ML031220048
| ML031220048 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/23/2003 |
| From: | Snook R State of CT, Office of the Attorney General |
| To: | Travers W NRC/EDO |
| Shared Package | |
| ML031740705, ML032970463 | List: |
| References | |
| %dam200610, 2.206, FOIA/PA-2003-0379, FOIA/PA-2003-0388, G20030216 | |
| Download: ML031220048 (121) | |
Text
EDO Principal Correspondence Control FROM: DUE: 06/04/03 EDO CONTROL: G20030216 DOC DT: 04/23/03 FINAL REPLY:
Robert D. Snook Assistant Attorney General State of Connecticut TO:
Travers, EDO FOR SIGNATURE OF : ** GRN ** CRC NO:
Collins, NRR DESC: ROUTING:
2.206 - Entergy Nuclear Operations, Inc. Travers Request of Emergency Plans at Indian Point Energy Paperiello Center Units 2 and 3 Kane Norry Dean Burns DATE: 04/30/03 Cyr, OGC Miller, RI ASSIGNED TO: CONTACT: Skay, NRR Goldberg, OGC NRR Collins, NRR SPECIAL INSTRUCTIONS OR REMARKS:
Temeat: E. DO- 001 C-/k, : £D6D- 0o
RICHARD BLUMENTHAL 55 Elm Strcct ATTOMNEY GENERAL P.O. Box 120 Hartford, CT 06141-0120 Office of Tnic Attorney General Tek ( 860 ) 808-5020 State of Connecticut Fax: (860) 808-5347 April 23, 2003 Dr. William D. Travers Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: In the Matter of Entergy Nuclear Operations, Inc.
Dear Dr. Travers:
Enclosed for filing please find an original and a copy of the Attorney General of Connecticut's 2.206 Petition. Please stamp and return the copy in the envelope provided.
If you have any questions, please call me at 860-808-5020.
Very truly yours, Assistant Attorney General EDO -- G20030216
I Before the UNITED STATES NUCLEAR REGULATORY COMMISSION Washington, D.C. 20555 In the Matter of:
DOCKET No.
ENTERGY NUCLEAR OPERATIONS, INC.
(Indian Point Nuclear Generating Unit, Units No. 2 and 3) Licenses DPR-5, DPR-26 and DPR-64
April 24,2003 RICHARD BLUMENTHAL, ATTORNEY GENERAL OF THE STATE OF CONNECTICUT, Petitioner SECTION 2.206 REQUEST FOR REVIEW OF EMERGENCY PLANS AT INDIAN POINT ENERGY CENTER UNITS 2 AND 3 Executive Summary The two nuclear reactors at the Indian Point Energy Center, and their associated spent fuel pools, pose an unreasonable risk to nearby population centers in New York and Connecticut.
The existing emergency response plans are based on inadequate or erroneous information, include clearly incorrect assumptions regarding the movement and actions of affected people, and, ominously, deliberately refuse to consider the effects of a terrorist-initiated emergency.
Because the response and evacuation plans will not work in the event of a true emergency, and because the failures of these plans will affect large numbers of people living in western Connecticut, the Attorney General of Connecticut calls on the Nuclear Regulatory Commission to immediately order a full review of all emergency preparedness plans at Indian Point and, during the course of this review, to order the suspension of the plant's license to operate.
I. Request for Action Richard Blumenthal, Attorney General of Connecticut ("Attorney General" or "Petitioner")
hereby respectfully requests, pursuant to 10 CFR §§ 2.206 and 2.202, that the United States Nuclear Regulatory Commission take the following immediate actions:
- 1. Order the Indian Point licensee to conduct a full review of the facility's vulnerabilities, security measures and evacuation plans and to suspend operations, revoke the operating license, or adopt other measures resulting in a temporary shutdown of Indian Point Unit 2 and Unit 3, as per 10 CFR § 2.202.
- 2. Require the licensee to provide information, as contemplated by 10 CFR § 2.204(a),
documenting the existing security measures which provide the Indian Point facility with protection against terrorist attacks. Such information should provide, at a minimum, sufficient basis for the Commission to determine that physical barriers, intrusion alarms, and other measures are in place and are sufficient to meet realistically possible threats.
- 3. Immediately modify the licensee's operating license for Units 2 and 3 to mandate, at a minimum, a defense and security system sufficient to protect the entire facility, including the containment and spent fuel storage buildings, control room and electricity equipment, from a land or water based terrorist attack as required by 10 CFR § 73.55. The security review described above should provide for appropriate measures on a permanent basis.
- 4. Order the revision of licensee's Emergency Response Plan and the Radiological Emergency Response Plans of the State of New York and the nearby counties, in order to account and prepare for possible terrorist attacks. These revisions must encompass not only realistic and catastrophic effects of a terrorist attack on the Indian Point facility, but also a comprehensive response to multiple attacks in the region which may impair the efficient evacuation of the area. Examples of such attacks include destruction of the regional road and bridge system, loss of power to passenger railroads, and other events that deny use of necessary infrastructure.
- 5. If, after conducting a full review of the facility's vulnerabilities, security measures and evacuation plans, the NRC cannot sufficiently ensure the security of the Indian Point facility against terrorist threats, or cannot ensure the safety of New York and Connecticut citizens in the event of an accident or terrorist attack, the Commission should take prompt action to permanently retire the facility.
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As explained more fully below, the Indian Point Radiological Emergency Preparedness Plan ("REPP") is fatally flawed. It is based on inadequate and antiquated information and unsupportable assumptions. Specifically, the travel time and evacuation route data is outdated or erroneous. Critical assumptions, such as the willingness of parents to abandon their children, are patently absurd and, ominously, both the existing security force at the facility as well as an independent review by an outside consultant concur that the Indian Point facilities' containment structures, reactor vessels, spent fuel storage areas, control rooms, and electrical switching equipment are all vulnerable to terrorist attack. Because Indian Point is located in the immediate vicinity of New York City as well as the most populous portions of the State of Connecticut, it is clear that the 20 million people who reside and work within a 50 mile radius of the plant would be directly and immediately threatened by any terrorist action aimed at Indian point. A successful attack on these structures would have a catastrophic effect on the region's human population, environment, and economy. Based on this threat, Petitioner requests, among other things, that the United States Nuclear Regulatory Commission suspend the operating licenses for all units until and unless the licensee can demonstrate that the facility is protected against plausible attack scenarios and citizens are protected if an attack should be successful.
II. The Interests of Petitioner Petitioner, Richard Blumenthal, Attorney General of Connecticut, ("Petitioner"), resides in Greenwich, Connecticut and brings this petition in his capacity as the chief legal officer representing the legal interests of Connecticut residents. It is important to note that the emergency planning area for Indian Point includes plans covering both a 10-mile radius 3
emergency planning zone ("EPZ") and a separate 50-mile radius ingestion pathway EPZ. The 50-mile radius EPZ includes substantial portions of the State of Connecticut, including its largest city, Bridgeport, and its most populous county, Fairfield.
Therefore, because the Indian Point EPZ plans affect significant portions of the State of Connecticut, including Fairfield County, Petitioner, individually, and in his capacity as chief legal officer of the state, is affected and aggrieved by the continued operation of Indian Point without the specific security and evacuation measures identified in this request.
III. Authority of the NRC.
The Nuclear Regulatory Commission ("NRC") has significant authority in matters pertaining to security and emergency planning. Pursuant to federal law and regulations, a radiological emergency preparedness plan must be created primarily to provide evacuation routes and other emergency plans in the event of a release from a nuclear generating facility.
Emergency evacuation plans for nuclear facilities are governed by regulations and guidance documents promulgated primarily by the NRC but also by the Federal Emergency Management Agency ("FEMA"), because the NRC will defer, in large measure, to the determinations of FEMA for certain emergency management issues. 1 The initial requirement for an emergency
'While NRC has primary responsibility over nuclear safety issues generally, Executive Order Number 12148 grants FEMA the responsibility to coordinate and review state and local evacuation plans. Further, FEMA regulation 44 CFR § 350 incorporates and adds to the requirements of guidance document "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG 0654/FEMA REP-1, Rev. 1, March 1987.
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response plan, specifically, 10 CFR § 50.47, mandates the existence of an evacuation plan as a condition of the license granted to the private operator of each nuclear power plant.
Specifically, 10 CFR § 50.33 requires, as part of an application to construct a nuclear power station, appropriate response plans regarding the "Emergency Planning Zone" or EPZ.
Further, 10 CFR § 50.47 states that no operation license can be issued without a finding by the NRC that "adequate protective measures can and will be taken in the event of a radiological emergency." This same section continues that "NRC will base its finding on a review of the Federal Emergency Management Agency (FEMA) findings" regarding emergency plans.2 However, 10 CFR § 50.47 contains several subsections detailing certain specific elements.
These include 10 CFR § 50.47 (7) regarding dissemination of information, (8) a requirement for 2The regulatory basis for radiological emergency preparedness plans is the "planning and preparedness standards and related criteria contained in NUREG-0654/FEMA-REP-1, Rev. 1."
44 CFR § 3501.13(a) citing 44 CFR § 350.5(a). The Planning Standards include a series of "Evaluation Criteria" requirements for the licensee, and for the State and local governments.
The "overall objective of the emergency response plan is to provide dose savings (and in some cases immediate life savings) for a spectrum of accidents." NUREG-0654/FEMA REP-1, Rev. 1 at 6. To reach this objective, NUREG 0654 FEMA REP-1, Rev. 1 requires that the criteria be met by each REPP, noting that "it is important that the means by which all criteria are met be clearly set forth in the plans" and that the plans address "the substance of all criteria." Emphasis added. NUREG-0654/FEMA Rep-1 at 29.
A key standard that must be met in order for the REPP to "adequately protect public health and safety" is standard 10, which requires that A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
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"adequate emergency facilities, and (10) "protective actions" including evacuation and sheltering for the public and emergency workers. As will be discussed below, there are obvious and material failures in the Indian Point REPP regarding the elements described above, both with regard to the requirement found in 10 CFR § 50.47 and in the regulations of FEMA which support the findings upon which the NRC bases its ultimate conclusions.3 IV. Indian Point.
The Indian Point Energy Center ("Indian Point") is located in the Town of Buchanan, New York, and currently includes two actively operating nuclear reactors. Indian Point is owned by Entergy Nuclear Northeast, a licensee of the NRC. Indian Point is located in one of the most densely populated regions of the United States.
As described in a recent publication of the United States General Accounting Office (GAO") submitted as testimony before the Subcommittee on National Security, Emerging Threats and International Relations on March 10, 2003, ("GAO Report"), to this day there are serious concerns regarding "problems in emergency preparedness [that] remain after being repeatedly identified as needing attention." (GAO Report, pp. 14-15.)
This very sobering report documents how, beginning in 2001, a previous report by the GAO noted that "NRC had identified a number of emergency preparedness weaknesses at Indian Point 2 that had gone largely uncorrected. For example, in 1998 and again in 1999, NRC 44 CFR § 350.5(a)(10).
3 In 10 CFR § 50.47, NRC states not only that it relies on the FEMA findings, but that it establishes a presumption in favor of then.
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identified several communication weaknesses, including delays in activating the pagers used to alert the plant's staff about an emergency." (GAO Report. 3.)
Apparently, the plant's owners made some moves to adjust matters but, "according to an April, 2001 NRC inspection report, the actions were not fully effective.... NRC found that critical emergency response personnel were not notified in a timely manner, which delayed the staffing and operation of the on-site emergency response facility." (Id.)
The GAO's testimony continued with an exhaustive discussion of the history of emergency response failures at Indian Point and concluded as follows:
In reviewing NRC's reports on its on-site inspections and evaluations of the plant's emergency preparedness exercises or drills completed since we issued our 2001 report, we found that the facility's emergency preparedness program has continued to experience problems or weaknesses. For example, NRC reported that, in an emergency exercise conducted last fall, the facility gave out unclear information about the release of radioactive materials, which also happened during the February 2000 event. In addition, NRC reported that several actions to correct previously identified weaknesses had not been completed. For example, NRC noted that the timely and accurate dissemination of information was identified as a weakness in the fall 2002 exercise and had been documented previously in drill critique and condition reports.
(GAO Report, p. 12.)
In sum, the independent review by the GAO clearly establishes three things. The first is that Indian Point has a documented history of emergency preparedness failures going back several years. The second is that NRC is aware of these problems and has insisted on their being corrected. The last is that, in large measure, the problems have not been corrected.
Consequently, it is not surprising that the testimony of the GAO concludes that concerns remain.
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4 V. The NRC Has Broad Discretionary Powers to Order and Implement Petitioner's Requests.
Section 2.206(a) of Title 10, CFR, states that "[a]ny person may file a request to institute a proceeding pursuant to § 2.202 to modify, suspend, or revoke a license, or for any other action as may be proper." The Petitioner submits this petition identifying the threat of a terrorist attack on the Indian Point facility as a new, site-specific, hazardous condition that is larger and more dangerous than previously considered during the initial licensing of Indian Point Units 2 and 3.
Finally, pursuant to 10 CFR § 2.202(a), the Commission has authority to "institute a proceeding to modify, suspend or revoke a license or to take such actions as may be proper." In upholding its duty to protect the public, the environment, and property, the NRC has broad discretionary powers to grant Petitioner's requests. Further, pursuant to 10 CFR § 2.206, a petitioner may submit a request to suspend the license of a commercial nuclear reactor if such request properly "set[s] forth the facts that constitute the basis for [this] request," and properly identifies "the potentially hazardous conditions" as required by 10 CFR § 2.202(a)(1),
specifically, in this case, the manifest failures of the emergency response plans and the failure properly to secure the facility from the threat of a terrorist attack. Ultimately, Section 161 (b) of the Atomic Energy Act empowers the Commission to "establish rule[s], regulation~s], or order[s]" to "protect health or to minimize danger to life or property." 4 The NRC's authority to protect the public 4 42 U.S.C § 2201(b), (1) 8
... cannot be read simply to permit the Commission to provide adequate protection; another section of the Act "requires" the Commission to do that much.
We therefore must view section 161 as a grant of authority to the Commission to provide a measure of safety above and beyond what is "adequate." The exercise of this authority is entirely discretionary. If the Commission wishes to do so, it may order power plants already satisfying the standard of adequate protection to take additional safety precautions. 5 In addition, the Code of Federal Regulations, in Title 10, Sections 2.200, 2.204, 2.206, and 73.55, as well as other authority, authorizes the NRC to take the specific actions requested herein.
VI. Critical New Information Constituting the Basis for This Request.
Background
As is made clear by the regulations of the NRC, a viable and effective emergency response plan is a fundamental necessity for legal operation of a licensed commercial nuclear power~facility in the United States. 10 CFR § 50.47. Without such a plan, it is illogical and illegal to continue to operate such a power station.
The Indian Point REPP is fatally deficient. It lacks critical data and much of what it has is outdated. Furthermore, key assumptions about the transportation network and basic human behavior are simply wrong.
The nature and severity of these deficiencies were highlighted in a recent, independent report requested by the State of New York and performed by James L. Witt Associates ("Witt Report"), released in draft on January 10, 2003 and finalized on March 7, 2003. This study identified numerous areas of concern regarding security at the nuclear power facility and with 5Union of ConcernedScientistsv. NRC, 824 F.2d 108, 110 (D.C. Cir. 1987) 9
regard to emergency response procedures generally. As a response to this study, and the concerns expressed by numerous state and county officials, the State of New York declined to certify the REPP as of January 31, 2003.6 In addition, a formerNRC staff member, Dr. Joe Hopenfeld, has reviewed recent testimony before the House Subcommittee on Emerging Threats and, in his letter, strongly criticizes the NRC's position 7 on the threat posed by terrorist attacks.
Finally, recent events associated with the war on terrorism and the invasion of Iraq have, as confirmed by the Department of Homeland Security, raised the probability of terrorist attacks on the energy and transportation infrastructure of the nation.
The specific deficiencies of the REPP are as follows.
A. THE INDIAN POINT REPP FAILS TO ADEQUATELY INFORM THE PUBLIC IN THE EVENT OF RADIOLOGICAL EMERGENCY AND RELIES UPON SELECTIVE RELEASE OF CRITICAL INFORMATION AND IRRATIONAL AND UNENFORCEABLE SECRECY.
Federal law requires notification to the public of a radiological release, particularly when protective action is required. Specifically, an emergency plan is required to include proper public notification procedures. 10 CFR § 50.47 (7). In addition, the plan needs to address means of maintaining order and control during evacuation. However, the Indian Point REPP fails to accomplish these two tasks because it bifurcates notice of evacuation. The REPP envisions a first, non-public notification of public school administrators. This, in effect, "secret notice" will 6 Subsequent to New York's decision not to ratify the REPP, the Petitioner filed a petition on February 20, 2003 the
("FEMA Petition") before the Federal Emergency Management Agency ("FEMA") requesting that FEMA also withdraw its approval of the REPP.
7 The NRC has most recently articulated its position regarding emergency planning and terrorist threats in ithe Director's Decision Under 10 CFR 2.206, Dckt Nos.50-003, 50-247 and 50-286 (Nov. 18, 2002) which states:
"The Petitioners are correct that the [design basis threat] did not consider a terrorist attack...."
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be counterproductive and will inevitably lead to confusion and loss of trust and public confidence.
Specifically, the REPP states that "school superintendents, college, university and private school administrators within the EPZ in accordance with evacuation procedures developed may evacuate prior to the announcement of a general evacuation." The obvious reason for this policy is to evacuate children first and hopefully avoid the mass confusion of large numbers of parents rushing to the schools before leaving themselves. However, it is equally obvious that this "secret notice" approach will lead to confusion, panic and chaos.
The basis for this conclusion lies in recent changes in communication technology. At the time that the nation's existing nuclear power plants were built, mostly in the 1960s and 1970s, sirens, radio, television and landline telephones were the only effective means of public communications. Therefore, the emergency plans for nuclear facilities based public notification on the use of loud alert sirens and radio and television announcements. No thought was given to the possibility that the public would have access to, and largely rely on, instantaneous and redundant private communication systems outside the control, or even influence, of public officials.
Now, however, the public plainly does have that access. As was evident on September I 11h 2001, cell phones, pagers, and the internet were immediately used by people at and around the affected areas to disseminate unofficial warnings to friends, family and the public. This created "information soup" regarding emergency efforts. If there is an emergency at Indian 11
Point, plant personnel and other individuals receiving advanced notice can be counted upon to immediately call spouses, other relatives, and friends to tell them to leave. Once word is out unofficially, it will spread virtually instantaneously. Attempts to control evacuation information through secrecy will fail, and will undermine confidence in the overall evacuation plan.
Not only does the REPP fail to address the "information soup" problem and suffer from the obvious deficiencies inherent in its "secret notice" approach, but the REPP also is flawed in its operational characteristics. This conclusion is not new. As the GAO Report states: "NRC's Office of the Inspector General also identified emergency preparedness issues, including the state's difficulties getting information about the emergency from [the plant's then owners] and the fact that English is a second language for many who lived within 10 miles of the plant."
(GAO Report, p. 8) Further, the Report noted that while NRC informed the company about various problems, "the company did not correct the weaknesses identified. For example, in 1998 and again in 1999, NRC identified problems with activating the pagers used to alert the plant's staff about an emergency, as well as other communication weaknesses. In 1999, NRC concluded that [the company] lacked the ability to detect and correct problems and determine their causes, resulting in weak oversight of the emergency preparedness program." Id. Even after this warning, problems in the communication of emergency information continued. Regarding the February 2000 event, "NRC found that [the company] did not activate its emergency operations facilities within the required 60 minutes, primarily because of the complex process used to page the emergency response staff."
