98 135,340 410001522003 565 005 -002 10/00 147,220 08/99 268,920 410001513003 637 004 -034 07/90 135,470 410001510006 655 004 -002 01/58 122,610 410001507009 669 004 -051 02/86 126,500 410001519006 577 005 -001 01/60 139,100 410001516018 603 004 -004 05/02 264,540 410001516009 615 004 -003 410001501006 681 004 -052 06/71 157,720 410001666003 974 003A-025 146,700 410001663006 980 003A-024 03/03 151,170 410001681033 992 007C-090 12/00 114,908 410001660009 994 003A-014 06/02 156,980 410001657003 1000 003A-016 05/93 148,750 410001654006 1012 003A-015 01/58 125,000 410001651009 1020 003A-017 03/03 142,890 410001648003 1036 003A-021 05/79 139,320 410001646005 1044 003A-023 190,440 410001645006 1050 003A-019 06/92 138,440 410001642009 1080 003A-018 03/99 152,800 410001498009 1161 001 -009 410001479001 1427 001 -085 09/98 426,370 410001477003 1437 001 -045 09/82 190,640 410001478002 1439 001 -083 09/98 415,360 410001468003 1477 001 -058 02/88 230,910 410001467004 1495 001 -057 04/74 224,300 410001588009 1634 001C-010 09/99 170,320 410001586002 1708 001C-103 07/78 319,210

Q141- PENNDOT please confirm, if the sidewalks will remain for pedestrian use along Byberry Road in Philadelphia between Bustleon Avenue and Philmont Avenue?

Q142 – PENNDOT please explain, why a mix of regional traffic and local traffic warrants a ‘partial’ rating for the Project Need: Traffic and Pedestrian Safety in TABLE ES-1 and being reminded of the claim made by the DVRPC comparing preferences to necessities?

Q143- PENNDOT please confirm, if Byberry Road in Philadelphia between Bustleton Avenue and Philmont Avenue is being improved with additional lanes, lane markings and improved intersections in various build alternatives?

Q144 – PENNDOT if the answer is yes to the above question, then how is traffic safety adversely affected by this regional traffic driving next to local traffic on Byberry Road in Philadelphia, when it will be driving on an improved roadway network?

Q145- PENNDOT would it be accurate to say that other roadways simultaneously carry combinations of regional and local traffic in the Project Area besides Somerton/Philadelphia? And in this region? And in many similar neighborhoods that are wedged next to major highways, across the state, throughout the US? Any neighborhoods that are nestled next to major highways should expect to have a mix of local and regional traffic on roadways in their neighborhoods?

Q146 – PENNDOT, is it logical to conclude that the same type of a ‘mix’ of regional and local traffic will also exist on Byberry Road - west of Philmont Avenue; and in this case, the residents of Lower Moreland who will be the other group of people that will have their pedestrian and vehicular safety also ‘put to risk’ by the motorists who live west of Lower Moreland and who are driving their vehicles west on Byberry Road via our roads, therefore, their regional traffic is mixed in with our local traffic? As you can see, this is a common scenario, vehicles are in motion 24 –7, and all vehicles are entitled to share the road – just so they are responsible drivers and obey the laws of the road.

1) Eg: In Lower Moreland, our local traffic, will most likely be intermixed with regional traffic from Hatboro, Horsham etc.
2) Eg: In Upper Southampton, their local traffic will most likely be intermixed with regional traffic from Warminster, Warrington etc.

Q147 – PENNDOT is it logical to conclude that the highest volumes of traffic would first have to pass through any community that was built adjacent to Rt. 1?

Q148- PENNDOT, is it logical to conclude that even higher volumes of traffic would first pass through any community that was built adjacent to the intersection of Rt. 1 and Woodhaven Road Expressway?

Q149- PENNDOT please clarify the rationale for the strong concern regarding pedestrian safety along the section of Byberry Road between Bustleton Avenue and Philmont Avenue, with the cause of concern being the risk attributed to the existence of a mix of regional and local traffic - YET there has been no mention of the existence of SEPTA’s R3 Regional Rail Forest Hills Station nor the traffic associated with this station, all of which is located in the middle of that section of Byberry Road?

Q150- PENNDOT please explain the reason for the lack of safety concerns for other neighborhoods in the ‘Project Area’ since there is NO mention of the need for ‘traffic and pedestrian safety’ on Byberry Road west of Philmont Avenue, also highly residential – where Byberry Road is widened from 2 to 4 lanes compared to the 2 lanes of Byberry Road in Somerton/Philadelphia?

Q151- PENNDOT please explain the reason for the lack of safety concerns for other neighborhoods in the ‘Project Area’ since there is NO mention of the need for ‘traffic and pedestrian safety’ on Huntingdon Pike – where the Pike will be widened from 2 to 4 lanes compared to the 2 lane of Byberry Road in Somerton/Philadelphia?

Q152- PENNDOT please explain the reason for the lack of safety concerns for other neighborhoods in the ‘Project Area’ since there is NO mention of the need for ‘traffic and pedestrian safety’ on County Line Road – where County line will be widened from 2 to 4 lanes compared to the 2 lane Byberry Road in Somerton/Philadelphia?

Q153- PENNDOT please explain what the effect on pedestrian and traffic traffic safety is, that would be caused by the widening of Byberry Road - as referenced in the statement on page ES-x and ES-xii: “Due to the mix of regional and local traffic on Byberry Road west of Bustleton Avenue and the widening of Byberry Road, the need to improve traffic and pedestrian safety is only partially addressed?”