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It is self-evident that a communications 'plan' that has demonstrated a track record of delay and confusion, that has been unable "to detect and correct problems," and that willfully disregards the impact of modem, private communications on emergency situations is deeply and fatally flawed. The only remaining question is whether this facility and its staff have the ability to ever identify and correct these persistent weaknesses or whether the entire process can be salvaged.
B. THE INDIAN POINT REPP FAILS TO ADDRESS VOLUNTARY EVACUATION AS REQUIRED BY NRC GUIDANCE DOCUMENTS In 1992, the NRC further refined and improved travel time estimates for nuclear power plant evacuation planning in Guidance Document NUREG/CR-483 1, "State of the Art in Evacuation Time Estimate Studies for Nuclear Power Plants." NUREG/CR-493 1 sets forth a series of issues that must be addressed in the basic methodology of evacuation time estimates. 8 It builds upon two evacuation planning documents issued by the NRC.9 NUIREG/CR-483 1, in its discussion of estimating the number of people to be evacuated, specifically addresses "shadow evacuation," which it defines as "voluntary evacuation" of those "who decide to evacuate without being advised to evacuate." NUREG/CR-4831 at 4. The research and history that lead to the identification of "shadow evacuation" as a phenomenon in 8 The evacuation estimates required for nuclear evacuation plans must "examine the sensitivity of evacuation times to key variables, including the nature and limits of transportation facilities in the affected area and other factors that may affect evacuation time, such as the public's use of public transportation or need for special transportation."
NUREG/CR4831 AT 1. NUREG/CR4831 addresses these "transportation analysis and ancillary concerns" required in an evacuation travel time estimate. NUREG/CR-483 1 at 1.
9 See, the joint NRC - FEMA document Criteriafor Preparationand Evaluation of RadiologicalEmergency Response Plans and Preparednessin Support of Nuclear Power Plants, NUREG/CR-NUREG/CR 1754.
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Ir I emergency planning is more fully discussed in the Witt Report, Section 5.2.3. These evacuees "can be individuals living within the planning zone but not within the sector(s) where evacuation has been advised, or those living outside, but near, the EPZ who may be responding to an evacuation order directed at people within the EPZ." Emphasis added. NUREG/CR-483 1 at 4.
NUREG/CR-483 1 identifies two activities that can be planned to address shadow evacuation: 1.
control voluntary evacuation traffic to avoid interference with other evacuating traffic; and 2.
include an "appropriate number of voluntary evacuees" in the traffic demand estimate.
NUREG/CR-4831 at 4.1 The REPP does not address "shadow evacuation." See Witt Report p. vi. "Shadow evacuation" is not mentioned, and from the descriptions of the computer model used, it is clear that "shadow evacuation" was not factored into the model. Accordingly, all calculations of evacuation times, road capacities, and other logistical concerns assume no additional usage or loads by those outside the zone who may decide to evacuate without either instruction or permission from authorities to do so.
This glaring omission in the REPP alone clearly violates the regulatory requirements of 10 CFR § 50.47 and has an immediate impact on the State of Connecticut because, on the one hand, that shadow evacuation will affect the predicted movement of evacuees into Connecticut 0 In addition to these suggestions to address "shadow evacuation," NlUREG/CR-483 1 also identifies "background traffic," which it defines as "vehicles in the EPZ during an evacuation but not associated with permanent residents, transients, or special facility populations," which, for example, would consist of "through-traffic on major intercity routes such as interstate highways." NUREG/CR483 1 at 4. NUREG/CR-483 I suggests that "background traffic" be addressed by "access control measures to direct through-traffic onto some alternative route outside the EPZ," as the preferred method, or if the traffic cannot be re-routed, it "must be considered part of the evacuating traffic."
NUREG/CR4831 at 4.
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and, on the other hand, no one can seriously doubt that, even though people in western Connecticut live more than 10 miles from the plant, there will be huge numbers of Connecticut citizens who will spontaneously evacuate from Fairfield County and add their numbers to the swell of nuclear refugees.
C. THE REPP FAILS TO ADDRESS FAMILY SEPARATION IN ITS ANALYSIS OF EVACUATION TIMES.
The REPP assumes that family members, particularly parents and school children, will be willingly separated in the event of evacuation. This presumption is contrary to everyday common sense and has a serious impact on evacuation timetables.
Specifically, Planning Standard J(10)(1) requires that the state and local governments' "plans to implement protective measures for the plume exposure pathway" include "time estimates for evacuation of various sectors and distances based on a dynamic analysis." NUREG 0654/FEMA REP 1, Rev. 1 at 63. The "dynamic analysis" must require known behavioral responses of the population to be evacuated if the estimates are to be consistent with federal regulatory requirements. NUREG 0654/FEMA REP 1, Rev. 1 at 4-1 16. The requirements for such an analysis require that Distribution functions for notification of the various categories of the evacuee population shall be developed. The distribution functions for the action stages after notification predict what fraction of the population will complete a particular action within the given span of time. There are separate distributions for auto-owning households, school population, and transit dependent populations. These distribution functions can be constructed in a variety of ways, depending greatly on the kinds of data available for the actual site being studied. The previously developed conditional distributions are combined to develop the time distribution for the various population segments departing their home or other facility from which they are being evacuated.
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I Emphasis added, NUREG 0654/FEMA REP 1, Rev. 1 at 4-8. Thus, a logical, thorough and complete analysis of the information known about population is necessary for the REPP to meet the legal requirement to "adequately protect the public health and safety." 44 CFR § 350.5(b).
The Indian Point REPP fails to provide this type of analysis. The most glaring example of this deficiency is that the REPP blithely assumes that school children and their families would evacuate separately, and at the same time presumes that families would leave as one unit and utilize only one family car. In evacuation scenarios that take place during school days, these two situations contradict each other. When people decide to get their children before evacuating, this will obviously throw off the planned evacuation timetable. The REPP time estimates analysis also fails to address the situation where parents may have children in multiple schools, which may have different designated reception centers for each child.
There is a larger behavioral problem, however. The evacuation plan calls for separation of school children from their parents in the event of a radiological release that requires evacuation. This will not happen. It defies explanation that plan preparers believe that parents will calmly leave their children in school or infants with daycare providers and climb into their private cars and drive to a designated disaster relocation area. What will happen is that people will seek to reunite prior to evacuation despite anything that governmental authorities try to do to stop them.
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The failure properly to account for family evacuation behavior renders the "dynamic analysis" of travel times useless. The current REPP, therefore, is deficient on its face and does not meet the requirements of 10 CFR § 50.47.
D. THE INDIAN POINT REPP FAILS TO MEET THE REQUIREMENTS FOR PROTECTION OF FOODSTUFFS AND DRINKING WATER IN THE 50 MILE INGESTION EXPOSURE PATHWAY EPZ.
As noted in 10 CFR § 50.47, the "plans for the ingestion pathway shall focus on such actions as are appropriate to protect the food ingestion pathway." As previously noted, NRC defers, in large measure, to the determinations of FEMA in reviewing emergency preparedness plans. FEMA, in turn, requires each REPP to address contamination of the food and water supply in the fifty mile EPZ. Planning Standard J(1 1) requires each State to Specify the protective measures to be used for the ingestion pathway, including the methods for protecting the public from consumption of contaminated foodstuffs.... The plan shall identify procedures for detecting contamination, for estimating the dose commitment consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment, decontamination, processing, decay, product diversion, and preservation.
NUREG 0654/FEMA REP 1, Rev. 1 at 64. The New York State REPP provides for the water sampling procedures to be carried out by various New York agencies. State REPP at H-8. These efforts include sampling of "open reservoirs downwind within the EPZ and the tap water for water supplies using these reservoirs" by the Bureau of Public Water Supply in the Division of Environmental Health, New York Department of Health. State REPP at H-8. This issue vitally affects Connecticut citizens because there are vital water supply sources in Connecticut, and 17
water supply sources in New York that supply water to nearby Connecticut municipalities, that are within the 50-mile ingestion pathway EPZ.
The New York REPP expressly acknowledges that immediately following a radiological release, it cannot meet the requirement for "protecting the public from consumption of contaminated foodstuffs" required by federal law. NUREG 0654/FEMA REP 1, Rev. 1 at 64.
The New York REPP acknowledges that the data from the sampling are "normally delayed from several hours to a few days" and are not usable in preliminary decision-making after a release of radiation. New York REPP at H-7. The New York REPP explicitly indicates that the State has limited capability for conducting area monitoring in the EPZ in a timely manner that will be usable in the initial assessment stages.
New York REPP at H-7.
The Indian Point REPP only summarily discusses food and water contamination from a radiological release at Indian Point, and fails to identify the procedures for the nearby New York counties to undertake with New York in addressing the contamination as required by federal law.
The FEMA regulations require the state to assume the primary role in addressing radiological contamination of foodstuffs or the water supply, and to specify to the local governments how it plans to do so. NUREG 0654/FEMA REP 1, Rev. 1 at 64. There has been no such effort in the Indian Point REPP, which does not indicate which New York agencies are to be contacted or how these contamination assessment process will work. The Indian Point REPP does not even contain the maps locating crops, farms or water treatment centers, and indicates that they will not be made available. NUREG 0654/FEMA REP 1, Rev. 1 at 64.
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The Indian Point REPP is short on specific details essential to a plan protecting the water and food supplies of numerous Connecticut residents. When FEMA reviewed the Interim Report's analysis of the failure of the Indian Point REPP to address contamination of the water supply, it succinctly summed up the problem. FEMA Region II said that the State needed to improve its efforts and better notify the nearby New York counties about what was expected in an emergency situation, recommending that the State work with the counties to clarify the water supply plans in event of contamination. Contaminated water supplies fall into the ingestion pathway category under which NYS assumes control of the coordination of the response from the counties. The State with support from the federal response will assure protection from this radiological pathway.
Inasmuch as the REPP fails to meet minimum FEMA requirements, it is also inconsistent with the requirements of 10 CFR § 50.47 and, obviously, plans that make no provisions at all regarding potential water and food contamination in Connecticut are unacceptable.
E. THE EVACULATION TRAVEL TIME ESTIMATES FOR THE INDIAN POINT REPP FAIL TO MEET THE REQUIREMENTS OF NUREG 0654/FEMA REP 1.
NUREG 0654 FEMA REP 1 requires that both the licensee and the State and local governments meet specific requirements for the travel time estimates. Planning Standard J(8),
"Protective Response," requires that each licensee's plan "contain time estimates for evacuation within the plume exposure EPZ" which shall be in accordance with "Appendix 4." NUREG 0654 FEMA/REP 1, Rev. 1 at 61. Planning Standard J(10)(1) similarly requires State and local governments to implement protective measures that include "time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various 19
conditions) for the plume exposure pathway (See Appendix 4.)." NUREG 0654/FEMA REP 1, Rev. 1 at 63. Appendix 4 sets forth a variety of factors that must be considered, at a minimum, and provides that evacuation travel time estimates "will be used by those emergency response personnel charged with recommending and deciding on protective actions" and therefore, "should be updated as local conditions change." NUREG 0654/FEMA REP 1, Rev. 1 at 4-1.
Thus, it is both the licensee's and the state and local governments' responsibility to make sure that travel time estimates meet the minimum legal requirements, and where necessary, are updated.
However, as noted in the Witt Report, the REPP has several material weaknesses in this regard. The REPP appears to be "based on the premise that people will comply with official government directions rather than acting in ... their best interest." (Report, p. vi) Further, the plans do not consider the effects of a terrorist attack, which could include simultaneous attacks on transportation infrastructure or other targets within the 10-mile or 50-mile radii. Unlike an accident, the purpose of a terrorist attack is to cause disruption and increase casualties.
Therefore, preparation for a terrorist attack requires much different contingency plans than preparation for an accident. Finally, no mention is made in the REPP of the current transportation capabilities of Interstates 95 and 84. Both of these major roads have suffered significant increases in average daily vehicle trips (ADVTs). "Congestion is endemic throughout the Coastal Corridor [area]. It is acute on the primary highways, Interstate Routes 1-95 and 84, and U.S. Route 1 and CT Route 15, and particularly acute on the [Connecticut] westerly portion of Interstate Route 95." Coastal CorridorTransportationInvestment Area Twenty Year 20
StrategicPlan For TransportationInvestment Area, Nov. 7, 2001, p. 6, prepared for the Connecticut Transportation Strategy Board by the Coastal Corridor Transportation Investment Area Board. This report continues: "When they can reach their destinations only by road, people are trapped in the congested conditions found there and can only contribute to that congestion when traveling." Id., p. 7. Even further, the report notes: "Poor or outdated engineering contributes to the inefficient movement of vehicles and gives rise to public safety concerns. Many of the Coastal Corridor [area] roadways were built neither to handle the volume of traffic that currently exists nor to accommodate the type of travel common today." Id.
The fact that people are 'trapped' on normal days on the very network of roads that the REPP envisions using for emergency evacuation of millions of people is an obvious issue of concern. Furthermore, ongoing major reconstruction of these roads, which further increases travel time, does not appear to have been factored into the REPP. Finally, the Witt Report points out that existing travel time estimates are based on 1990 Census data and more current information has not yet been factored into the REPP. Witt Report, Section 5.1. The available data shows that there have been material changes in demographics since 1990 and, thus, "[t]he fact that such large changes are present underscores the need for updated data - it is directly related to effective emergency preparedness and response.. . ." Id.
Finally, in this regard, it is noteworthy that Mr. John Wiltse, the State Director if the Connecticut Office of Emergency Management, in his March 10, 2003, testimony before the Congressional Subcommittee on Emerging Threats, recently said that "Urban emergency transportation management and evacuation planning is a serious issue and should be a national 21
priority post 9/11. What we would like to see developed are flexible, technology-based regional all-hazards traffic management plans ... ." As this comment makes clear, we do not now have these plans, and they are needed now, particularly for the nuclear power station located in the most populated part of the country.
F. THE REPP FAILS TO ADDRESS ADMINISTERING RADIOPROTECTIVE DRUGS TO THE GENERAL POPULATION.
The Protective Response Planning Standards require that the State and Local governments develop a plan to administer radioprotective drugs, such as potassium iodide
("KI"), to the general public. Planning Standard J(10)(f) requires State and local organizations' plans should include the method by which decisions by the State Health Department for administering radioprotective drugs to the general population are made during an emergency and the pre-determined conditions under which such drugs may be used by offsite emergency workers.
NUREG 0654/FEMA REP 1, Rev. 1 at 63.
Some experts believe that radioprotective drugs, such as potassium iodide ("KI"), may have a protective effect if taken properly for radioiodines. Westchester County REPP at I-4.
The Westchester County REPP expressly acknowledges the importance of radioprotective drugs, clearly stating that "a major protective action to be considered after a serious accident at a nuclear power facility involving the release of radioiodine is the use of a table iodine as a thyroid blocking agent to prevent thyroid uptake of radioiodines." Nevertheless, the REPP only makes emergency workers eligible for potassium iodide. Westchester County REPP at C-1, 3-71. The Westchester County REPP makes no such provisions for administering these drugs in accordance with federal law, except to members of rescue personnel exposed to the radiological release. The 22
language of the Westchester County REPP expressly defies the plain language of federal law, stating that "Distribution to the general population is not recommended." Westchester County REPP at C-1.
The Rockland County REPP similarly makes no provision for distribution to the general public. Instead it states that "KI will be available for emergency workers and captive populations" such as hospital and nursing home patients and staff and incarcerated populations.
Rockland County REPP at H-6. The Interim Report offers a discussion of the current status of the potassium iodide issue.11 Great care must be taken to assure that the public understands both the value and limitations of KI, but federal law requires development of methods for administering these drugs to the general public. While Westchester County officials have recently decided to opt into the Nuclear Regulatory Commission's offer to distribute free KI on a one time basis within 10-mile EPZ's, the Indian Point REPP has failed to meet this clear legal requirement of 44 CFR § 350.5 and supporting guidance documents.' 2 Of greater concern to Connecticut, neither the regulations nor the plan provide at all for the possibility that KI will be needed in Connecticut, beyond the 10 mile EPZ. Obviously, the need for KI use in Connecticut must be evaluated.
1" See Interim Report at 43-44.
12 Radiation Pills to Be Given Away, New York Times, June 1, 2002, at Section B, page 4.
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G. THE INDIAN POINT REPP DOES NOT ADEQUATELY ADDRESS THE POSSIBILITY OF A TERRORIST ATTACK.
Political, judicial, and military operations against suspected terrorist organizations continue and therefore civilian and military establishments within the United States remain plausible targets of future terrorist attack. Recent published reports specifically discuss the possibility that nuclear power stations and transportation infrastructure have been identified as specific targets of terrorist attack. See, New York Times, March 19, 2003, Bin Laden Chose 9/11 Targets, Al Qaeda Leader Says. As New York City and its surrounding areas, including southwestern Connecticut, are potential terrorist targets, so, too, are nearby industrial facilities that, if compromised, could cause devastation to the populace, environment, and economy. No other facility in the country poses as great a risk to as great a number of people as the Indian Point nuclear power plant. Among the factors making the Indian Point facility a plausible target for a terrorist attack is the facility's proximity to:
A population density of approximately 20 million people within 50 miles of the facility;' 3 Proximity of New York City and heavily populated areas such as Westchester County, New York and Fairfield County, Connecticut.
Proximity of water supply reservoirs serving New York and Connecticut.
Confluence of major air, sea, rail and road networks.
13 According to year 2000 U.S. Census Bureau data, 19,086,634 people live within the twenty-six counties that are within 50 miles of Indian Point, availableat http://wwA.census gov/index.lhtml.
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The essential premise of the REPP is that any radiological release from the facility would come from an accident in the reactor containment building. This assumption is based on a purposeful policy decision of the NRC. This assumption, however, needs to be reevaluated because it is erroneous and fatally compromises the REPP because it does not consider the impact of a deliberate (terrorist-caused) release which would have significantly different characteristics and effects.
Specifically, in a recent letter attached hereto and dated March 17, 2003 ("Hopenfeld Letter"), to the House Subcommittee on Emerging Threats, Dr. Joe Hopenfeld, a former employee of the NRC, reviewed the NRC's and Nuclear Energy Institute's (NEI) statements before the Subcommittee that there is no difference between an accident and a terrorist attack at a nuclear power plant. Dr. Hopenfeld concluded "These statements are misleading. They disregard important evidence that terrorist attacks pose substantially higher safety risks than ... other causes." (Hopenfeld Letter, p. 1, emphasis in original.) He further points out that past evaluations of radioactivity releases were based on "design basis accidents (DBAs)" but that
"[t]he assumed accident sequences following equipment failures bear no relation to terrorist initiated accident sequences." (Letter, p. 2) Dr. Hopenfeld adds that the licensing of nuclear power stations was based on safety analyses largely related to the ability to 'withstand a main steam line break without reactor core melt." (Letter, p. 3) Further, "[t]he amount of radioactivity release[d] prior to core melt will greatly depend on operators' actions." Id.
Consequently, if a terrorist attack succeeds in killing operators and/or breaching multiple steam 25
lines or other coolant infrastructure, then significantly more radioactivity will be released than is assumed by the NRC's existing studies.
This is not an idle concern. Since September 11, 2001, there has been a heightened awareness that nuclear facilities are at risk for terrorist attacks. President Bush, Office of Homeland Security Director Tom Ridge and Secretary of Defense Donald Rumsfeld have repeatedly warned the public about the possibility of such an attack, which could be inflicted by an airplane. In his State of the Union Address, President Bush noted that "we have found diagrams of American nuclear power plants and water facilities, [and] detailed instructions for making chemical weapons." President George W. Bush, State of the Union Address (January 29, 2002). Such an attack might target the reactor containment building of a nuclear generating facility, but it might also target potentially more vulnerable targets, such as the spent fuel pools, that have considerably less structural protection. A recent article in the New York Times states that "A successful terrorist attack on a spent fuel storage pool at a large nuclear reactor could have consequences 'significantly worse that Chernobyl,"' citing a recent study by Princeton University. Study Warns Attack on Fuel CouldPose Serious Hazards, New York Times, Jan. 29, 2003. An attack on these non-containment building structures may result in the likelihood of a rapid radiation release because of their lack of even minimal radiological safety systems.
Furthermore, the essential purpose of a terrorist attack is to cause maximum damage and casualties. On September 11, 2001, multiple attacks on different targets occurred simultaneously, causing massive damage to buildings and loss of life. Official responses included shutting down transportation centers and roadways in New York City to permit 26
emergency personnel to reach the scene and also included shutting down the entire aviation system for an extended period in order to hinder the ability of other potential terrorists to carry out other attacks. The probability that, in the event of a deliberate attack, authorities would actually be required to shut down major roads and railways is not considered in the REPP. Even the most elementary police response to a terror attack, setting up roadblocks to catch escaping terrorists, would bring all evacuation to a halt, but that possibility is never discussed or considered in the REPP.
Finally, a terrorist attack could not only include the spent fuel pool (which is an easier target than a containment dome) but also nearby military or police facilities. Terrorist attacks of this nature have occurred around the world. The reason for this type of attack is that it scatters and confuses governmental response efforts, as well as causing casualties among emergency responders, all of which diminishes the effectiveness of overall governmental response. The REPP seems to assume that all local emergency service providers are fully available to respond and are not under fire themselves. In addition, often transportation systems such as major road networks are themselves the targets of secondary attack because they tend to be 'soft' targets and their destruction would prevent movement of security forces and medical and firefighting personnel. The REPP never considers the possibility that emergency personnel might be busy elsewhere, or under attack themselves, or that the evacuation routes may be partially or completely destroyed. In a post-September 1 l1th world, an 'emergency' plan that ignores these contingencies amounts to willful blindness.
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Because the reactors at Indian Point are operational, the licensee must extend full security measures to ensure protection of the control rooms and to guard against strikes that threaten the structural stability of the containment domes. While shutting down the reactors will not remove the need for such security, the reduction in threat would allow the licensee to focus its protective efforts on the more critical areas of the facility, especially the spent fuel storage area. The licensee would be able to shift some security personnel away from low risk areas, concentrating resources where they are most valuable and most likely to protect effectively against the deadliest attack.
H. Indian Point and NRC Personnel and Resources Confront Dual Challenges When Ensuring Security At Operational Facility.
Currently, employees at Indian Point must ensure both the safe and stable generation of power and a heightened security environment. Simultaneously, NRC personnel are charged with overseeing the ordinary operations of the plant while also ensuring that nuclear plants like Indian Point are protected against foreseeable threats. Resources of both the agency and the licensee have been stretched thin by this double-tasking. Closing down reactor operations will reduce these expenditures, simplifying daily operations at Indian Point, thereby reducing the chances of an accident while allowing both the Commission and licensee to prioritize security measures.
I. Vulnerability of the Spent Fuel Storage Facility Terrorist action against the spent fuel storage facility could result in a catastrophic failure of the containment system. NRC has never established that the Indian Point spent fuel storage facility is secure against foreseeable attacks. Likewise, the Commission cannot be certain that 28
the structure of the storage facility is sufficiently sound to preclude the possibility of a spent fuel fire in the event of an airborne, land, or water based assault.
NRC has not properly evaluated the consequences of terrorist attack on the spent fuel storage area. In a study conducted by the NRC in October 2000, it stated that:
"the risk analysis in this study did not evaluate the potential consequences of a sabotage event that could directly cause off-site fission product dispersion, for example, a vehicle bomb driven into or otherwise significantly damaging the SFP
[Spent Fuel Pool], even after a zirconium fire was no longer possible.'" 4 During the course of normal operation, the presence of cooling water reduces heat produced by the decaying fuel rods and minimizes the potential for fire in the fuel cladding. A reduction of cooling water in the spent fuel pools could lead to a catastrophic release of radiation. As the water in the fuel pool is reduced the remaining water will heat up and evaporate. This could expose the zirconium cladding which surrounds the spent fuel rods to oxygen and steam, resulting in an exothermic reaction that will lead to a spent fuel rod assembly fire. This event would release deadly amounts of radiological material and toxic fumes. The NRC October 2000 report stated:
This reaction of zirconium and air, or zirconium and steam is exothermic (i.e.,
produces heat). The energy released from the reaction, combined with the fuel's decay energy, can cause the reaction to become self-sustaining and ignite the zirconium. The increase in heat from the oxidation reaction can also raise the temperature in adjacent fuel assemblies and propagate the oxidation reaction. The zirconium fire would result in a significant release of the spent fuel fission products which would be dispersed from the reactor site in the thermal plume from the zirconium fire. Consequence assessments have shown that a zirconium 4 NRC Report October, 2000 at 4-15.
29
fire could have significant latent health effects and resulted (sic) in numbers of early fatalities.' 5 A Department of Energy report indicates that such a fire would release considerable amounts of cesium-137, an isotope that accounted for most of the offsite radiation exposure from the 1986 Chernobyl accident. 16 Another report, authored by NRC, concludes that, in the event of a pool fire, approximately 100 percent of the pool's inventory of cesium would be released to the atmosphere.' 7 The emission of radioactive particles from a spent fuel pool accident would lead to horrific consequences. The NRC study stated that human fatalities within the first year of such an event "can be as large as for a severe reactor accident even if fuel has decayed several years."' 8 The radioactive fallout from this type of release could also make tens of thousands of acres of land uninhabitable.
An uncontrolled fuel rod fire in one pool could quickly cause fires in other pools where water loss is occurring. In the October 2000 report, the NRC stated that "[i]f the fuel handler fails to respond to the alarm or is unsuccessful in extinguishing the fire within the first 20 15NRC Report October, 2000 at 3-1 (internal citation omitted).
16 See US Department of Energy, Health and Environmental Consequences of the Chernobyl Nuclear Power Plant Accident. DOE/ER-0332 (Washington, DC: DOE. June 1987).
17 See V L Sailor et al, Severe Accidents in Spent Fuel Pools in Support of Generic Safety Issue 82. NUREG/CR-4982 (Washington, DC: NRC, July 1987).
18 See NRC Report October, 2000 at 3-34.
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minutes, the staff assumes that the SSP cooling system will be significantly damaged and cannot be repaired."19 In addressing catastrophic events such as an earthquake, the report stated that the spent fuel pools "are also subject to unpredictable changes as a result of the severe seismic, cask drop and possibly other dynamic events which could rapidly drain the pool." A terrorist attack is one such dynamic event.
The spent fuel storage buildings at Indian Point are not capable of withstanding a terrorist attack. The roofs are "made partly out of pretty insubstantial metal, like sheet metal," according to the Nuclear Energy Institute. 2 0 This construction, coupled with relatively thin walls, is insufficient to protect against large vehicles or medium sized aircraft. The storage facilities are highly vulnerable to a ground-based attack of only several individuals or to a car and/or truck bomb. Compromise of the storage facility could pose an immediate health threat to workers and residents within close proximity of the Indian Point facility since radiation levels in the spent fuel storage facility can be five times higher than radiation levels in the containment area.2 1 J. Defending the Indian Point Facility Against a Terrorist Attack Security forces at nuclear power plants have repeatedly failed to repel mock terrorist attackers. In NRC-recognized drills intended to test the ability of plants to defend against land 19 See NRC Report October, 2000 at 3-16.
20 See Vibeke Laroi, Spent Nuclear FuelPools Seem Vulnerable To Attack, REUTERS (Nov. 4, 2001).
21 Based on calculations assuming that there are 15 times as many cores in the spent fuel storage area as in the containment area.
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based terrorist attacks, the nuclear industry has repeatedly failed to stop mock terrorist assaults from reaching the secure area of the plant and wreaking simulated damage that would, in a real situation, result in a core meltdown. The NRC reveals that 33 of the 68 facilities failed to repel small groups of mock intruders whose weapons, explosives, and tactics are severely limited. 22 In response to this problem, Paul Leventhal, founder of the Nuclear Control Institute,2 3 stated:
The security guards at half the nuclear power plants in the United States have failed to repel mock terrorist attacks against safety systems designed to prevent a reactor meltdown. These are so-called "force-on-force" exercises supervised by the Nuclear Regulatory Commission. The NRC refuses to take enforcement action in response to the failures, and is in the process of weakening the rules of the game in response to industry complaints. Sabotage of nuclear power plants may be the greatest domestic vulnerability in the United States today. This is the time to strengthen, not weaken, nuclear regulation. 2 4 K Illness and Fatality Data A study performed by NRC estimates that a terrorist attack on the Indian Point Unit 2 reactor that leads to a meltdown would cause "46,000 Peak Early Fatalities, 141,000 Peak Early Injuries, [and] 13,000 Peak Deaths from cancer." 2 5 A meltdown of the Indian Point Unit 3 reactors would cause "50,000 Peak Early Fatalities, 167,000 Peak Early Injuries, [and] 14,000 Peak Deaths from cancer." 26 22 Douglas Pasternak, A Nuclear Nightmare, U.S. WORLD & NEWS REPORT (September 17,2001), available at www.nci.org/01/09/09-3.htm.
23 The Nuclear Control Institute (NCI) is a non-partisan and non-profit Washington, D.C. based, independent research and advocacy center specializing in problems of nuclear proliferation.
24 Paul L. Leventhal, Commencement Address to the Class of 2001 at Franklin & Marshall College (May 13, 2001).
25 Id.
26 Id.
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Loss of life and long term illnesses will be exacerbated by the near-impossibility of evacuating the 22 million people who live within the 50 mile radius surrounding Indian Point.
Following the 1979 accident at Three Mile Island, then Director of NRC's Office of State Programs testified that a similar accident at Indian Point would have had far more drastic consequences:
Everybody says what a terrible situation we had at Three Mile Island, and I agree, but can you imagine what it would have been if it had been at Indian Point? It would have calamitous. You would have had dozens, hundred of people killed perhaps trying to get out of the place, because the roads are, you know, they're North-South roads basically and. ..there are narrow old bridges, one of the oldest bridges across the Hudson, the Bear Mountain Bridge, is a two-lane bridge. ..It's just a ridiculous place.2 7 L. Economic Loss Data This same NRC study reveals that a terrorist attack on the Indian Point Unit 2 or 3 reactors that leads to a meltdown would cause $274 billion (1982 dollars)229in property damage,2 and $314 billion (1982 dollars) in property damage respectively.29 In terms of 2000 dollars, property damage from a Unit 2 meltdown would be estimated conservatively at $500.5 billion, and property damage from a Unit 3 meltdown would be estimated conservatively at $573.5 billion -- figures based solely on inflation without factoring the substantial rise in metropolitan area real estate values.3 0 Data from the New York State Office of Real Property Services show 27 At Indian Pt, A History of Nuclear Power, Problems And Controversy, N.Y. TIMES (May 6, 1983).
28 Sandia Labs, NRC, Calculation of Reactor Accident Consequences ( 1982).
29 Id.
30 See The Inflation Calculator, available at http://www.westegg.com/inflation/ (based on increases m the Consumer Price Index as of Nov. 7, 2001).
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that property values in Westchester County, and NY state in general, have increased four-fold since 1982.31 Compounding this economic disaster would be the tremendous loss of both personal and corporate equity, and the loss resulting from uninsured and unrecoverable defaults on mortgage loans resulting from property loss.
M. Environmental Consequences The potential dispersal of radiological contaminants into the water, atmosphere, and on land, would cause extensive and irreversible environmental damage. The dispersal of radiological contaminants is dependent on their physical and chemical properties. Some particles would be suspended or dissolved in water, contaminating drinking water supplies. The consumption of these suspended particles would adversely affect the health of aquatic life. Some radioactive isotopes are known to bio-accumulate in the tissues and organs of wildlife, thereby leading to systemic contamination of the food chain and further injury to humans. As some of the radioactive particles fall out of suspension and settle, water supply reservoirs relied upon by Connecticut residents would become contaminated.
The REPP is flawed because it is based on erroneous assumptions. Therefore, the REPP is inadequate in providing protection to the public. The assumptions in the REPP ignore the possibility of an intentional act of terrorism or sabotage, a meltdown event involving Units Two or Three, a radiological release from the spent fuel storage area, a spent fuel rod fire, or the 31 See New York State Office of Real Property Services, Exemptions From Real Property Taxation In New York State (1982 & 1999 reports), availableat http://www.orps state.ny.us/.
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possibility of an explosion at the Indian Point facility.3 2 A particularly disturbing assumption is that the effect of an accident "would almost certainly be contained within the reactor containment building." The fallacy of this assumption in the context of a terror attack is enough by itself to call into question the REPP.
Based on the inherent inadequacies of the REPP and its blindness of the new site-specific, hazardous condition posed by a terrorist threat, the REPP must be revoked. In the interim, the Indian Point facility should be temporarily shut down until and unless a realistic REPP can be developed, implemented, and tested.
VII. The NRC Has Broad Discretionary Powers to Order Petitioner's Requests.
Pursuant to 10 CFR § 2.202(a), the Commission has authority to "institute a proceeding to modify, suspend or revoke a license or to take such actions as may be proper." In upholding its duty to protect the public, environment, and property, the NRC has broad discretionary powers to grant Petitioners' requests.
Section 161 (b) of the Atomic Energy Act empowers the Commission to "establish rule[s], regulation[s], or order[s]" to "protect health or to minimize danger to life or property." 3 3 The NRC's authority to protect the public
... cannot be read simply to permit the Commission to provide adequate protection; another section of the Act "requires" the Commission to do that much.
We therefore must view section 161 as a grant of authority to the Commission to 32 Indian Point Radiological Emergency Preparedness Plan for Westchester County, Revision May, 2000, at I-3.
33 42 U.S.C. § 2201(b), (i) 35
provide a measure of safety above and beyond what is "adequate." The exercise of this authority is entirely discretionary. If the Commission wishes to do so, it may order power plants already satisfying the standard of adequate protection to take additional safety precautions. 3 4 In addition, the Code of Federal Regulations, in Title 10, Sections 2.200, 2.204, 2.206, and 73.55, as well as other authority, authorizes the NRC to take the specific actions requested herein.
VIII. The Actions Requested Are Necessary and Appropriate to Protect the Safety of the Twenty Million People Living in the Vicinity of Indian Point.
Petitioners have properly "set forth the facts that constitute the basis for [this] request" pursuant to 10 CFR § 2.206, and have properly identified "the potentially hazardous conditions" as required by 10 CFR § 2.202(a)(1), specifically the threat of a terrorist attack on the Indian Point'facility. The NRC should take immediate action in response to Petitioners' request.
The threat of terrorism on a scale of the September 1 1th attacks, and including assaults from the air or water, has not been previously considered in the licensing or design basis threat of the Indian Point facility. Therefore, this request is proper and demands NRC's immediate attention and action. The Atomic Energy Act "commands the NRC to ensure that any use or production of nuclear materials 'provide[s] adequate protection to the health or safety of the public."' 3 5 As of September 11, 2001, this duty has taken on a new dimension: the protection of the public from the threat of a major radiological release resulting from a terrorist attack. Given 34 Union of Concerned Scientists v. NRC, 824 F.2d 108, 110 (D.C. Cir. 1987).
35 Shoreham-WadingRiver Cent. Sch Dist. v US NRC, 931 F.2d 102, 106 (D.C. Cir. 1991) (citing 42 U.S.C. § 2232(a)).
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that NRC's "paramount responsibility [is] protection of the public health and safety and the environment," 36 the NRC should immediately order the actions requested here and more fully articulated below.
A. The NRC Should Order An Immediate, Temporary Suspension of Operations at Indian Point Units Two and Three, and Conduct a Full Review of The Facilities' Vulnerabilities, Security Measures and Evacuation Plans.
Title 10, Section 2.202 of the Code of Federal Regulations authorizes the NRC to "modify, suspend, or revoke a license, or [take] any other action as may be proper." 3 7 The NRC should immediately order the Indian Point licensee to suspend operations, revoke the operating license, or adopt other measures resulting in a temporary shutdown of Indian Point Unit Two and Unit Three, as per 10 CFR § 2.202, and to conduct a full review of the facility's vulnerabilities, security measures and evacuation plans for the following reasons:
First, as an operating facility, Indian Point is unnecessarily vulnerable to risks from takeover of or damage to control rooms. As long as the facility remains operational, the control rooms are a likely and vulnerable target for terrorist attack. Seizure or disability of the control rooms would dramatically increase the potential for the intentional or accidental destruction of the reactor core.
36 Conference Report at 47, 1982 U.S. Code Cong. & Admin.News at 3617.
37 10 C.F.R. § 2.202.
37
Second, an operating reactor produces power because of the heat of a controlled chain reaction. Thus, unlike a storage facility, an operating reactor is already at criticality as its default or normal operating mode. Therefore, an accident or attack at an operating reactor creates a significantly greater danger of catastrophic contamination, because the nuclear reaction is already occurring. The danger of a potential release of high-risk radio-nucleides would be reduced by a temporary de-powering and cold shut down of these reactors.
Third, the operating facility creates multiple vulnerable points in plant security. While shutting down the reactors will not remove the need for security, the reduction in threat would allow the licensee to focus its protective efforts on the more critical areas of the facility, especially the spent fuel storage area, thereby concentrating resources where they are most valuable and most likely to effectively protect against the deadliest attack.
Fourth, Indian Point and NRC personnel and resources confront dual challenges when ensuring security at an operational facility. Currently, employees at Indian Point must both ensure the safe and stable generation of power and create a heightened security environment.
Simultaneously, NRC personnel must oversee the ordinary operations of the plant - which is the only nuclear plant in the nation with a D rating (multiple/repetitive degraded) from the NRC -
while also ensuring protection against foreseeable threats. Resources of both the agency and the licensee are stretched thin by this double-tasking.
Finally, shutting down Indian Point's reactors creates a more secure environment. Spent fuel security has never been demonstrated at Indian Point. For all of these reasons, an 38
immediate, temporary shutdown of the operating reactors at Indian Point Units Two and Three is necessary and prudent.
B. The NRC Should Require the Licensee to Provide Information Documenting That Existing Security Measures Are Sufficient Against Plausible Threats of Terrorist Attacks.