Q154- PENNDOT, if your answer refers to a negative effect, since project needs would only be partially addressed, then is it logical to conclude that widening Byberry Road was a factor that resulted in pedestrian and traffic safety being compromised?

Q155- PENNDOT please explain why- in all four current build alternatives, Byberry Road in Lower Moreland Township is being widened either 2 to 4 lanes or 2 to 5 lanes, yet there is no documentation of the Project Need of ‘pedestrian and traffic safety’ only being partially met as it relates to a widened Byberry Road in Lower Moreland?

Q156- PENNDOT please explain, why does a widening of Byberry Road in Philadelphia (between Bustleton Avenue and Philmont Avenue) result in only partially met Project Needs relating to pedestrian and traffic safety, BUT a widening of Byberry Road in Lower Moreland DOES NOT result in partially met Project Needs as it relates to pedestrian and traffic safety charted on TABLE ES-1?

Q157- PENNDOT please explain the data (given on page 1-8) that states currently there are over 1,100 vehicles making the right turn from Evans Street onto Byberry Road during the PM peak hour and the volume is EXPECTED TO INCREASE TO APPROXIMATELY 1, 250 vehicles by the year 2026?

Q158 - PENNDOT relative to predicting Average DailyTraffic Volumes for 25 years into the future, what is the acceptable transportation industry standard tolerance for these forecasts? 1%. 2.5%, 5% ? Please identify.

Q159- PENNDOT whatever number you provide, rules of statistics and common sense, would most likely indicate that the lowest range will BE GREATER than 150, correct?

Q160- PENNDOT, please justify the fact that, in essence, you are attempting to construct an expressway extension for this minimal quantity of ONLY 150 vehicles, a numerical value that would most likely not appear on any statistical analysis for forecasts a quarter of a century into the future?

Q161- PENNDOT, please comment, it could be said that you are building this highway for a mythical set of drivers that does not exist?

Q162- PENNDOT please explain, why creating a pedestrian bridge over Proctor Road to access St. Christopher’s Church and School has never been considered? According to the Public Involvement Technical Files, a major frustration according to the senior citizens in the FOP Apartments was not being able to cross Byberry Road to attend various church functions?

Q163- PENNDOT please explain, how this new pedestrian bridge would function physically and socially?

Q164- PENNDOT please confirm, if this effect from having the bridge constructed would improve safety for all pedestrians crossing Byberry Road at Proctor Road?

According to the features of the three build alternatives for the Byberry Road Upgrade Alternative, the Bustleton Avenue Alternative, and the Bustleton Avenue Modified Alternative, the proposed scenarios for these alternatives are described as: ”Pedestrian access to the residential areas along Byberry Road, Huntingdon Pike and County Line Road could be more difficult due to increased traffic volumes and widened roadways”.

Q165 - PENNDOT please explain why an important element of community cohesion; ‘pedestrian access’, has been attempted to be minimized by using the word ‘could’ to casually acknowledge the undesirable living conditions many residents will have to live with if these roads are widened to your specifications?

Q166 - PENNDOT please explain, how much wider would the roads have to be, and how much more traffic would the roads have to bring into our communities - in order for the word “could” to justifiably become a definitive, an accurate “would”?

Q167 - PENNDOT please explain, the if the execution of the ‘Project Needs’ applies to the entire ‘Project Area’ to all of the communities inhabiting it?

Q168 - PENNDOT, if you answer is yes, then please cite references to the DEIS where the safety of Lower Moreland’s schools, our elderly our neighborhood streets near busy intersections are mentioned.

Q169 - PENNDOT please explain, if pedestrian bridges or sidewalks may be considered for the residents who live in the residential areas on Byberry Road (along the entire ‘Project Area’ including Lower Moreland Township and Bryn Athyn Borough), Huntingdon Pike and County Line Road since pedestrian access could be an issue?

Q170 - PENNDOT please explain, if your answer is no to the question above, why aren’t bridges or sidewalks being considered for these residents – since improving traffic and pedestrian safety is supposedly a ‘Project Need’? For the same reasons there is no on-street parking and bicycle lanes?

According to the features of the two build alternatives for the Byberry Road Upgrade Alternative and the Bustleton Avenue Alternative: “The widening would not create additional impacts on community cohesion as the communities are currently bisected.”

Q171 - PENNDOT please define the term ‘bisected’?

Q172 - PENNDOT please provide a schematic that highlights which neighborhoods and which roadways that are being referred to as already being bisected?

Q173 - PENNDOT, please confirm the quantity of lanes comprising the majority of the existing roads that exist in these communities that are referred to as being already bisected?

Q174 - PENNDOT, is it logical to say that, generally speaking, many roads in many suburban environments are probably 2 lanes wide in this region?

Q175 - PENNDOT, is it accurate to say that Byberry Road in Lower Moreland, Huntingdon Pike in Lower Moreland and portions of County Line Road on the Lower Moreland/Southampton Township are currently 2 lanes wide in the project area?

Q176A - PENNDOT please provide the data used to arrive at your conclusion that: “The widening would not create additional impacts on community cohesion as the communities are currently bisected”?

Q176B - PENNDOT it is obvious this project is a stacked deck. You state that there would not be impacts from massive road widenings, yet the concern for ‘pedestrian access’ within our communities could be impacted from these massive road widenings! Please justify your logic?

Q177- PENNDOT please explain how the presence of concrete sound barriers in this area negatively impacts community cohesion?

Q178- PENNDOT, please explain if it is possible that cumulatively, the widened roads AND the concrete sound barriers, together, negatively impacts community cohesion?

PENNDOT, the Woodhaven Extension Alternative Description does not include the statement: ”Pedestrian access to the residential areas along Byberry Road, Huntingdon Pike and County Line Road could be more difficult due to increased traffic volumes and widened roadways”.

Q179 - PENNDOT please confirm if this alternative involves the most new road construction and the most road widenings in the suburban portion of the Project Area?

Q180- PENNDOT is it logical to state that ”Pedestrian access to the residential areas along Byberry Road, Huntingdon Pike and County Line Road could be more difficult due to increased traffic volumes and widened roadways” in the Woodhaven Extension Alternative since this characteristic is a feature of the three other less invasive build alternatives?

Q181- PENNDOT, if the answer is yes to the above question, then it would be true to say that all four or your current build alternatives, 100%, could render pedestrian access more difficult AND that all current build alternatives could have a negative impact?

As we can see PENNDOT chooses to downplay highly likely negative impacts and make them appear to be negligible negative impacts. When it comes to the suburbs in the project area, according to PENNDOT, it is not such a great place to live, with our communities are already being fragmented, just bring on the bulldozers and widen those 2 lane country roads! According to PENNDOT, after they widen the roads, we could have a problem with pedestrian access - but they do not appear to be too concerned with our communities and our quality of life in the suburbs! To claim that the people living along the highly residential Byberry Road, Huntingdon Pike and County Line Road would not suffer a feeling of separation from their neighbors if their roads were widened from two lanes to four/five lanes encased in sound barriers - is subjective, arbitrary, illogical, boldly insensitive, cold hearted, a poor attempt to skew the perception of the real impact to other communities in the Project Area - and to ultimately lay the groundwork for the still unjustified perceived need for the full Expressway.

Q183- PENNDOT please confirm what is the percentage of the above defined area relative to the TOTAL Project Area in Montgomery County for the Woodhaven Road Project?

Q184- PENNDOT are you aware that the Jewish population comprises only 2 % of the total population in the United States?

Q185- PENNDOT are you aware that Huntingdon Valley is comprised of a Jewish population of over 50%?

Q186- PENNDOT are you aware that based on various residents knowledge of the demographics of Huntingdon Valley, the bounded project area is comprised of a Jewish population of over 50%?

Q187- PENNDOT are you aware that the concentration of the Jewish population in Huntingdon Valley is at least 25 x’s the national average?

Q188- PENNDOT, are you aware that per Executive Order 12898, all federal agencies are required to address the impacts of their programs with respect to environmental justice as it applies to minority populations and low-income populations?

Q189- PENNDOT please comment on the fact that the demographics of these people living inside the bounded Project Area were not addressed relative to excessive project impacts; thereby unduly discriminating against this segment of the population which is a minority group?

Q191- PENNDOT please explain if the Woodhaven/PA 63 Expressway is considered the most important local east-west route because Street Road is not inside the Project Area and is not in Philadelphia City Limits?

Q192- PENNDOT please explain how your plans to separate regional and local traffic- by removing the regional traffic from Byberry Road and directing it to the expressway will be feasible since according to page 2-20; the Woodhaven PA/63 Expressway is the single most important east-west route in the LOCAL roadway network? This claim to be able to separate regional traffic from the local traffic is in direct conflict with the function of Woodhaven /PA 63 Expressway as being a LOCAL roadway. Where will this regional traffic come from if it is just on a LOCAL roadway?

Q193- PENNDOT please confirm this common traffic condition that is occurring in the project area: Motorists are driving on the Woodhaven Expressway from I-95 passing Franklin Mills and continuing westward. For example, if you live in Normandy, all of the motorists from Somerton and Lower Moreland and Upper Moreland and Hatboro are considered regional - if you live in Normandy. As this traffic approaches the end of the expressway at Evans Street, the motorists who live in Somerton now become the local traffic, and the motorists in the suburbs, since they live west of Somerton, still stay classified as regional traffic because they live further west. (Now the magic begins…the regional and local traffic will magically be separated from each other, maybe the motorist’s vehicles will be magnetized and directed to drive only on the appropriately designated roads, according to their zip code!) SO IT CAN BE SAID, that depending which segment of an expressway or road or street that a motorist is on, there are varying degrees of traffic mixes; at any given time and any given place, caused by the presence of exit and entrance ramps, intersections etc. In the case of Woodhaven Expressway; - The people who live to the west or east of any given neighborhood are considered regional relative to the community they are passing through – until they get close enough to their community, then they become local. This works for traffic moving east and west, north and south, in any community, in any state! As you can see PENNDOT, having of mixes of traffic drive on roads is perfectly natural and a result of millions of people driving their vehicles in America!

Q194- PENNDOT please explain what the DEIS means when it states that the study area is well served by the SEPTA R3 West Trenton Regional Rail Line?

Q197 - PENNDOT please explain why the following Philadelphia streets; Trina Drive, Worthington Road, Stevens Street, Kelvin Street, Gaston Lane, Proctor Road and Lewis Street which are situated between Evans Street and Bustleton Avenue are not depicted on Figure 2-7?

Q198 - PENNDOT, is it accurate to state that according to this chart: no vehicles turn off Byberry Road onto these streets, and all of these vehicles remain on Byberry Road all the way to Bustleton Avenue from Evans Street?