Title 10, Section 2.204(a) of the Code of Federal Regulations authorizes the NRC to demand information from a licensee. The NRC should immediately demand that Entergy provide information documenting security measures which provide the Indian Point facility with protection against land, water, and airborne terrorist attacks. Such information must provide, at a minimum, sufficient basis for the Commission to determine that physical barriers, intrusion alarms, and other measures are in place to meet plausible threats, for the following reasons:
Actual threats against nuclear power plants have been documented and the Indian Point facility is a plausible target of future terrorist actions. However, as explained above, the design-basis threat for Indian Point did not consider the possibility of an intentional terrorist attack from the air or water, or a suicide attack from any front. Security forces at nuclear power plants have repeatedly failed to repel mock terrorist attackers. Moreover, Indian Point has a long history of safety problems related to the ability to respond to emergency situations. Entergy, the new owner and licensee of Indian Point, has a demonstrably poor security record and it is clear from Entergy's history of violations that its ability to protect the facility against a terrorist attack is questionable at best.
The NRC should immediately demand all information necessary to determine whether Indian Point is, or can be secured against a land-, air- or water-based terrorist attack.
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C. The NRC Should Immediately Modify The Operating License For Units Two And Three To Mandate, At Minimum, Security Measures Sufficient To Protect The Facility as Required by 10 CFR § 73.55.
As explained above, a successful attack on either of Indian Point's reactors or spent fuel storage facilities 38 would likely result in a massive release of radioactive materials into the surrounding towns and counties, quite possibly reaching into and contaminating New York City.
Such a release would cause hundreds of immediate fatalities close to the site and 100,000 or more latent cancer deaths farther downwind of the plant. Further, a major release would probably contaminate the drinking water supply for New York City and Westchester County, devastate the area's ecology, and render portions of the New York metropolitan area uninhabitable.
Faced with this catastrophic threat, the NRC should, at a minimum, take action to obtain the following security measures:
- 1. A permanent no-fly zone within 10 nautical miles of the Indian Point facility; 38 A terrorist action against the spent fuel storage facility could result in a catastrophic failure of the containment system. NRC has never established that the Indian Point spent fuel storage facility is secure against foreseeable attacks, nor can it be certain that the structure of the storage facility is sufficiently sound to preclude the possibility of a spent fuel fire in the event of an airborne, land, or water based assault. A likely result of an aircraft crashing into a spent fuel storage facility or of a truck bomb explosion would be a precipitous loss of cooling water in the spent fuel pools. A reduction of cooling water in the spent fuel pools could lead to a catastrophic release of radiation. As the water in the fuel pool is reduced the remaining water will heat up and evaporate. This could expose the zirconium cladding which surrounds the spent fuel rods to oxygen and steam, resulting in an exothermic reaction that will lead to a spent fuel rod assembly fire. This event would release deadly amounts of radiological material and toxic fumes leading to horrific consequences. Fallout from this type of release could make tens of thousands of acres of land uninhabitable. The spent fuel storage buildings at Indian Point are not capable of withstanding a terrorist attack. The spent fuel storage area is highly vulnerable to an air attack and mitigation and control of damage from such an attack is highly improbable.
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- 2. A defense and security system sufficient to protect and defend the no-fly zone; and
- 3. A defense and security system sufficient to protect the entire facility, including the containment and spent fuel storage buildings, control room and electricity equipment, from a land- or water-based terrorist attack.
These measures are necessary to comply with the requirements of 10 CFR § 73.55 regarding physical protection of licensed activities in nuclear power reactors against radiological sabotage.
D. The NRC Should Order the Revision of Entergy's Emergency Response Plan and Westchester County's Radiological Emergency Response Plan in Order to Account for Critical New Information and Prepare for Possible Terrorist Attacks.
The NRC should order the revision of Entergy's Emergency Response Plan and Westchester County's Radiological Emergency Response Plan in order to account and prepare for possible terrorist attacks. These reviews must contemplate not only the full range of realistic effects of a terrorist attack on the Indian Point facility, but a comprehensive response to multiple attacks in the region which may impair the efficient evacuation of the area. Examples of such attacks include destruction or blockage of the Tappan Zee Bridge, loss of power to passenger railroads, and other events which deny use of necessary infrastructure.
Westchester County's Radiological Emergency Preparedness Plan (REPP) was last revised in May of 2000 and does not address the site-specific, hazardous conditions of a sabotage 41
event or a terrorist attack at the Indian Point facility. 39 Moreover, the REPP does not address the likelihood of a spent fuel storage area release, or a spent fuel assembly fire. The REPP is flawed, as it is based on erroneous assumptions, and therefore, it must be found inadequate in providing protection to the public. The assumptions in the REPP ignore the possibility of an intentional act of terrorism or sabotage, a radiological release from the spent fuel storage area, a spent fuel rod fire, or the possibility of an explosion at the Indian Point facility. 4 0 The inadequacies of emergency response at the Indian Point facility were known and considered beginning decades ago, but no adequate action has been taken to resolve them. Based on the inherent inadequacies of the REPP and its blindness to the new site-specific, hazardous condition posed by a terrorist threat, the REPP must be revised.
39 Indian Point Radiological Emergency Preparedness Plan for Westchester County, Revision May, 2000.
40 Id. at 1-3, I-4.
42
CONCLUSION The NRC is confronted with a new challenge: how to protect the nation's most densely populated area and the environment from the threat of a terrorist attack on the Indian Point facility. While this may be a challenging and daunting task, the NRC must react quickly and in a determined manner. The temporary shutdown of the Indian Point facility will significantly reduce the potential catastrophic consequences if it experiences a terrorist attack. As the potential harm resulting from such an attack is reduced, the Indian Point facility becomes less of an attractive target to terrorists. Therefore, the temporary shutdown and increased protection of the Indian Point facility are the most logical actions to take to protect public health and minimize danger to life.
The NRC should order Entergy and local municipalities to review and update their emergency response plans in consideration and response to a terrorist threat since: (1) the threat of a large, highly coordinated terrorist attack has not been previously considered in the licensing or the design basis threat of the Indian Point facility; (2) it also has not been considered in the development of Indian Point's emergency response plan; and (3) it has not been considered in the Radiological Emergency Response Plans developed by local municipalities. If Entergy, any municipality, or FEMA or the NRC determines that it is infeasible to develop an Emergency Response Plan or a Radiological Emergency Preparedness Plan to meet this new threat, then the NRC should order the shutdown of the Indian Point facility until the new site-specific, hazardous condition is abated.
43
The Indian Point REPP is vitally important for the millions of people who live within the fifty mile EPZ surrounding the Indian Point nuclear generating facility. It sets forth a series of protective actions in response to a radiological release. Although the possibility of a radiological release at Indian Point may be small, the consequences could be enormous. Indian Point is unique amongst nuclear power plants in the United States because of the population density surrounding the facility and because of its proximity to important areas of Connecticut and New York City. Indian Point is only miles away from major portions of the reservoirs for the water supply system for over eight million residents. The largest cities in the states of New York and Connecticut are within the 50-mile EPZ. Fairfield County, Connecticut, the most populous county in the state, also lies largely within this 50-mile radius. As the Witt Report notes, almost 11.8 million people reside within the area controlled by the REPP. In addition to the public health implications, the effect of a terrorist attack or nuclear accident at this facility to the national economy is simply incalculable. It is imperative, therefore, that the Indian Point REPP meet all legal requirements to protect this population, should an unthinkable radiation release ever occur.
PET TI ATTORNEY GENERAL OF THE STATE OF CONNECTICUT 44
1 March 17, 2003 Staff Members Subcommittee on National Security, Emergency Threats, And International Relations
Dear Staff Members:
This letter concerns testimonies given by the Nuclear Regulatory Commission (NRC), the Nuclear Energy Institute (NEI) and Entergy Nuclear to the Subcommittee on National Security on March 10, 2003 on the assessment of public safety and security measures at nuclear power facilities. The NRC and the NEI stated in that testimony that nuclear plants present a hard target to terrorism and that there is no difference, in regard to public safety, between terrorist attacks and equipment failure from other causes. These statements are misleading. They disregard important evidence that terrorist attacks pose substantially higher safety risks than equipment from other causes.
The NRC and the NEI have overlooked the fact that the main steam lines and the control room are not protected by containment. An attack directed to these more vulnerable areas in a nuclear power plant could have devastating consequences. I have attached to this letter a more detailed demonstration of why this is so. The only reasonable conclusion is that component failures from terrorist attacks present higher safety risk than component failures from other causes and that nuclear power plants are indeed soft terrorist targets.
Despite the evidence, the NRC has steadfastly refused to draw a similar conclusion. It appears that the NRC is reluctant to impose on nuclear plants the cost burden of retrofitting the plants against terrorism.
The NRC's failure to realistically address the safety risk due to terrorist attack does not serve the public interest. The result has been to obscure or to avoid making an important policy choice. I see that choice as follows: Either we accept that continued operation of plants in populated areas, such as Indian Point, comes with higher risks than have been previously acknowledged; or 2) we shut down the threatened plants and bear the costs.
Sincerely, Dr. Joe Hopenfeld, former NRC staff member 1724 Yale PI.
Rockville, MD, 20850 1
Nuclear Plant Vulnerability to Terrorist Attacks
- 1. Why Pressurized Water Reactors (PWRs) are Soft Targets While the steam that drives the turbines is produced inside the reactor containment, the pipelines that deliver this steam to the turbine building are outside the containment. These steam lines (two to four per reactor) are about 2.5 ft in diameter with a design wall thickness of approximately 0.75-inch, but which actually have thinner walls because of degradation from corrosion and erosion. These steam lines are typically about 20 feet above ground, are unprotected, and can be easily recognized from outside the plant boundaries.
Laser-aimed shoulder fired missiles and other readily available terrorist weapons, as well as small aircraft loaded with high-energy explosives, can easily destroy the unprotected, relatively thin walls of the main steam line pipes. Destruction of the pipeline walls would cause instantaneous steam depressurization of the secondary side of the steam generators (SG). The depressurization of the secondary side of the typically degraded SG tubes and the attendant vibrations would rupture a large number of the 2604 to 15,531 SG tubes which contain high-pressure radioactive water on the other (reactor cooling system) side of the tubes.
The result would be a cataclysmic common cause/common mode steam generator tube failure-causing the radioactive reactor cooling water to blow out of the broken steam lines directly to the environment. Eventually the cooling water would be depleted and the reactor core would be uncovered. This core melt would be followed by an extremely large direct and unfiltered offsite radioactivity release, especially if the attack had occurred at the end of a PWR plant fuel cycle when decay heat is greatest.
- 2. Why Damage to a plant from a terrorist attack is potentially more lethal than damage from other causes.
On March 10, 2003 the NRC stated to Congress that "Preliminary results from our vulnerability studies do not indicate an increased source term or quicker release from terrorists initiated events than is already addressed by the emergency planning basis required by NRC regulations."
The above statement is alarming because it reflects ignorance of how the radioactive source term was determined. Assumed equipment failure sequences, based on engineering judgement were used to determine radioactivity releases during design basis accidents (DBAs). Experience has shown that some of the se assumptions produced non-conservative results.
The assumed accident sequences following equipment failures bear no relation to terrorist initiated accident sequences. For example, a terrorist attack is much more likely to compromise the integrity of the control room and indeed could result in the death of one or more of the power 2
plant operators. Thus accident sequences following terrorist attacks probably would lead to a different sequence of events and could lead to a more lethal radioactivity release.
U.S. commercial nuclear PWR power plants were licensed on the basis that they could withstand a main steam line break without reactor core melt. Licensees justified their designs with analyses, which were based upon simplified assumptions, using crude manual calculations and simplistic computer analysis codes. Actual plant experience, known material aging, less than adequate available inspection techniques, and advanced analysis methodology, all indicate that following the depressurization event however, the primary to secondary pressure will exceed the specified design value by as much as I OOOpsi. This force would cause the tube sheet and the support plates to move relative to the tubes and further increase the potential for tube damage. If more than ten tubes were to be damaged the core will melt accompanying by a massive radioactivity release bypassing containment.
The amount of radioactivity release prior to core melt will greatly depend on operators' actions.
The operator has the extremely difficult (if not impossible) task, with the high residual heat level in the core, of reducing the reactor coolant system pressure to low levels. Existing plant PWR training simulators do not provide operators with meaningfiul training in handling steam line breaks because certain important parameters and transients that exist during steam line breaks are not accurately modeled in simulators. Nevertheless, without training or other verifiable basis, the NRC has assigned a 99.9% probability in accident analyses that reactor operators will be able to prevent core melt during main steam line breaks with fewer than ten simultaneous SG tube ruptures.
The NCR's Advisory Committee on Reactor Safety (ACRS) concluded in March 2001 (NUREG-1750) that the NRC staff does not have defensible technical positions on the most important issues associated with main steam line breaks for nuclear power plants. The source term used by the NRC even without a terrorist attack is highly questionable.
The number of SG tube failures caused by a terrorist attack on exposed exterior steam lines would exceed by many orders of magnitude the number of tube failures hypothesized by the NRC because operators could be disabled during the attack since the control room like the steam lines is also outside the containment.
Conclusions The main steam lines and the control room are vulnerable to attacks by small general aviation airplanes and shoulder fired missiles. Massive radioactive releases with catastrophic consequences especially in populated areas could follow such attacks.
The source term is not based on limiting calculations; it is based on theoretical models. The uncertainties of such modeling are much large when the radioactivity release resulted from a terrorist attack than if it would have had resulted from anticipated equipment failure.
3
Nuclear plants should not be allowed to operate in densely populated areas until they can be proven to withstand attacks by general aviation airplanes and shoulder missiles.
Related information can be obtained at the following URL:
http:/HwxNwv.theioumalnews.com/newsroom/062402/24steamttibes.html 4
2 A GAO NUCLEAR REGULATION jjijhjj i Highlights of GAO-0528Ta report to the Emergency Preparedness Issues at the Indian Point 2 Nuclear Power Plant Subcommittee on National Security, Emerging Threats and International Relations, Committee on Government Reform, House of Representatives Why GAO Did This Study What GAO Found After the September 11, 2001, In 2001, GAO reported that, over the years, NRC had identified a number of terrorist attacks, emergency emergency preparedness weaknesses at Indian Point 2 that had gone largely preparedness at nuclear power uncorrected. ConEd had some corrective actions underway before a 2000 plants has become of heightened concern. Currently, 104 event raised the possibility of a leak of radioactively contaminated water commercial nuclear power plants into the environment. ConEd took other actions to address problems during operate at 64 sites in 32 states and this event. According to NRC, more than a year later, the plant still had provide about 20 percent of the problems similar to those previously identified-particularly in the pager nation's electricity. In July 2001, system for activating emergency personnel. However, NRC, in commenting GAO reported on emergency on a draft of GAO's report, stated that ConEd's emergency preparedness preparedness at the Indian Point 2 program could protect the public. Four counties responsible for responding nuclear power plant in New York to a radiological emergency at Indian Point 2 had, with the state and ConEd, State (NuclearRegulation: developed a new form to better document the nature and seriousness of any ProgressMadein Emergency radioactive release and thus avoid the confusion that occurred during the Preparednessat Indian Point2, but February 2000 event. Because they are the first responders in any AdditionallmprovementsNeeded radiological emergency, county officials wanted NRC and FEMA to
[GAO-01-605, July 30,20011). This testimony discusses GAO's findings communicate more with them in nonemergency situations, in addition to and recommendations in that communicating through the states. However, NRC and FEMA primarily rely report and the progress the plant, on the states to communicate with local jurisdictions.
the Nuclear Regulatory Commission (NRC), and the Since GAO's 2001 report, NRC has found that emergency preparedness Federal Emergency Management weaknesses have continued. For example, NRC reported that, during an Agency (FEMA) have made in emergency exercise in the fall of 2002, the facility gave out unclear addressing these problems. GAO information about the release of radioactive materials, which had also also provides its thoughts on the happened during the February 2000 event. Similarly, in terms of findings of a soon-to-be-issued communicating with the surrounding jurisdictions, little has changed, report (the Witt report) on according to county officials. County officials told GAO that a emergency preparedness at Indian Point and the Millstone nuclear videoconference system-promised to ensure prompt meetings and better power plant in Connecticut, and communication between the plant's technical representatives and the the implications of that report for counties-had not been installed. In addition, NRC and FEMA continue to plants nationwide. work primarily with the states in nonemergency situations. Although they note that there are avenues for public participation, none of these is Since 2001, the Entergy exclusively for the county governments.
Corporation has assumed ownership of the Indian Point 2 GAO did not evaluate the draft Witt report or verify the accuracy of its plant from the Consolidated Edison findings. The draft Witt report is a much larger, more technical assessment Company of New York (ConEd). than the 2001 GAO report. While both reports point out difficulties in communications and planning inadequacies, the draft Witt report concludes that the current radiological response system and capabilities are not adequate to protect the public from an unacceptable dose of radiation in the event of a release from Indian Point, especially if the release is faster or larger than the release for which the programs are typically designed. GAO is aware that, in commenting on a draft of the Witt report, FEMA disagreed WWw.gao.gov/cgi-bln/getrpt?GAO-03 528.
with some of the issues raised but said the report highlights several issues To view the full report, including the scope worth considering to improve emergency preparedness in the communities and methodology, click on the link above. around Indian Point and nationwide. NRC concluded that the draft report For more information, contact Jim Wells at (202) 512-3841 or wellsj6agao gov. gives 'undue weight' to the impact of a terrorist attack.
Mr. Chairman and Members of the Subcommittee:
We are pleased to be here today to discuss emergency preparedness at operating commercial nuclear power plants. Twenty-four years ago, in March 1979, the accident at the Three Mile Island nuclear power plant in Pennsylvania created considerable alarm and uncertainty in the surrounding areas about the plant's safety and the adequacy of emergency planning. On the broader front, the American public focused not only on Three Mile Island but also on safety and emergency preparedness at nuclear power plants nationwide. With the September 11, 2001, terrorist attacks, public concern about the plants has increased again. Concerns have focused principally on ensuring the plants' physical security and then on emergency preparedness in case terrorists are successful in their attacks. The nation currently has 104 commercial nuclear power plants licensed to operate at 64 sites in 32 states. These plants provide about 20 percent of the nation's electricity.
To protect the public should a commercial nuclear power plant accidentally release radiation to the environment, the Nuclear Regulatory Commission (NRC) requires the plant owner/operator to prepare for NRC's approval a radiological emergency preparedness plan. This on-site plan describes what is to be done in an emergency, how it is to be done, and who is to do it. Among other things, the plan identifies the process for notifying and communicating with the operator's own personnel as well as with federal, state, and local agencies and the media during an emergency. The plan also identifies the circumstances and the actions-such as evacuating the local population-the plant owner would recommend that off-site officials take to protect the public. NRC conducts inspections to ensure that the plant owner can effectively implement the on-site plan. In addition, the Federal Emergency Management Agency (FEMA) is responsible for ensuring that state and local communities develop emergency preparedness plans to address the off-site effects of a radiological emergency. FEMA oversees the conduct of periodic exercises to determine whether the off-site response would adequately protect public health and safety.
I GA-03-528T Indian Point 2
My testimony today is grounded in a report we issued in July 2001 to the Chairman of the House Committee on Government Reform and to Representatives Gilman, Kelly, and Lowey on emergency preparedness at the Indian Point 2 plant in New York State.! The Indian Point facility is located within the Village of Buchanan in upper Westchester County, approximately 24 miles north of New York City along the east bank of the Hudson River. About 300,000 people live within 10 miles of the plant and millions more live in New York City and within 50 miles in Connecticut, New Jersey, New York, and Pennsylvania Concerns that nuclear power plants may be targets for terrorists and Indian Point's close proximity to these large populations have increased public interest in the adequacy of the plant's security and emergency preparedness-leading some to call for closing the plant. A draft report (the Witt report) commissioned by the Governor of New York questions the adequacy of emergency preparedness at Indian Point and raises broader issues about emergency preparedness at other nuclear power plants.2 In my testimony today, I will discuss the (1) findings and recommendations of our 2001 report on emergency preparedness at the Indian Point 2 plant and (2) subsequent progress made by the plant, NRC, and FEMA in addressing problems noted in our report.
You also asked for our thoughts on the findings of the draft Witt report and its potential implications for emergency planning at other facilities. To follow up on the progress made to address the problems we identified in 2001, we reviewed relevant NRC inspection reports prepared since our 2001 report and held discussions with officials of NRC, FEMA, and the four counties responsible for emergency preparedness in the surrounding areas. We did not conduct a comprehensive update of emergency preparedness at the Indian Point 2 plant nor verify the accuracy of the draft Witt report's findings and conclusions. We should also note that, since our 2001 report, the Entergy Corporation has assumed ownership of the facility from the Consolidated Edison Company of New York.
'NUCLEARREGULAM7OK ProgressAMade in EmergencyPreparednessat ndian Point2, butAdditional Improvements Needed, GA-O01-605 (Washington, D.C., July 30,2001).
2James Lee Witt Associates, LLC, Review ofEm ergencyPreparednessatIndianPointandMi~lstone [Draft]
(Washington, D.C., Jan. 10, 2003). The Witt report was commissioned by Governor Pataki to be a comprehensive and independent review of emergency preparedness in the areas around Indian Point and for that portion of New York State in proximity to the Millstone nuclear power plant in Connecticut.
2 GA-03-528T Indian Point 2
t In summary-In 2001, we reported that, over the years, NRC had identified a number of emergency preparedness weaknesses at Indian Point 2 that had gone largely uncorrected. For example, in 1998 and again in 1999, NRC identified several communication weaknesses, including delays in activating the pagers used to alert the plant's staff about an emergency. Consolidated Edison had some corrective actions under way before a February 2000 event raised the possibility that radioactively contaminated water would leak into the environments Consolidated Edison initiated other actions to address problems that occurred during this event. However, according to an April 2001 NRC inspection report, the actions were not fully effective. In evaluating Consolidated Edison's response to the February 2000 event, NRC found that critical emergency response personnel were not notified in a timely manner, which delayed the staffing and operation of the on-site emergency response facility. According to NRC, this delay occurred because the process to activate the pagers was complex and not well understood and Consolidated Edison had responded to the earlier problems identified without diagnosing their underlying causes. As a result, NRC found emergency preparedness problems similar to those it had identified before and during the event. Despite these weaknesses, NRC, in commenting on a draft of our report, expressed its view that Consolidated Edison's emergency preparedness program could protect the public.
We reported in 2001 that the four New York counties responsible for responding to a radiological emergency at Indian Point 2 had strengthened their emergency preparedness programs as a result of the lessons learned from the February 2000 event. These lessons included the need for better coordination and communications (1) between the counties in responding to a radiological 3In February 2000, a tube ruptured in a steam generator and Consolidated Edison temporarily shut down the plant because of the possibility that radioactively contaminated water could leak into the environment According to Consolidated Edison and NRC, the total amount of radioactivity released posed no threat.
3 GA-03-528T Indian Point 2
emergency and in providing the media with information and (2) between Consolidated Edison and the counties about the emergency and its potential impact on the public. We reported that Consolidated Edison had not clearly communicated with the state and counties about whether a radioactive release had occurred and, if so, its magnitude. Consolidated Edison reported that a release had occurred but posed no threat to the public, while county officials reported that no release had occurred. This contradictory information led to credibility problems with the media and the public. Consolidated Edison, the state, and the counties revised the plant's radiological emergency data form to more clearly show whether a release had occurred.
As we also reported, county officials suggested changes to improve communications among NRC, FEMA, and nonstate entities. In particular, county officials said that since they are responsible for radiological emergency preparedness for Indian Point 2, NRC and FEMA should communicate directly with them during nonemergency situations. In New York and 16 other states-where more than half of the nation's operating nuclear power plants are located-counties or other local governments are responsible for radiological preparedness, but NRC and FEMA communicated primarily with the states and relied on the states to communicate with local jurisdictions. In response, NRC said that meeting with local officials would require considerable resources, and FEMA said that some states limit its communications with local officials.
However, NRC had not assessed the costs and benefits of routinely meeting with local officials, and FEMA's method of communicating with the states had not effectively provided the four counties with information on various initiatives that would affect their programs. Since effective communication is critical to prepare for and respond to a radiological emergency, we therefore recommended that NRC and FEMA reassess their policies for communicating primarily with the state in those instances where other entities have a major role for responding to a radiological emergency.
4 GA-03-528T Indian Point 2
- Since our 2001 report, NRC inspection reports have continued to show emergency preparedness weaknesses. For example, NRC reported that, during an emergency exercise in the fall of 2002, the facility gave out unclear information about the release of radioactive materials, as it did during the February 2000 event.
Similarly, in terms of NRC and FEMA communicating with the surrounding jurisdictions, little has changed, according to county officials. County officials told us that a videoconference system-promised to ensure prompt meetings and better communication between the plant's technical representatives and the counties-had not been installed. During the February 2000 event, these representatives had arrived late at the counties' emergency operations centers.
NRC officials said that they meet with state officials concerning emergency preparedness and have instituted various initiatives to improve public communication, in which local officials can participate. FEMA officials told us that it would continue to work with state and local governments on emergency preparedness.
- The draft Witt report is a much larger, more technical assessment than our 2001 report. While both reports talk to difficulties in communications and planning inadequacies, the draft Witt report concludes that the current radiological response system and capabilities are not adequate to protect the public from an unacceptable dose of radiation in the event of a release from Indian Point, especially if the release is faster or larger than the release for which the programs are typically designed. We are aware that, in commenting on the draft of the Witt report, FEMA disagreed with some of the issues raised but said that the report does highlight several issues worth considering in order to improve preparedness levels in the communities around Indian Point and nationwide. NRC concluded that the report gives "undue weight" to the impact of a terrorist attack. The agency said that it saw no difference between emergency plans for releases caused by terrorist acts and those caused by equipment malfunctions.
5 GA-03-528T Indian Point 2
Background
Emergency plans for commercial nuclear power plants are intended to protect public health and safety whenever plant accidents cause radiation to be released to the environment. Since the 1979 accident at the Three Mile Island nuclear power plant, significantly more attention has been focused on emergency preparedness. For example, the NRC Authorization Act for fiscal year 1980 established a requirement for off-site emergency planning around nuclear power plants and allowed NRC to issue a nuclear plant operating license only if it determines that there is either a
- related state or local emergency preparedness plan that provides for responding to accidents at the specific plant and complies with NRC's emergency planning guidelines or
- state, local, or facility plan that provides reasonable assurance that public health and safety are not endangered by the plants' operation in the absence of a related state or local emergency preparedness plan.
In November 1980, NRC and FEMA published regulations that provided the criteria for radiological emergency plans. The regulations include emergency standards for on- and off-site safety and require that emergency plans be prepared to cover the population within a 10-mile radius of a commercial nuclear power plant. In addition, state plans must address measures necessary to deal with the potential for the ingestion of radioactively contaminated foods and water within a 50-mile radius. NRC and FEMA have supplemented the criteria several times since 1980. For example in July 1996, the agencies endorsed the prompt evacuation of the public within a 2-mile radius and about 5 miles downwind of the plant, rather than sheltering the public, in the event of a severe accident.
FEMA and the affected state and local governments within the 10-mile emergency planning zone conduct exercises at least every 2 years at each nuclear power plant site.
In addition, each state with a nuclear power plant must conduct an exercise within the 50-mile zone at least every 6 years. The exercises are to test the integrated capabilities of 6 GA-03-528T Indian Point 2
appropriate state and local government agencies, facility emergency personnel, and others to verify their capability to mobilize and respond if an accident occurs. Before the exercises, generally, FEMA and state officials not involved in them agree to the accident scenarios and the aspects of emergency preparedness that will be tested. In addition, NRC requires plants to conduct exercises of their on-site plans. According to NRC staff, the plants usually conduct their exercises as part of FEMA's biennial exercises.
Indian Point 2 is one of the 104 commercial nuclear power plants nationwide licensed to operate. The Indian Point site, which is called the Indian Point Energy Center, has one closed and two operating plants. The other operating plant is referred to as Indian Point 3.
In 2001, We Noted That Indian Point 2 Had Struggled to Resolve Emergency Preparedness Weaknesses Over the years, Consolidated Edison's efforts to improve emergency preparedness at Indian Point 2 were not completely successful, and the company experienced recurring weaknesses in its program, as we reported in July 2001. The four New York counties surrounding the plant made improvements in their emergency response programs but suggested better communication among NRC, FEMA, and nonstate entities in nonemergency situations.
Consolidated Edison Acted to Resolve Emergency Preparedness Weaknesses, but Its Actions Were Incomplete Beginning in 1996, NRC identified numerous weaknesses with the emergency preparedness program at Indian Point 2. NRC found, for example, that Consolidated Edison was not training its emergency response staff in accordance with required procedures, and some individuals had not taken the annual examination and/or participated in a drill or exercise within a 2-year period, as required. In response, Consolidated Edison disciplined the individuals responsible, developed an improved computer-based roster containing the current status of the training requirements for 7 GA-03-528T Indian Point 2
emergency response personnel, and began a process to distribute training modules to those employees before their qualifications expired.
NRC relied on Consolidated Edison to take corrective actions for other emergency preparedness problems and weaknesses. However, the company did not correct the weaknesses identified. For example, in 1998 and again in 1999, NRC identified problems with activating the pagers used to alert the plant's staff about an emergency, as well as other communication weaknesses. In 1999, NRC concluded that Consolidated Edison lacked the ability to detect and correct problems and determine their causes, resulting in weak oversight of the emergency preparedness program. In response, NRC staff said that they met with the company's managers to specifically discuss and express NRC's concerns.
Similarly, NRC identified emergency preparedness weaknesses when evaluating Indian Point 2's response to the February 2000 event. For example, NRC found that Consolidated Edison did not activate its emergency operations facilities within the required 60 minutes, primarily because of the complex process used to page the emergency response staff. This problem delayed the on-site response. NRC's Office of the Inspector General also identified emergency preparedness issues, including the state's difficulties getting information about the emergency from Consolidated Edison and the fact that English is a second language for many who lived within 10 miles of the plant. The Office of the Inspector General concluded, and NRC agreed, that recurring uncorrected weaknesses at Indian Point 2 had played a role in the company's response during the February 2000 event. However, NRC concluded that Consolidated Edison had taken the necessary steps to protect public health and safety.
Consolidated Edison subsequently evaluated its entire emergency preparedness program to determine the causes of the deficiencies and to develop corrective actions.
Consolidated Edison concluded that senior management did not pay sufficient attention to the emergency preparedness program or problems at Indian Point 2 because these problems were not viewed as a high priority warranting close attention and 8 GA-03-528T Indian Point 2
improvement. As a result, emergency preparedness had relatively low visibility, minimal direction, and inadequate resources. The company also found that (1) the emergency response organization had been stagnant, understaffed, poorly equipped, and consistently ineffective; (2) the emergency manager performed collateral and competing duties; and (3! for a time, a contractor held the manager's position. Furthermore, the professional development and continuing training of the emergency planning staff had been minimal. The company undertook initiatives to address the deficiencies noted.
Despite these initiatives, in April 2001, NRC reported that it had found problems similar to those previously identified at Indian Point 2. NRC again found weaknesses in communication and information dissemination. It also found that the utility's training program had not prevented the recurrence of these issues during on-site drills and that its actions to resolve other weaknesses had not been fully effective. NRC said that Consolidated Edison had identified the major issues in its business plan, which, if properly implemented, should improve emergency preparedness at the plant In commenting on a draft of our July 2001 report, NRC noted that its April 2001 inspection report concluded that Consolidated Edison's emergency preparedness program would provide reasonable assurance of protecting the public.
The Four Counties Strengthened Their Emergencv Preparedness Programs but Suggested Better Communication Among NRC. FEMA. and Nonstate Entities The need to improve communication between Consolidated Edison and the counties about the extent of the emergency and the potential impact on the public was highlighted during the February 2000 event. At that time, Consolidated Edison reported that a radioactive release had occurred but that it posed no danger to the public. County officials, on the other hand, reported that no release had occurred. This contradictory information led to credibility problems with the media and the public.
Before the emergency, the counties did not have a defined process to determine what information they needed and how they would present the information to the public. At 9 GA-03-528T Indian Point 2
the time of the February 2000 event, the Radiological Emergency Data Form that Consolidated Edison used to inform local jurisdictions provided for one of three choices about a release of radioactive materials: (1) no release (above technical specification limits), (2) a release to the atmosphere above technical specification limits, and (3) a release to a body of water (above technical specification limits). In April 2000, Consolidated Edison, in partnership with the state and counties, revised the form to ensure that all affected parties were "speaking with one voice" when providing the media and the public with information. The change to the form provided for one of four choices: (1) no release, (2) a release below federally approved operating limits (technical specifications) and whether it was to the atmosphere or to water, (3) a release above federally approved operating limits and whether to the atmosphere or to water, and (4) an unmonitored release requiring evaluation.
The counties had also taken some other actions to improve their radiological emergency programs. For example, all four counties agreed to activate their emergency operation centers at the "alert" level (the second lowest of four NRC classifications). Before the February 2000 event, the counties differed on when they would activate their centers, with one county activating its center at the alert level and the other three counties at the site-area emergency level (the next level above an alert). As a result, once the first county activated its center during the event, the media questioned why the other three counties had not done so. The counties also connected the 'Executive Hot Line," which linked the state, four counties, and governor, to the emergency operations facility at Indian Point 2 to establish and maintain real-time communications during an emergency.
In addition to these actions, county officials suggested to us in 2001 that other changes to improve communications among NRC, FEMA, and nonstate entities could be taken. In particular, county officials said that since they are responsible for radiological emergency preparedness for Indian Point 2, NRC and FEMA should communicate directly with them during nonemergency situations. Absent these direct communications, the counties were not privy to issues or initiatives that could affect their emergency preparedness programs.
10 GA-03-528T Indian Point 2
NRC staff tried to meet every 5 years with officials from all states that have operating nuclear power plants. NRC staff told us that they met with some states more frequently and that the requests to meet exceeded the agency's capability. Although NRC's policy was to meet at the state level, its staff believed that local officials had various options for meeting with NRC. For example, local officials could participate in the meetings held at least every 5 years with the states and could interact with NRC staff during public meetings, including those held annually for all plants. Emergency preparedness officials from the four counties around Indian Point 2 said that they did not believe that public meetings were the appropriate forums for government-to-government interactions.
Therefore, the counties suggested that NRC should meet with them at least annually.
According to NRC staff, routinely communicating with local officials has resource implications and involves tradeoffs with its other efforts, such as maintaining safety and enhancing the effectiveness and efficiency of operations. However, NRC, at the time of our review, had not assessed the costs and benefits of meeting with local officials nor the impact that such meetings might have.
FEMA generally implements its programs through the states and relies on the states to communicate relevant information to local jurisdictions. County officials responsible for emergency preparedness at Indian Point 2 identified instances in which this method of communicating with local jurisdictions had not been effective. For example, both New York State and county officials told us that the February 2000 event identified the need for flexibility in FEMA's off-site exercises. County officials said they responded to the 2000 event as they would have responded during FEMA's exercises, which are conducted to the general emergency level (the highest of NRC's action level classifications). Yet, they noted, the response for an alert like the one that occurred in 2000 is significantly different from the response needed during a general emergency, when a significant amount of radiation would be released from the plant site. State and county officials suggested that it would be more realistic to periodically conduct biennial exercises at the lower alert level, which, they noted (and NRC data confirmed), occur more frequently than a general emergency. In commenting on a draft of our report, FEMA said that the 11 GA-03-528T Indian Point 2
emergency plans for the four New York counties require them to conduct off-site monitoring and dose calculations at the alert level.
FEMA officials also noted that the agency's regulations allow state and local jurisdictions the flexibility to structure the exercise scenarios to spend more time at the alert level and less at the general emergency level. Nevertheless, county officials who participated in the exercises were not aware of the flexibility allowed by FEMA's regulations, in part because they did not participate in developing the exercise scenarios.
Emergency Preparedness Weaknesses at Indian Point 2 Have Continued In reviewing NRC's reports on its on-site inspections and evaluations of the plant's emergency preparedness exercises or drills completed since we issued our 2001 report, we found that the facility's emergency preparedness program has continued to experience problems or weaknesses. For example, NRC reported that, in an emergency exercise conducted last fall, the facility gave out unclear information about the release of radioactive materials, which also happened during the February 2000 event. In addition, NRC reported that several actions to correct previously identified weaknesses had not been completed. For example, NRC noted that the timely and accurate dissemination of information was identified as a weakness in the fall 2002 exercise and had been documented previously in drill critique and condition reports.
In addition, in our 2001 report, we noted that NRC's Office of the Inspector General found that, during the February 2000 event, the Indian Point plant's technical representatives did not arrive on time at the local counties' emergency operations centers. To help address this problem, Consolidated Edison said that it would install a videoconferencing system in the centers to enhance communications between the plant and the off-site officials. According to county officials, the videoconferencing system had not been installed as of February 2003.
12 GA-03-528T Indian Point 2
With respect to our 2001 recommendation that NRC and FEMA reassess their practices of primarily communicating with state officials during nonemergency situations, federal and local officials indicated that little has changed since our report. NRC officials told us that they did reassess their policy since our report was issued and determined that no changes were needed. According to FEMA officials, the agency will continue to work with state and local officials to carry out its emergency preparedness program but has not made any changes regarding nonemergency communication with state and local officials.
Given this history of inadequate efforts to address weaknesses in Indian Point 2's emergency preparedness program, we continue to believe that both NRC and the plant owner could benefit from being more vigilant in correcting problems as they are identified. In addition to improving the plant's program, a better track record in addressing these problems could go a long way in helping alleviate the heightened concerns in the surrounding communities about the plant's safety and preparedness for an emergency. Similarly, more frequent, direct communication by NRC and FEMA with officials of the surrounding counties could improve local emergency preparedness programs and, in turn, help local officials better communicate with their constituents about the plant's safety and preparedness for an emergency.
The Witt Report Raises Emergency Preparedness Issues at Indian Point and Other Nuclear Power Plants On August 1,2002, the Governor of New York announced that James Lee Witt Associates would conduct a comprehensive and independent review of emergency preparedness around the Indian Point facility and for that portion of New York State in proximity to the Millstone nuclear power plant in Waterford, Connecticut.4 According to Witt Associates, the review encompassed many related activities that were designed, when taken together, to shed light on whether the jurisdictions' existing plans and capabilities are sufficient to ensure the safety of the people of the state in the event of an accident at one of the plants, and how the existing plans and capabilities might be improved.
13 GA-03-528T Indian Point 2
According to Witt Associates, it has considered and incorporated public comments on a January 2003 draft of its report and plans to issue the final report this month.