Q199 - PENNDOT is it logical to say that all of the build alternatives are derived from data that was based upon forecasted traffic conditions, forecasted population growth, forecasted employment growth and forecasted economic trendsq Q200 - PENNDOT please explain the definition of forecastq Q201- PENNDOT please explain why the traffic forecasts from the March 1989 Traffic Study, that forecasted traffic volumes for 1995 still have not materialized in 2002?

Q202 - PENNDOT please explain why we should hand over our communities for a project that has no real grounds, outdated information and mean spirited community leaders who revel in spreading their pain?q Q203 - PENNDOT, please explain the reason for the very small excavation sites the were dug in August 2002 on 2 properties across from the Forest Hills Cemetery on the south side of Byberry Road? (Refer to Reports and Photographs Section.)

Q204 - PENNDOT, please explain why e-mail was not an acceptable form of communication to submit Public Testimony according to the May 16, 2003 Public Notice sent out by PENNDOT and the US Army Corps of Engineers BUT according to the DEIS page 5-3 paragraph 2: “A total of 1331 surveys were received either on paper ballots, electronic polling, through the website, emails or letters.”?

Q205 - PENNDOT please explain how the public comments received at the 2 meeting held in 1997; (where only 300 attendees filled out questionnaires and only 44 spoke of their concerns), this was grounds to expand the project area to Huntingdon Pike in Lower Moreland per the last paragraph on 5-2?

Q206 - PENNDOT please explain the mixed signals you send relative to safety of ALL school children: Pg. 48 in the June 1992 Evaluation of Project Need report, fourth paragraph: “The Comly Elementary School is located at Byberry and Kelvin Roads. Many students walk to and from school and often cross Byberry Road. Potentially unsafe conditions exist for students…” THEN look at the increased average daily traffic volumes the current build alternatives will put on Pine Road in front of the Pine Road Elementary School in Huntingdon Valley. Are school children in Philadelphia more important than school children in Huntingdon Valley?

Q207- PENNDOT did you know that the world does not end west of Philmont Avenue?

1) Work with the Federal Government, the City of Philadelphia, and a Drexel University to declare Woodhaven Road a National Traffic Management Research Zone. In this zone, apply and develop new technologies to monitor and control traffic flows to mitigate congestion. Continue development for a period of 24 to 60 months.
2) Use the results generated in the research to provide specific focus to the definitive Benefit/Cost analysis of the Woodhaven Road Project. If there is a compelling public benefit, it will be determined by the precise data developed from advanced congestion monitoring and control.

A critical part of evaluation is a benefit-cost analysis for the whole project and for each alternative incrementally over the base case. The benefit-cost analysis is a standard process for evaluation of high impact engineering projects. It also has the additional benefit of focusing the most effective use of public resources in the proper alternative. Furthermore, it can prevent the waste of public resources when the benefits are not compelling relative to dis-benefits and costs. I was informed by Penn DOT personnel on 6/26/03 that a comprehensive benefit/cost analysis has not yet been performed for this project overall and it's alternatives.

Based on the lack of a proper engineering benefit/cost analysis, selection among alternatives in the Woodhaven Road Project is premature. Any decisions regarding next actions should be postponed until the benefit/cost analysis is completed and reviewed publicly.

The key factors under-pinning the benefit/cost analysis need substantial study. The cost side of this project from a capital cost point of view has been extensively studied. The economics of the benefits, dis-benefits, and ancillary costs has not yet been reviewed in a comprehensive and consistent manner. A proper benefit/cost analysis starts with the current level of activity and relies on forecasts of future activity. The forecasting must be realistic, consistent for all alternatives, and it must take into account real driver behaviors, and the impact of new technologies.

Advanced technologies are now emerging which make traffic congestion management cost effective and effective in modifying driver behaviors. The Woodhaven Road traffic situation is an ideal place to test new technologies to see if they can mitigate congestion at peak periods. A trial of these methods and their development could serve as a model for the region and the nation in terms of new solutions to traffic congestion. Furthermore, and advanced traffic congestion management system would develop sufficient data to support a proper benefit/cost analysis and focus the Woodhaven Road Project more precisely on the public need as determined by real driver behaviors, not paper forecasts and speculation.

Penn DOT, together with the Federal Highway Administration, and Drexel University as a research partner, should designate Woodhaven Road a National Traffic Management Research Zone where during a specific study period of three to five years, continuous monitoring of traffic flows and implementation of new technologies to manage congestion are developed, tested and improved. The results of this study will provide definitive data for the precise scope of public need in the Woodhaven Road Project. It would also provide benefits to Penn DOT and Pennsylvania in dealing with evaluation of high population density roadwork alternatives in the future. Penn DOT would also be seen as a national leader in advanced traffic engineering with a community preservation orientation.

Why is further research necessary?

Without a definitive study of new technologies and their impact on traffic flows, Penn DOT will be relying on historical data and subjective judgment to provide a proper benefit/cost analysis. Although this lower standard may be appropriate for low impact projects, it is woefully inadequate for the Woodhaven Road Project for the following reasons:
1) The extreme negative impact on highly developed communities in the path of the project as it is currently envisioned. The population density of the affected areas is much higher than for most, if not all, other Penn DOT projects.
2) After 40 years of deliberation, the project does not appear to have a compelling public purpose; otherwise, it would have been justified long ago.
3) The costs of building a few miles of highway through areas with high population density is extreme and cannot be easily justified on the basis of congestion management alone. The current contemplated scope is poor public policy.

For these reasons, and others cited in my public testimony, a compelling case of public need and public benefit must be made to justify any action on the Woodhaven Road Project other than replacement of the CSX bridge.

My name is Stephen V. Smith. I'm a resident of Lower Moreland Township and I live in the area that will be affected by the Woodhaven Road Project. In my professional life, I'm Professor and Director of the Engineering Management Program at Drexel University in Philadelphia. One specialization is the proper evaluation of engineering alternatives. I have the following comments about this project:

1) There is no proof that the benefits from any alternative other than the "no build alternative" outweigh the environmental damage, community damage, and massive costs of this project as it is now envisioned. Based on this lack of economic justification, it is a waste of taxpayer money in a time of tight state budgets and federal budget deficits.

2) This project was started in the 1960's and has never been justified beyond its current configuration over the past 40 years. In that time, communities have extensively developed, infrastructure has developed and the costs and damages of this project have increased to a much greater level with no further benefits to be gained. If it has been a dead project for 40 years, it's still a dead project.

3) The traffic congestion forecasts used to establish Project Needs do not take into account real driver behavior in avoiding congestion by alternate route planning. Furthermore, new technologies will make alternative route planning at critical periods even more effective in the future. All of these effects mitigate the stated benefits claimed in the "project needs".

4) A better use of a small amount of funds would be to install a congestion management system that would warn drivers on Woodhaven Road to take an alternate route when the traffic delay on Byberry Road reaches certain levels.

5) Our community has spoken out in public and collectively against the encroachment of this project on our community and lives. We don't want it, it's not of any benefit to us, and we do not see any benefit that justifies the community damage, environmental damage, and massive costs entailed in this project.

6) As it has been for the last 40 years, and most likely will be for the next 40, the "no-build" alternative is the only justified alternative.

1. 40 CODE OF FEDERAL REGULATIONS (CFR) PART 93.104 FREQUENCY OF CONFORMITY DETERMINATIONS

Section 4.1.9 Air Quality, Conformity Analysis, page 4-70 of the draft EIS states, "The TIP (Transportation Improvement Plan) was adopted by Delaware Valley Regional Planning Commission (DVRPC) on April 26, 2001, and was approved by the US DOT (FHWA and FTA) on July 6, 2001. The SIP (State Implementation Plan) conformity was adopted on July 27, 2000. Since this project is included in a conforming TIP, it satisfies all conformity requirements, as outlined in the CAAA (Clean Air Act Amendments) of 1990". In addition, the Table on page ES-xv of the Executive Summary claims that "Air Quality Conformance" has been achieved for the "No Build Alternative" and the four Build Alternatives.

Page 190 (Attachment I), of the DVRPC FY 2001-2004 TIP, (document dated Monday, October 21, 2002) as approved by DVRPC Board on July 27, 2000 lists the project description for the PA 63, Woodhaven Road Project, TIP# 9332, MPMS#17112, AQ Code 2015/20 as the following:

"This project involves an EIS with three alternatives: (1) no build, (2) widening the existing Byberry Road including extending the Woodhaven Expressway to Byberry Rd. and (3) extending Woodhaven Rd. from its current terminus at Evans St. to Philmont Ave. The limited access road would be four lanes (two lanes in each direction) from Evans St. to Bustleton Ave. and two lanes (one lane in each direction) from Bustleton Ave. to Philmont Ave. A partial diamond interchange will be constructed at Bustleton Ave".

The description of the PA63 Woodhaven Road Project in the 7/27/00 DVRPC FY 2001 -2004 TIP is vastly different than the currently proposed PA63 Woodhaven Road Project outlined in draft EIS. The major differences akin to each of the Build Alternatives in the draft EIS are outlined below:

1. Expansion of Hunting Pike to four lanes between Byberry Road and County Line Road.

2. Expansion of County Line Road to four lanes between Buck Road and New Road

3. Expansion of County Line Road to six lanes between Philmont Avenue and the current section of County Line Road to where it is four lanes.

4. Expansion of Bustleton Avenue to six lanes between County Line Road and Philmont Avenue.

There are other differences between the 7/27/00 TIP and the current build proposals outlined in the draft EIS. In addition, the 7/27/00 TIP does not state that the No Build Alternative includes replacing the temporary bridge that spans the CSX railroad tracks on Byberry Road.

The 7/27/00 Conforming TIP, referred to in the draft EIS, does not reflect, is vastly dissimilar to, and is much smaller in scope to the current four build alternatives in the draft EIS. This contradiction must be addressed in a comprehensive manner. The draft EIS does not fully explain how the PA63 Woodhaven Road Project meets the provisions of the Federal Clean Air Act Section 176(c) and 40 Code of Federal Regulations (CFR) Part 93 "Transportation Conformity". The Table on Page ES-xv of the Executive Summary and Section 4.1.9 Air Quality, Conformity Analysis can be construed as misleading given the comparison between the references made to the 7/27/00 TIP document which includes the PA63 Woodhaven Road Project and the current build descriptions.