We have not evaluated the Witt report or verified the accuracy of its findings and conclusions. We did note that the draft report identifies various issues-such as planning inadequacies; expected parental behavior that would compromise school evacuation; difficulties in communications; the use of outdated technologies; problems caused by spontaneous evacuation in a post September 11, 2001, environment; and a limited public education effort-that may warrant consideration at Indian Point and nationwide. The draft Witt report concludes that NRC and FEMA regulations need to be revised and updated. We understand that FEMA agreed, to an extent, in its review of the draft report According to the agency, the draft report raises a number of issues that should be considered for enhancing the level of preparedness in the communities surrounding the Indian Point facility, such as better public education, more training of off-site responders, and improved emergency communications. In addition, FEMA stated that some of these issues should be evaluated for their applicability nationwide.
However, FEMA also said that a number of the issues raised in the draft report were not supported by its own exercise evaluations, plan reviews, and knowledge of the emergency preparedness program. According to NRC, the draft report gives 'undue weight" to the impact of a terrorist attack. The agency said that it saw no difference between emergency plans for releases caused by terrorist acts and those caused by equipment malfunctions.
In summary, Mr. Chairman, the post September 11, 2001, environment clearly presents new challenges for NRC and FEMA. While the public has always had considerable interest in the safety of nuclear power plants, the terrorist attacks have brought a level of focus and anxiety that may rival or exceed that caused by the Three Mile Island accident in 1979. NRC and the nuclear industry deserve credit for taking action to strengthen physical security as the result of a changing world, but we are still concerned that, as shown in this hearing today, problems in emergency preparedness remain after being 4Mr. Witt is a former FEMA Director.
14 GA-03-528T Indian Point 2
repeatedly identified as needing attention. Mr. Chairman, GAO is currently conducting reviews of physical security at selected nuclear power plants and is looking in-depth at safety issues at the Davis-Besse plant in Ohio. We plan to report the results of our work later this year.
Mr. Chairman, this concludes our prepared statement. We would be happy to respond to any questions that you or Members of the Subcommittee may have.
Contacts and Acknowledgments For further information about this testimony, please contact me at (202) 512-3841.
Raymond Smith, William Fenzel, Kenneth Lightner, William Lanouette, Jill Edelson, Heather Barker, and Addison Ricks also made key contributions to this statement.
(360317) 15 GA-03-528T Indian Point 2
3 Twenty-Year Strategic Plan for Transportation in the Coastal Corridor Transportation Investment Area November 7, 2001 Submitted to the Connecticut Transportation Strategy Board CoastalCorndor TransportatwonInvestment Area. Twenty-Year Strategic Plan (November 2001)
Coastal Corridor TIA Board Members Council of Governments of the Central Naugatuck Valley (COGCNV)
RPO Representative: Peter Dorpalen, Executive Director, COGCNV Alternate: Laurel Stegina, Senior Planner, COGCNV Public Representative: Calvin Vinal, Vice President of Community Development, Webster Bank Greater Bridgeport Regional Planning Agency (GBRPA)
RPO Representative: Honorable Karen Burnaska (co-chair), Selectman, Town of Monroe Alternate: James Wang, Executive Director, GBRPA Public Representative: Jeffrey J. O'Keefe, General Manager, Greater Bridgeport Transit Authority Alternate: James Wang, Executive Director, GBRPA Housatonic Valley Council of Elected Officials (HVCEO)
RPO Representative: Jonathon Chew, Executive Director, HVCEO Alternate: George Walker, Manager, Office Park Public Representative: Cheryl Reedy, Newspaper Executive Alternate: George Walker, Manager, Office Park South Central Regional Council of Governments (SCRCOG)
RPO Representative: Judy Gott, Executive Director, SCRCOG Alternate: Honorable William Dickinson, Mayor, Town of Wallingford Public Representative: Dan Lorimier, Connecticut Fund for the Environment South Western Regional Planning Agency (SWRPA)
RPO Representative: Honorable Robert F. Harrel, First Selectman, Town of Darien Alternate: Honorable Diane Farrell, First Selectman, Town of Westport Public Representative: Franklin Bloomer (co-chair), Greenwich Safe Cycling Alternate: Vincent DeMarco, Automotive Business Valley Regional Planning Agency (VRPA)
RPO Representative: Honorable Mark A. Lauretti, Mayor, City of Shelton Alternate: Honorable Marc J. Garofalo, Mayor, City of Derby Public Representative: Edward Houghton, Executive, Pitney Bowes Alternate: William Purcell, President, Greater Valley Chamber of Commerce At-Large Members Jim Cameron, Vice Chairman, Metro North Comm. Council Bruce Heyl, Principal, Fletcher-Thompson Denis K. Pope, Association of Commuter Rail Employees Martin Tristine, President, Logistec Conn. Inc.
At-Large Alternates Richard Carpenter, Retired Executive Director of SWRPA Joe McGee, Vice President, SACIA Ex-Officio Members Congressmen James Maloney representaed by Lewis Wallace Congressman Christopher Shays represented by Peter Barhydt Coastal CorridorTransportationInvestment Area TFventy-Year Strategic Plan (November 2001) i
TABLE OF CONTENTS Executive Summary Overview ............................................................. 1 Vision Statement ............................................................ 1I Movement of People ............................................................ 2 Commitment to Transit ............................................................. 2 Roads ................................................... .......... 2 Commuter and Intercity Rail ................. ........................................... 2 Bus Transit ............................................................. 2 Waterborne ............................................................. 3 Airborne....................................................................................................................3 Pedestrian and Bicycle Facilities ......................... .................................... 3 Movement of Goods ............................................................. 3 Rail ............................................................ 3 Trucks ............................................................ 3 Waterborne . ............................................................ 3 Land Use Issues ............................................................. 3 Funding Issues .............................................................. 4 Twenty-Year Strategic Plan for Transportation in the Coastal Corridor TIA
- 1. Purpose of the Plan .............................................................. 5
- 2. Development of the Plan ............................................................. 5
- 3. Maps of the Coastal Corridor TIA ............................................................ 6
- 4. Vision Statement ............................................................ 6
- 5. General Recommendations ............................................................ 6 Projects Outside the Scope of this Project ............................... .................. 6 Travel Forecasting by Mode, Origin, and Destination ............. ................... 7 Collaboration with Neighboring States ................................... 7....................7 Enhance North-South Connectivity.............................................................7 Improve Access to Airports . ............................................................ 7
- 6. Movement of People ............................................................ 7 Recommendation ............................................................. 8 Increase Commitment to Transit .............................................................. 8 A. Roads ............................................................ 9 Issues/Problems ............................................................. 9 Recommendations ............................................................ 9 Roadway Improvements ......................... .................................... 9 Transportation Systems Management Strategies ....................................... 10 B. Transportation Demand Management Strategies ............................................................ 11 Issues/Problems ............................................................ 11 Recommendations ............................................................ 11 C. Commuter and Intercity Rail ............................................................ 12 Issues/Problems ............................................................ 12 Recommendations................................................................................................... 13 Order New Rail Cars Immediately ............................................................. 13 Infrastructure ............................................................ 13 Stations ............................................................. 13 Expanded Service ............................................................ 14 Metro North Operating Agreement ............................................................ 14 D. Bus Transit ............................................................ 14 Issues/Problems ............................................................ 14 Recommendations................................................................................................... 15 Consolidation of Bus Services ............................................................ 15 Expanded Service ............................................................ 15 CoastalCorridorTransportationInvestment Area: Twenty-Year Strategic Plan (November 2001)
Job Access ......... 16 Marketing ......... 16 Miscellaneous ......... 16 E. Waterborne ......... 16 Issues/Problems .16 Recommendations................................................................................................ 17 F. Airborne .17 Issues/Problems .17 Recommendation .17 G. Pedestrian and Bicycle Facilities .17 Issues/Problems .17 Recommendations .18
- 6. Movement of Goods .18 Recommendation .19 A. Rail .19 Issues/Problems .19 Recommendations .19 B. Trucks .20 Issues/Problems .20 Recommendations .20 Strategies/Policies .20 Projects/Studies .21 C. Waterborne .21 Issues/Problems .21 Recommendations .22
- 7. Land Use Issues .22 Issues/Problems .23 Recommendations .23
- 8. Funding Issues .24 Issues/Problems .25 Recommendations .25 Endnotes.27 Appendices .29 Map 1: Coastal Corridor Transportation Investment Area .31 Map 2: Municipalities and Planning Regions of the Coastal Corridor TIA .33 Map 3: Population Densities in the Coastal Corridor TIA .35 Map 4: Coastal Corridor Transportation Systems .37 Regional Planning Organization Comments/Endorsements .39 CoastalCorridorTransportationInvestment Area- Twenty-Year Strategic Plan (November 2001) iii
TWENTY-YEAR STRATEGIC PLAN FOR TRANSPORTATION in the COASTAL CORRIDOR TRANSPORTATION INVESTMENT AREA Executive Summary This executive summary of the initial twenty-year strategic plan for transportation in the Coastal Corridor TIA (the Plan) was prepared by its Board pursuant to House Bill No. 7506/Public Act 01-5, An Act Implementing the Recommendations of the Transportation Strategy Board (the Act). The Plan also creates a linkage between the TIA's strategy and projects listed in the Act as eligible for a share of the $50 million in funds appropriated in the FY 2001-2003 budget for projects endorsed by the Transportation Strategy Board.
Overview Congestion is endemic throughout the Coastal Corridor TIA. It is acute on the primary highways, Interstate Routes 1-95 and 84, and U.S. Route 1 and CT Route 15, and particularly acute on the westerly portion of Interstate Route 95. Employers increasingly see long commutes on congested roads as threats to productivity. Congestion also impedes the flow of goods into, out of, and through Connecticut and contributes to the status of much of the Coastal Corridor TIA as a 'severe non-attainment area" in terms of air quality.
The opportunity to develop the following alternative modes of transportation exists in the Coastal Corridor TIA:
- Rail lines extend throughout the Coastal Corridor TIA. They are not being utilized to the extent of their capacity, either for people or freight, although they are in urgent need of significant capital investment
- Based on return from the farebox, Connecticut's public bus system is one of the most productive in the country, suggesting that there is potential for increased ridership.
- The Coastal Corridor TIA has a potential air passenger market that would appear to support a regional or 'secondary" airport.
- The proximity of Long Island Sound offers the possibility of the development of both high speed ferries and increased barge transportation of goods.
- Particularly along the coast, the closeness of the origins and destinations of many trips suggests that there is considerable potential for travel by bicycle and on foot.
Vision Statement The Plan has established the following vision statement to describe its goal, i.e., the transportation system that should be in place in the TIA at the end of twenty years:
The Coastal Corridor TIA will have a transportation system that offers people and goods a choice of safe, convenient and integrated modes of transportation including (a) roads, (b) waterborne, (c) airborne, (d) rail and other modes of public transit and (e) facilities that make walking and bicycling viable transportation options so as:
to stimulate sustainable economic growth by ensuring mobility of people and goods within the TIA and connectivity of the TIA's economy to the state, regional, national and global economies; and Coastal CorridorTransportationInvestment Area- Tsventy-Year Strategic Plan (November 2001) I
to enhance quality of life by ensuring mobility of all residents of the TIA, including those unable to drive, while protecting the TIA's environmental, cultural and community resources.
Movement of People Where people can reach their destinations only by road, they are trapped in the congested conditions found there and can only contribute to that congestion when traveling But where choices exist, some will choose another mode of travel and in so doing will make no contribution to road congestion.
Development of alternatives to single-occupancy vehicles must be the priority. Nonetheless, the automobile will remain the dominant mode by which people travel in the Coastal Corridor TIA, even as alternative modes are developed.
Commitment to Transit. The Plan recommends that a determination be made of how best to enhance focus and accountability for, and commitment to, public transportation in Connecticut, specifically by considering establishment of a separate authority responsible for transit throughout the state and a separate funding source for public transportation.
Roads. The Plan makes both general and specific recommendations regarding roadway improvements. It also recommends a study of specific Transportation Systems Management strategies and their implementation (on a permanent or pilot basis) where appropriate, feasible and not already in place, funding of ConnlDOT's statewide intelligent transportation systems initiative and expanded use of Transportation Demand Management strategies to encourage the use of transit, carpooling, vanpooling, telecommuting, compressed work schedules, staggered work times, bicycling and walking. It also recommends evaluation of the institution of a Value Pricing Pilot Program on one or more limited access highways in the TIA.
Commuter and Intercity Rail. Ridership on the TIA's railroads has almost doubled in the last 30 years, but capital investment in rail facilities has not kept pace The frequency and reliability of both commuter and intercity rail service and the destinations served should be improved so as to make train service more convenient and thus more comparable to use of the automobile. The Plan makes recommendations regarding the need to order new rail cars immediately, specific infrastructure improvements, railroad station strategies, expanded service and Conn/DOT's agreement with Metro North.
Bus Transit. The Plan notes that a funding 'containment' philosophy has limited development of Connecticut's bus system. It recommends a study of consolidation of agencies to enhance efficiencies and makes recommendations for expanded service including job access services, marketing and cleaner fuels.
Waterborne. Noting the proximity of Long Island Sound, the Plan recommends limited investment in infrastructure to permit private operators to provide High Speed Ferry service.
Airborne. The Plan recommends a study of statewide airport resources and needs.
Pedestrian and Bicycle Facilities. To make bicycling and walking viable transportation options, the Plan recommends routine incorporation of bike/ped facilities in all road projects, as well as other, more specific recommendations.
Movement of Goods Connecticut is heavily dependent on trucks for the movement of goods into, out of and through the State. Providing more choices to shippers and receivers would promote the business climate and mitigate road congestion.
Rail. The Plan recommends encouragement of high speed off-peak truck-competitive rail freight usage of the New Haven Line, the Springfield Line and the New Haven to Boston Northeast Corridor.
This can begin immediately through Penn Station for certain commodities, but the Plan recommends Coastal CorrdorTransportationInvestment Area Twenty-Year StrategicPlan (November2001) 2
that Connecticut support a new rail crossing of the Hudson River. It makes other specific infrastructure recommendations.
Trucks. The Plan acknowledges the efficiency of truck transport, but also its disproportionate contribution to safety and environmental concerns as compared to rail and waterborne alternatives It makes recommendations regarding rest areas, non-peak movement of goods and specific infrastructure improvements.
Waterborne. The Plan notes the overcrowded facilities at New York/New Jersey port and the projected increase of container shipments into New England. Implementation of feasibility studies of development of Bridgeport's and New Haven's port facilities to accommodate barges carrying containers could remove many trucks from Route 1-95. The Plan recommends specific infrastructure and process changes to help achieve this.
Land Use Issues Transportation and land use decisions are usually made separately, even though each profoundly affects the other, and both have strong impacts on the local and regional quality of life. As a result of this disjoined decision-making, the region is consuming much of its land without improving its mobility.
Moreover, affordable housing for the work force of many employers is not available in proximity to place of employment. Connecticut must think beyond specific disciplines to create a "multi-modal" approach and managed land use planning for municipal and regional development.
The Plan recommends re-establishment of a Statewide Planning Division within the Connecticut Office of Policy and Management for coordinating and monitoring various short- and long-range plans. It also makes recommendations to encourage, among other things, increased land use clustering, mixed-use development, transit accessibility and pedestrian-oriented development, protection of 'Preservation Areas", redevelopment of 'brownfields" and development of new housing stock in areas with demonstrated job demand or availability to transit.
Funding Issues Connecticut can no longer rely largely on federal funding for the vast majority of its transportation capital and operating needs. Implementing a new transportation strategy will require substantial financial investment in addition to current sources of support and greater flexibility in the use of current funding sources.
The Plan makes recommendations both with respect to new funding sources and allocation of available funding.
Coastal CorridorTransportationInvestment Area - Twenty-Year Strategic Plan ('November 2001) 3
TWENTY-YEAR STRATEGIC PLAN FOR TRANSPORTATION in the COASTAL CORRIDOR TRANSPORTATION INVESTMENT AREA
- 1. PURPOSE OF THE PLAN Section 3(d) of House Bill No. 7506/Public Act 01-5, An Act Implementing the Recommendations of the Transportation Strategy Board (the Act) mandates that the participants in each Transportation Investment Area (TIA) prepare an initial TIA Corridor Plan for submission to the Connecticut Transportation Strategy Board by November 15, 2001. Section 1(5) of the Act defines a TIA Corridor Plan as a 'twenty-year strategic plan for transportation in the TIA."
This initial plan was developed to provide an overview of the Coastal Corridor TIA and its primary regional and inter-regional transportation concerns, and to describe a twenty-year strategy for enhancing the TIA's transportation system. This initial plan also creates a linkage between the TIA's strategy and transportation projects listed in the Act as eligible for a share of the $50 million in funds appropriated in the fiscal year 2001-2003 budget for projects endorsed by the Transportation Strategy Board.
- 2. DEVELOPMENT OF THE PLAN This initial plan has been developed with reference to the transportation needs, strategies and objectives stated in the following regional plans:
2001-2021 HVCEO Regional Transportation Plan, prepared by the Housatonic Valley Council of Elected Officials, April 2001.
Long-Range Regional Transportation Plan 2000, prepared by staff and endorsed by board members of the Council of Governments of the Central Naugatuck Valley, January 10, 2001.
Mobility: A Transportation Plan for the Year 2020, prepared by the South Central Regional Council of Governments, January 2001.
Regional Transportation Plan for the Greater Bridgeport Planning Region, prepared by the Greater Bridgeport Regional Planning Agency with the endorsement of the Greater Bridgeport and the Valley Regional Planning Agency, February 2001.
South Western Region Long Range Transportation Plan, 2001-2025, prepared by the South Western Regional Planning Agency, June 22, 2001.
Regional Transportation Plan for the Valley Planning Region, prepared and endorsed by the Valley Regional Planning Agency, February 2001, endorsed by the Greater Bridgeport and Valley Regional Planning Agency.
- 3. MAPS OF THE COASTAL CORRIDOR TIA Thematic maps of the Coastal Corridor TIA are attached as Appendices (Maps 1-4) beginning on page 29.
- 4. VISION STATEMENT CoastalCormrdorTransportationInvestment Area - Twenty-Year Strategic Plan (November 2001) 4
A strategic plan is essentially a method or technique for achieving some end. This initial plan has established a vision statement describing the end it seeks to achieve, i.e., the transportation system that should be in place in the TIA at the end of twenty years. Section 4(c) of the Act describes in broad terms what the strategy should achieve, and the balance of Section 4 provides further guidance. The vision statement is drawn from Section 4 and is not intended to replace it but rather to provide the focus necessary to develop a strategy. The vision statement constitutes a template against which specific proposals are measured.
The following is the vision statement:
The Coastal Corridor TIA will have a transportation system that offers people and goods a choice of safe, convenient and integrated modes of transportation including (a) roads, (b) waterborne, (c) airborne, (d) rail and other modes of public transit and (e) facilities that make walking and bicycling viable transportation options so as:
- to stimulate sustainable economic growth by ensuring mobility of people and goods within the TIA and connectivity of the TIA's economy to the state, regional, national and global economies; and
- to enhance quality of life by ensuring mobility of all residents of the TIA, including those unable to drive, while protecting the TIA's environmental, cultural and community resources.
- 5. GENERAL RECOMMENDATIONS The following are general recommendations applicable to the entire strategic plan:
Projects Outside the Scope of This Plan Projects currently in the Statewide Transportation Improvement Program (STIP) that are already in design, right-of-way acquisition or construction should go forward and should not be de-funded in order to fund priorities identified in this plan.