Within 40 CFR 93.104 "Frequency of Conformity Determinations", 40 CFR 93.104 (c) (2) states, "A TIP (transportation improvement program) amendment requires a new conformity determination for the entire TIP before the amendment is approved by the MPO (Metropolitan Planning Organization) or accepted by the DOT (United States Department of Transportation), unless the amendment merely adds or deletes exempt projects listed in 40 CFR 93.126 or 40 CFR 93.127". The changes to the 7/27/00 PA Woodhaven Road Project TIP as reflected in the current build proposals in the draft EIS do not qualify as exempt projects as listed in 40 CFR 93.126 or 40 CFR 93.127. In fact, 40 CFR 93.126 makes a specific reference to the fact that the adding of additional travel lanes is not an "exempt project". Also, the "No Build Alternative" by itself requires a new conformity determination by itself since removing a bridge weight restriction is not an "exempt project".

A new conformity determination must be made for the PA63 Woodhaven Road Project's current TIP approval, pursuant to 40 CFR 93.104(c)(2). This would require a Major amendment as outlined in the DVRPC Memorandum of Understanding Concerning Special Procedures for Expediting TIP Amendments and Modifications for the Pennsylvania Portion of the DVRPC, as adopted on June 27, 2002.

Based on a review of DVRPC documents, the DVRPC website (www. Dvrpc. Org), and a discussion with Mr. Charles Dougherty of the DVRPC, no major amendment has been filed for and no request for a new conformity determination has been made for the modifications to the PA63 Woodhaven Road Project outlined in the draft EIS. When doing a DVRPC web site search with the PA63 Woodhaven Road Project MPMS#17112, a project description the same as that listed in the 7/27/00 TIP is shown (Attachment II). No mention of the PA63 Woodhaven Road Project is listed in the DVRPC FY2003 TIP Pennsylvania (FY2003 FY2006).

This issue must be addressed. A complete explanation must be provided on why PENNDOT and the USDOT would rely on a conformity determination made to a proposal which is totally different from the current PA63 Woodhaven Road Project build proposals. Also, PENNDOT and the USDOT should outline how it plans to meet 40 CFR 93, and all other applicable Federal rules and regulations going forward. As per the 6/27/02 DVRPC MOU, a new conformity determination would require a 30 day public comment period and approval of the DVRPC board.

It would be necessary to reissue the draft EIS for public review and comment if a new transportation conformity determination is necessary since this document would have to modified significantly, to rectify the error made, and to give the public the opportunity to comment on accurate information.

Since the four current build alternatives are not in an approved transportation conformity determination, they do not currently qualify for federal funds, pursuant to 40 CFR 93.100, which is a rule which implements Section 176 (c) of the Clean Air Act and the related requirements in 23 U.S.C. 109(j).

The last sentence on Page 4-70 of the draft EIS states, "Coordination with FHWA and DVRPC will continue throughout the project to ensure inclusion of the Woodhaven Road Project as it is currently designed in future conformity determinations". This directly contradicts Page ES-xv of the Executive Summary and the last sentence in the Conformity Analysis which states, "Since this project is included in a conforming TIP, it satisfies all conformity requirements, as outlined by the CAAA of 1990". Such inconsistencies are unacceptable and misleading.

2. HEALTH RISK ASSESSMENT

No human health risk assessment is included in the draft EIS. Health impacts to aquatic organisms (page 4-22) and macroinvertebrates (page 4-31) were evaluated, but not impacts to human health.

In the January 29, 2002, Federal Register (Vol. 67, No. 19), the United States Environmental Protection Agency (USEPA) approved and announced the availability of MOBILE6 motor vehicle emissions factor model for official use outside California.
In the October, 2002 USEPA Document "User's Guide to MOBILE6.1 and MOBILE6.2:Mobile Source Emission Factor Model (Document Number EPA420-R-02-028), USEPA outlines the document as:

This document is the MOBILE6.1 and MOBILE6.2 User's Guide. MOBILE6 is a computer program that estimates hydrocarbon (HC), carbon monoxide (CO), oxides of nitrogen (NOX), exhaust particulate matter (which consists of several components), tire wear particulate matter, brake wear particulate matter, sulfur dioxide, ammonia, six hazardous air pollutants, and carbon dioxide emission factors for gasoline-fueled and diesel highway motor vehicles, and for certain specialized vehicles such as natural gas fueled or electric vehicles that may replace them. The program uses the calculation procedures presented in technical reports posted on EPA's Web page. While MOBILE6 replaced earlier versions of MOBILE, this version does not supercede MOBILE6.0 but adds capabilities to it".

This USEPA methodology provides the mechanism to determine emission factors. Some of the contaminants of concern are lead, particulate, benzene, Methyl Tertiary Butyl Ether (MTBE) and sulfates. With the use of these emission factors, total air contaminant emissions can be determined over 8 hour, 24 hour, and annual periods. These total air contaminant emissions can then be computer modeled to determine ambient concentrations at residences along the areas of proposed road construction. Reference concentrations of the carcinogens emitted from vehicles could then be used to determine the health risks. Hazard indices could also be used with these ambient concentrations to determine the non-carcinogenic health impacts.

Such analyses must be done for each alternative proposed to determine the potential health risks. The public needs this information, since with the reintroduction of truck traffic to Byberry Road, emissions of toxic air contaminants from diesel engines will impact residential communities. Within each alternative proposed, various scenarios should be considered. For example, if a truck route was established in a given alternative, the health risk from the truck route and non-truck route scenarios within the alternative could be determined. Such scenarios can be determined as stated in Section 4.4.3 Summary of Alternatives and Project Need Evaluations of the draft EIS which states, "Under the Woodhaven Extension Alternative, Bustleton Avenue Alternative, and Bustleton Avenue Alternative Modified, the removal of the weight restriction would result in increased local truck traffic, although most through truck traffic would be expected to use the new facility, not Byberry Road". Another scenario within each alternative would be the banning of trucks, except for local deliveries.