Travel Forecasting By Mode, Origin and Destination While the Connecticut Department of Transportation (ConnDOT) has a statewide computer forecasting model for its own needs, most groups, such as the TIA, and its constituent regional planning organizations, have no such resources. Planning questions involving the examination of traffic flows to view the degree of common origins and destinations are unanswerable. Upgrading the forecasting system statewide would help insure that optimal decisions are made as to transportation investments. ConnDOT's model should be refined to provide time-of-day projections, new origins and destination studies, and upgraded municipal and zone-level population and employment projections.
Collaboration with Neighboring States
. Connecticut state agencies should reinforce collaboration both within the state and with appropriate agencies in neighboring states to ensure coordinated and compatible development of transportation and other infrastructure.
Enhance North-South Connectivity North-south connectivity in the Coastal Corridor TIA should be enhanced to alleviate congestion along east-west routes and to improve quality of life.
- 6. MOVEMENT OF PEOPLE CoastalCorridor Transportation Investment Area- Tventy-Year Strategic Plan (November 2001) 5
In its report to the Connecticut Regional Institute for the 21t Century (or the 'Gallis Report"), Michael Gallis & Associates summarizes the situation of the Coastal Corridor TIA in the following terms-Connecticut's access to the global marketplace is principally through the 1-95 corridor. This corridor, with interstate and transit lines, provides access to the very dynamic New York metro region and access to the continental grid.... While the Connecticut to New York commute is largely transit-oriented, there is very little inter-city transit within Connecticut. As congestion increases in this corridor and the major global connections move west of the Hudson [River], this corridor will not offer the level of access to the economic activities and hubs necessary to support Connecticut's institutions, businesses and people. Congestion effectively blocks economic activity from extending farther than Stamford in the [Coastal Corridor TIA].
Congestion is endemic throughout the Coastal Corridor TIA. It is acute on the primary highways, Interstate Routes 1-95 and 84, and U.S. Route 1 and CT Route 15, and particularly acute on the westerly portion of Interstate Route 95. The increased congestion in the Coastal Corridor TIA is mirrored throughout the country. Employers increasingly see long commutes on congested roads as threats to productivity. Congestion also contributes to the status of much of the Coastal Corridor TIA as a 'severe non-attainment area" in terms of air quality.
Significant increase in road capacity in the Coastal Corridor TIA would be expensive, would have negative environmental impacts and could encounter strong public opposition. Moreover, adding capacity to highways induces additional traffic, as people take additional car trips and new development creates even more demand.
By contrast, public transportation (rail, bus, airborne and waterborne) not only provides relief from congested roads, it lessens the negative impact on air quality and the safety hazards of traffic (especially congested traffic) Moreover, it contributes to the economy; public transportation has been found to create savings to business operations and to increase business sales, household incomes and tax revenues.'
If safe, convenient and integrated alternative modes of transportation were in place, there would be considerable potential to switch trips from the automobile. The opportunity to develop the following alternative modes of transportation exists in the Coastal Corridor TIA:
- Rail lines extend throughout the Coastal Corridor TIA. They are not being utilized to the extent of their capacity, although they are in urgent need of significant capital investment.
- Based on return from the farebox, Connecticut's public bus system is one of the most productive in the country, suggesting that there is potential for increased ridership.
- The Coastal Corridor TIA has a potential air passenger market that would appear to support a secondary airport if it had an airport with a runway sufficient for small, narrow-bodied jets.
- The proximity of Long Island Sound offers the possibility of the development of high speed ferries.
- Particularly along the coast, the closeness of the origins and destinations of many trips suggests that there is considerable potential for travel by bicycle and on foot.
Recommendations Increase Commitment to Transit
. Determine how best to enhance focus on accountability for, and commitment to, public transportation in Connecticut. Consider establishment of a separate authority responsible for transit throughout the state and a separate funding source for public transportation, such as a CoastalCorrdorTransportation Investment Area Twven0'-Year Strategtc Plan (November 2001) 6
dedicated mass transit operating account in the state budget Study the best practices in managing public transit, including the success of neighboring authorities, New York's Metropolitan Transportation Authority and the Massachusetts Bay Transit Authority, in advancing public transportation in their respective regions.
Improve Access to Airports
- Improve access to metropolitan area airports by means other than single-occupancy vehicles.
A. ROADS Issues/Problems Congestion in the Costal Corridor TIA affects the movement of people. Where they can reach their destinations only by road, people are trapped in the congested conditions found there and can only contribute to that congestion when traveling. But where choices exist, some will choose another mode of travel and in so doing will make no contribution to congestion on our roads. Development of alternatives to single-occupancy vehicles must be our priority. Nonetheless, the automobile will remain the dominant mode by which people travel in the Coastal Corridor TIA, even as alternative modes are developed. This will require further investment in our road system.
Most importantly, the road system, including local roads, must be maintained in a state of good repair.
Poor or outdated engineering contributes to the inefficient movement of vehicles and gives rise to public safety concerns. Many of the Coastal Corridor TIA's roadways were built neither to handle the volume of traffic that currently exists nor to accommodate the types of travel common today.
Engineering designed to improve system efficiency such as intersection improvements, coordinated signalization, turning lanes and emergency shoulders are important elements to facilitating traffic flow through a given spot and enhancing safety.
Facilitating economic growth is a major goal of this plan, but growth that is dependent on motor vehicles could be counter-productive to that goal. Moreover, added volume on local roads, which are already congested, contributes to a degradation of quality of life. Added traffic volume would also contribute to the region's air quality problems.
Recommendations Roadway Improvements Undertake road capacity expansion projects only after a comprehensive review that takes into consideration, at a minimum, the following factors: environmental impact; all reasonable alternatives and options; impact on community character; impact on roadways in adjacent regions, even if those adjacent regions are located outside Connecticut; and impact of the proposed project on the transportation system as a whole.
- Evaluate operational and construction improvements to 1-95 and Route 15 to relieve congestion and improve access in the corridor.
- With the Interstate 84 and Route 8 interchange as its priority, fund a safety and capacity study of Route 8 from Seymour to Waterbury, as proposed in Section 16 (a)(19) of the Act. Extend the study area from Waterbury to Bridgeport. This study should include an examination of gateways to provide access to downtown areas and the feasibility of designating Route 8 as an interstate highway.
- Fund the expansion of commuter parking lots in the Coastal Corridor TIA, as proposed in Section 16.(a)(2) of the Act.
Coastal CorridorTransportationInvestment Area. Tsventy-Year Strategic Plan (November 2001) 7
- Fund the recommendations of ConnDOT's two most recent improvement studies for Interstate I-84 which together assessed congestion and safety on the 32 miles from Waterbury to the New York state line, following the investment priorities recommended in these studies, including funding for the safety and operational improvements at Interstate 1-84 interchanges from Danbury to Newtown, as proposed in Section 16.(a)(1 8) of the Act.
- Study the capacity and feasibility of widening Route 1-95 east from New Haven to the Rhode Island state line, with consideration of environmental and sprawl impact of any large highway project and with reference to the study proposed in Section 16 (a)(14) of the Act.
- Fund ConnDOT's statewide intelligent transportation systems initiative.
TransportationSystems Management Strategies Transportation Systems Management (TSM) is a strategy designed to maximize the efficiency of existing highway capacity through various operational and administrative mechanisms. A variety of TSM strategies have been implemented within the Coastal Corridor TIA including incident management teams, construction management programs and highway advisory radio. Few of these strategies, however, have been implemented consistently throughout the Coastal Corridor and, as a result, the benefits are fragmented.
Following a study of existing regional systems, the following TSM strategies should be implemented (on a permanent or pilot basis) where appropriate, feasible and not already in place, and appropriate benchmark data should be established:
- Entrance closures to discourage local travel on limited access highways, but only in conjunction with action to alleviate the added burden on local roads. Fund the analysis of the appropriateness of peak hour on-ramp closures on Interstate 1-95, as proposed in Section 16.(a)(8) of the Act.
- Signalization improvements.
- Incident management programs to clear accidents quickly from roadways. Fund the improvement and further development of an Accident Clearance Policy to minimize the impact of accidents on Interstate 1-95 and the Merritt Parkway and the enhancement of hours of truck safety stations, as proposed in Section 16.(a)(7) of the Act.
- Construction management practices that minimize the impact on traffic flow, e.g., by coordinating overlapping road improvement projects, shortening the duration of construction periods, scheduling construction during off-peak periods and providing incentives to contractors that complete work ahead of schedule
- Ramp metering to regulate the entry of vehicles into the traffic stream on limited access highways.
- Enhanced traffic enforcement.
- Highway informational radio to alert motorists to problems in time for them to alter their routes.
- Dedicated high occupancy vehicle (HOV) lanes.
B. TRANSPORTATION DEMAND MANAGEMENT STRATEGIES Issues/Problems Coastal CorrdorTransportationInvestment Area - Twent-Year Strategic Plan (November2001) 8
Transportation Demand Management (TDM) strategies are designed to encourage commuters to modify their travel patterns and behavior in such a way as to reduce single-occupant vehicle traffic and, by extension, traffic congestion. TDM strategies support and encourage the use of transit, carpooling, vanpooling, telecommuting, compressed work schedules, staggered work times, and bicycling and walking, all of which are currently in place to one degree or another in the Coastal Corridor TIA. Another potentially effective TDM measure that is not currently in place in the Coastal Corridor TIA is value pricing.
Recommendations
- Evaluate the institution of a Value Pricing Pilot Program on one or more limited access highways in the Coastal Corridor TIA.
- Continue and expand support of existing commuter incentive programs.
- Fund marketing of the Deduct-a-Ride program, as proposed in Section 16.(a)(3) of the Act.
- Develop "commuter connections" with guaranteed rides between transportation hubs, residential areas and employment centers.
- Continue promoting and supporting employer-based TDM programs at major employment centers in the Coastal Corridor TIA, and continue to expand TDM programs to smaller employers where appropriate.
- Increase availability of commuter information and services (e.g., parking availability, transit ticket purchases) on the Internet through consolidation and coordination of existing transportation web sites and improved user utility.
- Increase funding for marketing of all transportation alternatives and coordinate marketing under a single brand identity (while allowing for local customization by transportation organizations).
- Consider expansion of existing employer trip reduction tax credit and other incentives.
C. COMMUTER AND INTERCITY RAIL Issues/Problems There are 575 route miles of railroad track in Connecticut owned by eleven separate entities.
Passenger service over this patchwork of rail ownership is provided by three entities. Pursuant to a contract among ConnDOT, New York State's Metropolitan Transportation Authority (MTA) and the Metro North Commuter Railroad, Metro North provides service on the New Haven main line from New York City to New Haven and over the three branch lines: New Canaan branch, Danbury branch, and Waterbury branch. Under contract with ConnDOT, Amtrak operates the Shore Line East service east of New Haven over the trackage it owns. In addition, Amtrak provides intercity service from New York to Boston via New London and from New York to Hartford and Springfield, using ConnDOT trackage west of New Haven and its own trackage north and east of New Haven.
Commuter service over the former New York, New Haven and Hartford (NYNH&H) line has long been a vital transportation amenity in the Coastal Corridor TIA. Traditionally this link has primarily provided access by Connecticut residents to jobs in New York City, but increasingly it is being used by so-called reverse commuters, New York City residents who work in Connecticut, and intra-state Connecticut commuters. Overall, ridership has increased by 41 percent since 1984 and by nearly 100 percent since 1970, and reverse and intrastate commutes were up 47 percent between 1995 and 2000.2 Unfortunately, this increase in ridership has resulted in a shortage of seats, but no new rail cars have been added to the fleet used to service the New Haven line in almost a decade. The bulk of Coastal CorridorTransportationInvestment Area T-venty- Year Strategic Plan (November 2001) 9
/
the passenger cars owned by ConnDOT and used on the New Haven line are M-2 type electrical multiple unit rail cars and are nearly 30 years old, which is past their anticipated useful life.
More frequent service to more destinations will make the railroad a more attractive alternative to the automobile. During off-peak hours, existing stops between New Haven and Stamford is hourly and between Stamford and New York is half-hourly. A "subway/shuttle" service, offering customers trains every 15 or 20 minutes would make train service more convenient and thus more comparable to use of the automobile.
Recommendations Order New Rail Cars Immediately Ordering the new equipment necessary to maintain the existing level and maintain reliability of service must be our first priority, given the lengthy time required for specification, manufacture and delivery. ConnDOT and MTAIMetro North have identified an immediate need for 10 locomotives and 60 push/pull coaches to maintain the existing level and reliability of service, and to increase intrastate service. In addition, they estimate that by 2030 well over 500 passenger cars may be required to replace the existing fleet and provide for future growth in ridership.3 Infrastructure To properly maintain and store the new equipment and overhaul the existing M-2 fleet, the site selection and acquisition and the design of the needed new storage and maintenance facility should begin as soon as possible, as this facility must be completed before delivery of new equipment. Fund the site selection study for the expansion of the New Haven Line rail maintenance facilities' capacity and purchase land for a new rail service maintenance facility, as proposed in Section 16.(a)(5) of the Act.
Both to ensure service reliability and to permit Amtrak's Acela trains to operate at higher speed, the replacement of the obsolete catenaries should be accelerated.
Either change the electrical current used east of New Haven to the same current used west of New Haven or modify Metro North electrical rail cars to use the current east of New Haven. This will permit Metro North electrical rail cars to operate east of New Haven Any construction of limited-access busways should include provision for their conversion to rail or light-rail as future demand warrants.
Stations
- Following a review of commutation and residency patterns, a fair distribution of additional parking and other access facilities at rail stations needed to meet demand, both existing and anticipated, should be determined. On the basis of this review, a strategy should be devised to construct the additional facilities needed, and to offer consistent access and pricing to all motorists using parking facilities. Station access facilities should include strategies other than vehicular, including bus, jitney, walking and bicycling.
- A strategy should be devised to ensure the availability of shuttles or taxis at the arrival and departure times of trains throughout the day (not just at peak commuter hours) at the principal railroad station in each town served by Metro North and Shore Line East.
Expanded Service Increase service on Metro North by offering more frequent, subwaylshuttle" service.
CoastalCorridor TransportationInvestment Area: Tventy-Year Strategic Plan (November 2001) 10
- Integrate the services offered by Metro North and Shore Line East into a single, seamless service This integration should not be structured as only a two-year trial, as proposed in Section 16.(a)(9) of the Act.
- Implement the improvements in the Danbury Branch Line from Norwalk to New Milford proposed by the Route 7 Travel Options Implementation Plan.
- Update the study of expansion of service on the Waterbury Branch Line.
- Operate more trains from and to east of Stamford to and from Greenwich without requiring a change in Stamford.
- Expand destinations served by Metro North to include Penn Station in New York City, Hartford, Springfield, MA, Providence, RI, and intermediate destinations. This action would permit rail customers to choose between Metro North and Amtrak to many destinations.
- Fund the design study for an Orange/West Haven rail station, as proposed in Section 16.(a)(4) of the Act
- Support an alternative stop by Amtrak's Acela train at Bridgeport.
- Fund the study of the infrastructure cost and operating characteristics of rail commuter services from New Haven to Springfield, including Bradley Airport, as proposed in Section 16.(a)(17) of the Act.
- Funding of the proposal to partner with Amtrak to provide an additional peak period train from Connecticut to Penn Station, as proposed in Section 16.(a)(10) of the Act, is not recommended.
Metro North Operating Agreement Use all available means under the existing service agreement among ConnDOT, the MTA and Metro North to improve Connecticut rail transit including, if possible, obtaining a seat on the MTA board.
D. BUS TRANSIT Issues/Problems Connecticut's local bus system is one of the most productive systems in the country, with an average return from the farebox of 36 percent and with some districts returning over 40 percent. This compares with an industry average of 35 percent.4 This high productivity suggests that there is potential for increased ridership.
While buses are nonetheless a major provider of public transit in Connecticut, investment in bus transit in Connecticut has remained relatively flat. This funding containment" philosophy has limited Connecticut's bus system from enjoying a much larger market share and prevented it from contributing to its fullest extent to the reduction of congestion and air pollution. Connecticut must move from an incremental or "containment" funding philosophy and invest new dollars in both operating and capital for bus operations.
Connecticut's bus system is faced with a $2.5 million projected operating deficit this year alone.5 To address this deficit, several thousand hours of revenue bus service will have to be cut, and some transit districts will have to raise fares just to make ends meet. As with our rail service, we are failing to provide our bus system with the funding it needs.
Recommendations Coastal CorrdorTransportationInvestment Area* Twenty- Year Strategic Plan (November 2001) I11
Consolidation of Bus Services Study whether consolidation of agencies that operate buses in the state and/or the Coastal Corridor TIA would enhance operating and planning efficiency.
Expanded Service
. Implement recommendations for more bus service contained in the 'Connecticut DOT's Statewide Bus System Study" (July 2000).
- Expand Fairfield County inter-regional service by purchasing ten new buses (including articulated buses for the coastal link) and provide funding for additional local bus service, as proposed in Section 16.(a)(1 1) of the Act
- Where the demand exists, provide for more inter-district, inter-town, inter-regional bus routes like the Coastal Link, including routes linking rural communities.
- Improve bus services for the elderly and the disabled.
- Consider extension of the Hartford to New Britain Busway, to and from Waterbury.
- Develop (a) operational and fiscal plans for the expansion of local and regional bus services to coordinate with rail and ferry schedules for service to area attractions, and (b) a single ticket fare and fare media structure for rail, bus and ferry services, as proposed in Section 16.(a)(13) of the Act. The fare structure should be integrated with a statewide Deduct-A-Ride program.
- Fund expansion of bus services connecting with rail services in the Coastal Corridor TIA, as proposed in Section 16.(a)(6) of the Act.
Fund expansion of bus services for existing and new western Connecticut commuters to utilize Metro-North's Upper Harlem Line for commuting to New York City and White Plains, as proposed in Section 16.(a)(12) of the Act.
Consider the introduction of Bus Rapid Transit projects in the Coastal Corridor TIA similar to the Hartford Bus Rapid Transit project, including the feasibility of using state or interstate routes for Bus Rapid Transit Demonstration projects.
Job Access
- Fund the Jobs Access Program that provides later evening bus service route extensions and customized paratransit services for residents in the cities of Bridgeport, New Haven and Waterbury, as proposed in Section 16.(a)(1) of the Act.
- Incorporate all effective Job Access Program services now funded from grants in the operating budgets of transit districts.
- Where demand exists, provide service to all major job centers, including retail centers on Saturdays and Sundays.
Marketing Develop a comprehensive, regional bus marketing campaign for the Coastal Corridor TIA, taking advantage of the national efforts to enhance poor public perception of public transportation.
Coastal CorridorTransportation Investment Area Twenty-Year Strategic Plan (November 2OO) 12
Improve buses' image by making buses more attractive and user-friendly, for example, by discontinuing the practice of darkening bus windows with advertising or other materials that restrict visual contact between passengers and the surrounding streetscape.
Miscellaneous Provide both funding and incentives to transit operations to use cleaner fuels like compressed natural gas.
E. WATERBORNE Issues/Problems The state has funded a comprehensive study to explore utilizing Connecticut's waterway system further to expand the potential for movement of people within the Coastal Corridor TIA. The infrastructure (Long Island Sound) has been in place for thousands of years, and its capacity for ferry service is infinitely expandable. There is an existing ferry service between Bridgeport and Port Jefferson. Several private ferry operators have indicated an interest in providing service on high speed ferries, so that the service may require no operating subsidy from the state. While there are land access and parking issues, such an operation would require minimal capital investment from the state.