Much of the road construction project is being done in residential areas. Sensitive receptors (infants, children, pregnant women, nursing mothers, and the elderly) will be directly impacted by the air contaminant emissions. The distance from the emissions to these sensitive receptors could be 10 feet or less when they are at home. Also, since most of the air contaminant emissions are discharged at ground level, there is little opportunity for dispersion prior to reaching the sensitive receptors. Also, health impacts at schools and senior residences within the study area need to be determined.

Inhalation and soil ingestion risk assessments must be done. The methodologies, inputs, and results must undergo public scrutiny. Each road construction alternative should undergo such an analysis. The health of our community is too important for these studies not to be conducted.

It is necessary to reissue the draft EIS for public review and comment with a comprehensive health risk assessment so that the public will have the opportunity to evaluate all alternatives knowing the associated health risks.

3. AMBIENT AIR QUALITY DETERMINATIONS

The Air Quality Section must be expanded to demonstrate that the proposed project will not result in a violation of any Federal air quality standard. This analysis should include lead, nitrogen dioxide, particulate matter PM-10, particulate matter PM-2.5, and sulfur dioxide. Clean Air Act Section 176(c)1.(B) (Attachment III) states . . . Conformity to an implementation plan means that such activities will not (i) cause or contribute to any new violation of any standard in the area; (ii) increase the frequency or severity of any existing violation of any standard in any area; or (iii) delay timely attainment of any standard or any required interim emission reductions or other milestones in any area.

Of particular concern are the emissions of particulate matter PM-2.5. All of the following data is taken from the "2001 Pennsylvania Air Quality Monitoring Report" (Report). The annual arithmetic mean Standard Level Concentration for the National Ambient Air Quality Standard for PM-2.5 is 15 micrograms per cubic meter (ug/m3). The Bristol monitoring location had annual PM-2.5 concentrations of 13.8 ug/m3 and 14.6 ug/m3 in 2000 and 2001, respectively. The Norristown monitoring location had annual PM-2.5 concentrations of 13.6 ug/m3 and 15.1 ug/m3 in 2000 and 2001, respectively. The Chester monitoring location had annual PM-2.5 concentrations of 15.9 ug/m3 and 16.0 ug/m3 in 2000 and 2001, respectively. The Woodhaven Road project lies in proximity with all three monitoring locations. All three shows increasing PM-2.5 trends, and two locations show one year exceedances of the NAAQS annual standard for PM-2.5.

In addition, the following annual PM-2.5 2002 readings (preliminary and unpublished) were obtained from the Pennsylvania DEP for the monitoring location indicated: the annual average for Bristol as 14.2 ug/m3, the annual average for Chester as 14.6 ug/m3, and the annual average for Norristown as 13.7 ug/m3. Several quarterly readings for these sites exceeded 15 ug/m3. All annual readings are within 90% of the standard.

As stated above and in Part One, page 1 of Transportation Conformity- a Basic Guide (Attachment IV), according to the Clean Air Act, transportation plans, programs, and projects cannot 1) create new violations of the Federal air quality standards; 2) increase the frequency of severity of existing violations of the standards; or 3) delay attainment of the standards.

No demonstration of the impact of the PM-2.5 ambient air quality standards has
been made for the Woodhaven Road project. This must be done. PM-2.5 are small particles that when breathed into the lungs can aggravate or cause respiratory ailments or carry other pollutants into the lungs. As listed in the April 1, 2003 "Guidance for Determining Boundaries of Fine Particle Attainment and Nonattainment Areas"(Guidance-Attachment V) diesel engines emit fine (PM-2.5) particulates and motor vehicles emit VOC which react with other gases in the atmosphere to produce "secondary" particles, which include PM-2.5.

The Guidance also states that PM-2.5 designations (attainment/nonattainment) for the area will not be made final by the USEPA until December 15, 2004 and that transportation conformity requirements become effective one year after an area is designated non-attainment. However, Section 176(c)(1)(B)(i) is clear that no applicable activity can "cause or contribute to any violation of any standard in any area". PM-2.5 background concentrations can be assumed using the existing monitoring results, and MOBILE6 can be used to determine particulate emissions and a conservative estimate can be made about the PM-2.5 emissions from the increased car and truck traffic.

It is necessary to reissue the draft EIS for public review and comment with a comprehensive assessment of the ambient air quality impacts of the criteria pollutants so that the public will have the opportunity to evaluate all alternatives knowing the associated impact.

4. AIR QUALITY CONSTRUCTION IMPACTS

Section 4.5 Construction Impacts, Part 4.5.4. Air Quality is inadequate and must be expanded. The Construction activities of the Woodhaven Road project, to protect public health, must have several mandated requirements. Any Contractor must develop and implement a Dust Management Plan (DMP). This DMP would provide regular inspections of the job site to identify any potential fugitive dust emissions and reduce this potential. Water sprays must always be available and used to prevent fugitive emissions. Truck wheel washing must be implemented. Also, employees should be instructed to notify the job supervisor if dust becomes present.

The fuel used for all mobile and stationary combustion equipment should be low sulfur diesel fuel. Truck idling should be kept to an absolute minimum.

All stationary engines should be equipped with the latest in Air Pollution Control Technology. This would include soot traps and catalytic units.

5. CHANGES TO PA 63 WOODHAVEN ROAD PROJECT IN SUMMER 2002 WOODHAVEN ROAD NEWS LETTER

The Summer, 2002 Woodhaven Road Project Newsletter stated that, "in response to public input received in early 2002, the two lane section of County Line Road, which extends from Buck Road to just west of New Road, was included in the study". On November 19, 2002, the attached email(Attachment VI) was sent to Joseph Capella, PENNDOT as to who made the comments and why Step 5 "Detailed Alternatives" was not being repeated given the changes.

In a March 25, 2003 email (Attachment VI), Mr. Capella responded that 39 written comments and 6 oral comments were received favoring improving County Line Road in conjunction with, or as opposed to, improving other roads in the study area. In a March 31, 2002 letter (Attachment VII), Mr. Capella was requested to issue a summary of who made the comments and what comments were made. Mr. Capella has not yet replied to this letter.

The following issues must be addressed:

1. Why Step 5 of the PENNDOT 10 Step Process did not have to repeated for the modified build alternatives outlined in the Summer, 2002 Woodhaven Road Project Newsletter? The State or Federal rules guiding this process must be listed. Clearly, there must be some criteria outlining when a transportation project has been modified to such a degree as to trigger a complete reevaluation.

2. A summary of and the actual 45 comments made at the 1/29/02 public meeting that lead to the major redesign of the PA 63 Woodhaven Road Project. This must be made available to the public.

3. A summary of and the actual 99 written comments and 63 oral comments made at the 1/29/02 public meeting which did not support the major redesign of PA 63 Woodhaven Road Project, and how these comments were evaluated by PENNDOT.

4. A copy of the summary and presentation made by PENNDOT to Public Officials at a meeting held on January 31, 2002 to provide local legislators and other stakeholders a summary of the public commentary. This must demonstrate that a balanced view of the public commentary was provided to the public officials. Also, a list of the public officials in attendance must be provided.

6. January 29, 2002 Survey
On Page 5-3 of the draft EIS a Survey distributed at the January 29, 2002 meeting at Lower Moreland High School is mentioned and the results are outlined. However, the survey was inappropriate and its results are skewed. A "No Build Alternative" was not included as a choice and there was no choice of "other _____" where a citizen could write in "No Build" or any other alternative of his or her choice. This resulted in the high Survey percentages of the "Woodhaven Road Alternative" and the "Bustleton Avenue Alternative". The impact of this Survey on the overall decision making process must be outlined.

7. No Build AlternativeThe "No Build Alternative", outlined on Pages 3-24 and 3-25 of the draft EIS, is an inappropriate baseline for comparison with the four build alternatives. On Pages 3-24 and 3-25, it is stated that the temporary Byberry Road Bridge (CSX-Trenton Line) will be replaced and that its three ton weight restriction will be removed. This would allow truck traffic to be introduced to Byberry Road. Also, the Public Utilities Commission (PUC) has mandated that the bridge be replaced regardless of whether other improvements are made as part of this project. It appears that the proposed modification to the bridge will be an upgrade, rather than a replacement. Removal of a bridge weight restriction is a major upgrade.

The draft EIS is unclear on the following: whether the PUC is mandating the that the bridge be upgraded to have the weight restriction removed, what government entity (state or Federal) will be paying for the modifications to the bridge, what does "temporary" mean on page 3-24, as the bridge has been around already since 1995 and is there at State or Federal definition that would qualify it as temporary, and does the PUC have ultimate jurisdiction on the final design of the new bridge. Such issues must be addressed.

The appropriate "No Build Alternative" would be a true replacement of the bridge, maintaining the three ton weight restriction. The draft EIS should have had five build alternatives, the four currently outlined and a fifth analyzing the upgrade of the bridge with the weight restriction removed. This would have allowed the public to properly analyze the impact of the additional truck traffic on Byberry Road. The draft EIS must be reissued to allow the public this opportunity and to address the issues which should have been discussed on Pages 3-24 and 3-25.

In addition, if any Federal funds will be used to the upgrade of the bridge, an amendment to the PA 63 Woodhaven Road Project as listed in the Delaware Valley Regional Planning Commission FY 2001-2003 Transportation Improvement Program (TIP) must be obtained and a new transportation conformity determination is necessary, pursuant to 40 CFR 93.104 (c)2. No mention of upgrading the bridge is in the FY 2001 TIP. Removing a weight restriction from a bridge is not included as an exempt activity, as listed in 40 CFR 93.126 or 93.127. The fact that an amendment is necessary should have by itself put the upgrade of the bridge into its own build alternative.

"No Build" should mean "No Build" and nothing else.

8. TRUCK ROUTES AND TRUCK RESTRICTIONS

PENNDOT should examine the establishment of truck routes since additional trucks will be travelling on roads in the areas described in the Build Alternatives. Also, truck prohibitions, except for local deliveries, should be considered for certain roads and during certain times of day (8 pm -8am) to minimize the impact on the residential communities.

9. PREVENTING CUT THROUGHS IN RESIDENTIAL NEIGHBORHOODS

Efforts should be made to prevent cut through in residential neighborhoods during construction and afterwards. The following should be implemented at a minimum: the placement of speed bumps at the entrance and throughout residential neighborhoods, "NO THRU TRAFFIC" signs, and prohibitions on turning into certain streets at rush hour (no left turn 7:00 am to 9:00 am and 4:00 pm to 6:00 pm).