Recommendations Fund infrastructure improvements (e.g., dredging, bulkheading, and passenger facilities) to insure that a ferry operation interfaces with the Bridgeport Intermodal Facility. The funding of a high speed ferry from Bridgeport to Stamford to New York, as proposed by Section 16.(a)(20) of the Act, should be limited to such infrastructure improvements.
F. AIRBORNE IssueslProblems Six airports - Danbury Municipal Airport, Waterbury-Oxford Airport, Sikorsky Airport, Tweed-New Haven Airport, Meriden Markham Airport and the Griswold Airport - are located in the Coastal Corridor TIA, but only Tweed-New Haven provides commercial air service. However, commercial service is available from Westchester County Airport which is located immediately adjacent to the southwestern border of the Coastal Corridor TIA.
A significant percentage of the persons who live and work in the Coastal Corridor TIA rely on New York airports to meet their commercial air travel needs, thereby contributing to road congestion.
However, a significant market exists for expanded commercial air travel in Connecticut and the economic impacts of expanded commercial air travel opportunities would boost Connecticut's economy.
Recommendation Conduct a study of statewide airport resources and needs, including airports owned by the state, municipalities and private interests, which among other things should determine the need for one or more regional or "secondary" airport within the Coastal Corridor TIA attractive to commercial air carriers capable of flying to destinations of up to 1,000 miles.
G. PEDESTRIAN AND BICYCLE FACILITIES Issues/Problems Coastal CorridorTransportationInvestment Area. Twent - Year StrategicPlan (November 2001) 13
With the adoption of the federal Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA),
Congress recognized that bicycling and walking should be integral parts of a multi-modal approach to transportation and made funding available for bicycle and pedestrian facilities. This support continues in the Transportation Equity Act of the 21 st Century (TEA-21).
Despite the availability of this funding, little has been done in the Coastal Corridor TIA to improve conditions for cyclists and pedestrians. However, ConnDOT acknowledges that bicycle and pedestrian trips in Connecticut have been below the national average and that a significant number of trips could be switched from the automobile. 6 The close proximity within the Coastal Corridor TIA of many residential areas, businesses and shopping areas and recreational facilities makes bicycling and walking viable travel options. Although both are short-range transportation choices, when used in conjunction with public transit or rideshare lots the range can be much greater.
Recommendations
- The cost of developing bicycle and pedestrian facilities is low as compared with the cost of development of road or rail facilities. A cost-efficient way to integrate bicycling and walking into the transportation infrastructure would be for ConnDOT, in respect of state roads, and MPOs, in respect of county and local roads that are part of regional Transportation Improvement Projects, routinely to include bike/ped improvements in all projects involving such roads. The U.S.
Department of Transportation has adopted a policy statement to this effect which is designed for adoption at the state and local levels, and this policy statement should be both adopted and followed by ConnDOT and the MPOs in the Coastal Corridor TIA.
- Each regional planning agency of the Coastal Corridor TIA should adopt a Bicycle and Pedestrian Plan for its region.
- Greater funding should be provided for bicycle and pedestrian facilities, particularly greenway projects incorporating multi-use paths where such greenways extend through well-traveled transportation corridors.
- Establish a pedestrian set-aside in ConnDOT's local aid program that would provide municipalities withi moneys to construct sidewalks and implement traffic-calming projects.
- Equip buses and commuter trains for the carriage of bicycles.
- 7. MOVEMENT OF GOODS Generating more transportation alternatives such as waterborne and rail intermodal should be an objective of the State of Connecticut. More choices for shippers and receivers would promote Connecticut's business climate. Increasing and improving transportation options would assist in improving the flow of goods into, out of, and through Connecticut while improving highway safety and air quality.
Seventy-four percent of the volume of commodities that travel into, out of, and through Connecticut travel by trucks that enter the state, including 38 percent of the traffic destined for Connecticut and 44 percent of the traffic passing through the state. This mode of transport carries with it a disproportionate level of safety and environmental concerns as compared to rail and waterborne alternatives. 7 Commodities carried cover the range of all the products necessary for human life and economic well being.
Recommendation Coastal CorndorTransportnationInvestment Area Twenty-Year StrategicPlan (Novtember 2001) 14
Create shipper alternatives such as improved rail, efficient rail intermodal and waterborne routes.
Shippers must be convinced there are cost-effective, efficient alternatives to our highways.
A. RAIL Issues/Problems Connecticut shares heavy truck traffic on 1-95 with other interstates from Virginia to Maine.
Connecticut needs to develop the alternative choice of truck-competitive, intermodal rail freight.
Connecticut's existing "cul-de-sac" or dead ended rail freight system must be promptly and effectively transformed so as to provide a rail freight option with intermodal connections. This new rail freight service must operate on the fastest, most direct rail lines along the 1-95 corridor.
Operating track capacity on the New Haven Line was dramatically increased in the 1980s as the result of signal improvements and even with an increase in commuter rail service there will be hours in the 24-hour "day" when rail freight trains could operate.
Recommendations
- As soon as possible, start directing rail freight operations through Penn Station tunnels during off-peak hours for perishable shipments (such as an extension northward to New England of the CSX "Orange Blossom Special"), RoadRailer, mail and express and high priority container-on-flat-car trains.
- Actively advocate and support a new, direct, rail freight connection across the Hudson River andlor New York Harbor at New York City. The feasibility of the New York Cross Harbor rail tunnel has been proven, and environmental and planning studies are well under way. Connecticut should support and encourage this bold and timely capital investment in our national rail freight network.
- In addition, added cross-Hudson rail capacity is needed at Penn Station. Connecticut should get involved and work for freight as well as passenger use of any additions to track and tunnel capacity at this vital point
- Encourage consideration of additional Hudson River rail crossings.
- Encourage, rather than discourage, high speed off-peak truck-competitive rail freight usage of the New Haven Line, the Springfield Line and the New Haven to Boston Northeast Corridor.
. Resume the past policy of improving rather than disinvesting in rail overhead and side clearances. Actively consider the cost benefit of improving such clearances as well as the economic and environmental penalty for failing to do so.
- Act now to preserve valuable and difficult to replace rail freight yard and terminal space, especially at New Haven (Cedar Hill Yard), at Hartford (North Meadows) and, working with Rhode Island, at Providence (Northrup Avenue Yard).
- The issues relating to rail freight in Connecticut are poorly understood. This is especially true in terms of the geographic relationships between freight haulers and potential changes to East Coast service routes as may affect Connecticut. A clearly written inventory report, to serve as a base for all freight planning and possible public investment, is immediately needed.
B. TRUCKS Issues/Problems CoastalCorridorTransportationInvestment Area Tiventy-Year Strategic Plan (November 2001) 15
- The U.S. has an extremely comprehensive and efficient highway system which has reached capacity. In order for Connecticut to deal with the current level of traffic congestion, the state must find ways to get more out of its existing assets by making it more efficient. This is, in fact, a goal of the U.S. Department of Transportation.
- ConnDOT has determined that truck-only routes are more cost effective than other transportation modes for shipments less than 500 to 1,000 miles. 8
- ConnDOT has found that trucks make up only 8 to 15 percent of peak hour traffic at the New York/Connecticut border and, while trucks are equivalent to as many as four passenger vehicles, they also are more likely to be traveling longer distances than the passenger cars. 9
- Diesel trucks account for a disproportionate amount of the state's greatest non-point source of air pollution - traffic - thereby contributing to the region's status as a severe non-attainment area" in terms of air quality.10 Recommendations Strategies/Policies
- Address the severe shortage of areas where tired truckers can rest along state highways. Explore a public-private partnership with commercial truck stop owners to operate facilities to provide safe and secure areas for truckers to rest.
- Work with local interests to encourage non-peak movement of goods where it does not conflict with quality of life issues.
- Encourage establishment of warehousing, distribution and cargo transportation facilities in the New Haven/Hartford/Springfield corridor, perhaps a "cluster' like effort.
- Become an active participant in the discussions and decision-making concerning any new east coast port development or expansions, in order to affect decisions as to cargo routing options.
- Re-invest in staff and facilities to strengthen Connecticut's safety and diesel truck emissions testing.
Projects/Studies Conduct detailed origin and destination studies on all freight moving into, out of, and through Connecticut, on all transportation modes. Include surveys of all businesses in the state to determine flexibility of shipping and receiving activities, types of products or supplies transported, schedule requirements and proximity to intermodal facilities.
C. WATERBORNE IssueslProblems
- The Port Authority of New York and New Jersey has established a Port Inland Distribution Network (PIDN) system due to overcrowded port facilities and capacity.
- Projected container shipments into New England has been estimated at 386,000 by 2010 and 609,000 by 2020. Clearly road congestion will get much worse if freight activities continue."
- Two feasibility studies were conducted by Greater Bridgeport Regional Planning Agency (GBRPA) and South Central Regional Council of Governments (SCRCOG) in 2000 for implementing shipping containers by barge over the 70 miles of water to and from Bridgeport Coastal CorrdorTransportnationInvestment Area Twenty-Year Strategic Plan (November 2001) 16
port/New Haven port and the New York/New Jersey port If implemented, that container service would be able to reduce trailer trucks in the highly congested 33-mile stretch of 1-95 from Greenwich to Bridgeport or the 53-mile stretch to New Haven.
- The creation of a Bridgeport/New Haven container facility would eliminate up to 80,000 tractor trailer trucks from this section of 1-95. 2 With a diminished number of trucks on the road, air quality and highway safety are destined to improve.
Recommendations
- Support Section 16(a)(21) of the Act, to create container barge feeder port and service in Bridgeport and New Haven.
- Create 'port zones" around our deep water ports to restrict non-water dependent uses and to make our port areas more efficient and more secure.
- Establish more efficient dredge permit procedures and seek affordable dredge disposal alternatives to insure the smooth functioning of our maritime commerce and which results in the least damaging environmental impact or a net positive environmental gain.
- Accelerate restoration of rail service to the Port of New Haven.
- 8. LAND USE ISSUES When the New York, New Haven and Hartford Railroad Company built the New Haven line in the 1840s, it was built to serve commercial and industrial uses as well as passenger needs in the urban centers of six regions of the Coastal Corridor TIA. The post-World War II development of interstate highways and increased use of private automobiles, as well as a shift in commercial uses away from central cities, allowed people to reach farther out into the suburbs to find places to live and work.
There is considerable consensus that the resulting separation of home and work has led to greater congestion on local and regional road networks, declining air quality, and creation of a 'placeless" landscape that have affected all of the municipalities in the TIA and the state.
Transportation and land use planning should have similar end-goals in mind: efficient use of a limited resource (land) that allows for efficient movement of goods and people and creation of strong communities. However, in Connecticut, transportation and land use decisions are usually made separately, even though each profoundly affects the other, and both have strong impacts on the local and regional quality of life. As a result of this disjoined decision making, the TIA is consuming much of its land without improving its mobility.
Another key issue for transportation, of severe proportions in much of Connecticut, is the fact that affordable housing for the local work force is not available in proximity to places of employment.
Municipal policy supports this mismatch by encouraging fiscally positive (business and industry) and discouraging fiscally negative (moderate income housing) land uses in order to enhance the local property tax. Thus, the journey to work becomes longer and longer as affordable housing recedes over the miles to the next region. There needs to be a stronger link between affordable housing and transit services.
The challenge facing the Coastal Corridor TIA today is to think beyond specific disciplines to create a
.multi-modal" approach and managed land use planning for municipal and regional development. A starting point may be found in discussion of the following general questions:
- What incentives exist to create synergistic transportation and land use plans?
Coastal Corridor Transportation Investment Area: Twventy-Year Strategic Plan (November 2001) 17
What incentives exist to develop inter-municipal, or inter-regional, or whole-state plans?
What common assets do the suburban communities share with central cities and how can transportation and land use linkages make the highest and best use of those assets at the local, regional, and state levels?
IssueslProblems
- Strong "home rule" sentiments are counter-current to regional transportation/land use planning efforts in southwest Connecticut
- The Connecticut Conservation and Development Policy Plan has little effect on the realities of municipal planning processes.
- ConnDOT relies on traditional planning models rather than integrating transportation strategies with goal-oriented plans of conservation and development.
. As the Transportation Strategy Board seeks to promote inter-regional efforts to improve Connecticut's transportation services delivery system, ConnDOT proposes to shift responsibility for the acquisition of rights-of-way and land for transportation projects from the state to municipalities. This policy change may result in barriers to the development of inter-municipal transportation projects such as increased legal costs, increased cost of land and project delays.
Recommendations
- Re-establish a Statewide Planning Division within the Connecticut Office of Policy Management for the comprehensive coordination and monitoring of various short- and long-range plans including but not limited to the Conservation and Development Policies Plan for Connecticut, the Master Transportation Plan, the Statewide Transportation Improvement Program (STIP), various regional plans of conservation and development, various regional long-range transportation plans, and town and city plans of conservation and development.
- Strengthen adherence to the Conservation and Development Policies Plan for Connecticut.
- Evaluate, formulate and implement state subsidized incentives to encourage increased land use clustering, mixed-use development, transit accessibility and pedestrian-oriented development.
. Establish state recognized 'Transportation Zone Areas of Development" with associated incentives to encourage their development and use.
- Avoid highway and road expansion projects in areas that the Conservation and Development Policies Plan for Connecticut classifies as "Preservation Areas" wherever possible.
- Evaluate, formulate and implement incentives to encourage 'Transit-Oriented Development."
- Evaluate, formulate and implement incentives to encourage "infill" development in urban areas and existing transportation corridors.
- Evaluate, formulate and implement changes in eligibility requirements for various "brownfield" programs and implement new incentive programs specifically encouraging "brownfield" redevelopment in urban areas and existing transportation corridors.
- Evaluate, formulate and implement incentives to encourage the development of new housing stock in areas with demonstrated job demand as well as adjacent to newly established
'Transportation Zones."
Coastal Corndor TransportationInvestment Area. Tienty-Year Strategic Plan (November 2001) 18
- Evaluate, formulate and implement incentives to encourage the re-drafting of local and municipal zoning regulations to allow for more intensive 'mixed-use" development.
- Institute a program by which ConnDOT will develop the requisite skills and capacity to consider and model the impacts different transportation policies will have on environmental, land use and "quality of life" issues.
- Streamline existing environmental review and approvals processes to eliminate duplication of efforts and enhance coordination among local, state and federal agencies.
- Develop and implement a project-ratings scale that prioritizes state funding for projects located in transportation corridors and transportation zones.
- Require that all municipalities (a) include a bus circulation element in their plan of conservation and development and (b) include specific congestion mitigation plans (including funding sources) to mitigate the increased burden of congestion from any new or proposed development project.
- Upgrade planning coordination between Connecticut and the New York Metropolitan Transportation Council, which is the planning agency for metropolitan New York City.
- 9. FUNDING ISSUES It is clear to our TIA that Connecticut can no longer rely largely on federal funding for the vast majority of its transportation capital and operating needs. Additional state funding for transportation is needed, or the Connecticut economy will stagnate. The current tax structure does little to encourage the movement of people or freight in the most cost-effective and efficient manner.
Issues/Problems
- Connecticut's transportation planning and systems need significant modernization in order to support the state's economic development and quality of life.
- Implementing a new transportation strategy will require substantial financial investment in addition to continuing existing levels of federal, state and local support.
- New sources of transportation revenue, increasing the levels of current funding and gaining more flexibility in the use of current funding will be necessary to meet future needs.
- The active participation of the business community is critical in order to gain the support of public policymakers and the general public for a new strategic plan for transportation and the necessary funding.
- Although the state spending cap does a good job in ensuring that state government does not spend above the means of the growth of our economy, the cap on operational spending substantially limits growth potential in transportation spending. Transportation spending must vie each year with other state spending needs.
- Revenue projections indicate motor fuel tax revenue will not increase and the Special Transportation Fund will incur a deficit.
Recommendations CoastalCorrmdor TransportationInvestment Area Twenty-Year Strategic Plan (November2001) 19
- Examine procurement policies and practices to ensure that competitive bidding, based on the highest and best value criteria, is used as a tool for containing costs and maximizing level and quality of service, particularly with long-term service contracts.
- Connecticut's federal, state and local elected and community delegations must create a unified approach to obtaining more funding from the federal government as reauthorization of TEA-21 approaches In addition, Connecticut needs to work with other northeastern states to obtain additional funding and funding flexibility. A comprehensive strategy to communicate this unified message should be developed.
- Evaluate value pricing and/or congestion pricing programs as recommended in the 'Movement of People" section of this plan.
Create enabling legislation allowing municipalities or regions to develop transportation related tax incentives and impose impact fees.13
- Create Benefit Assessment Districts.
- Explore the use of Tax Increment Financing.
- Explore innovative financing options:
a) State Infrastructure Banks b) Turnkey Procurement c) Advance Construction Authority d) Leasing Rights of Way
- Study the feasibility of converting Connecticut Transit bus contracts from "management" contracts to "service" contracts, thus creating a shared risk" in bus transit financial performance.
- Maintain transit fares at levels which encourage use of mass transit modes, and adjust subsidies to cover operational and maintenance deficits.
- Develop a formula-based allocation of operating funding for all transit districts. The formula may be driven by such variables as vehicle miles traveled (VMT), revenue generation/units, local community contributions, ridership, service to elderly and handicapped populations, demographics, population, revenue per passenger, cost per hour, population density (etc.).
- Create an incentive program that would encourage local communities to contribute more to public transportation programs in their regions.
- Reward companies with policies and programs that help limit traffic congestion.
- Increase mass transit funding with a dedicated funding source.
- Encourage revenue bonding at the state and local levels for capital infrastructure improvements.
- Increase funding levels for Town Aid to Roads.
- Consider establishment of a separate authority for transit, as recommended in the "Movement of People" section of this plan.
- Provide separate funding of the Connecticut Port Authority.
Coastal CorridorTransportationInvestment Area Twenty-Year StrategicPlan (November 2001) 20
ENDNOTES
'Cambridge Systematics, Inc., Public Transportationand the Nation 's Economy (October 1999).
2 ConnDOT, Analysis of the Amended and Restated Service Agreement for the Operation and Subsidization of the New Haven Rail Line (May 2001) 3 Ibid., pp 25-6.
4 APTA TransitFactBook (1999); ConnDOT, Connecticut Statewide Bus System Study (July 2000), Executive Summary.
5' Connecticut Transit 2001-02 budget; GreaterBridgeport Transit District2001-02 budget; Greater Iaterbury TransitDistrict 2001-02 budget.
6 ConnDOT, Master TransportationPlan, p. III-113.
7 ConnDOT, Southwest CorridorCommodity Study (May 2000) 8 Ibid.
9Ibid.
° Hall and Gordon, GreeningFreight: PreliminaryResearch on Heavy Duty Trucks in Southwestern Connecticut (October 1998), p 6 "1Portof New London- Can New London be a Transit ContainerPort? Management & Transportation Associates (January2001), p. 12.
12 FredericR Harris,Inc., CoastalBarge FeederStudy, South Central Connecticut (February2001), p 63.
13 This recommendation is not supported by the South Central Regional Council of Governments.
CoastalCorridor TransportationInvestment Area. Twenty-Year-Strategic Plan (November2001) 21
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1 Qt-95 ORRIDr COR QALI.TION, 5JTRATE-G 1a PLA N II7 1-315 CORlRIDO COALION www.n95con.ition org
This edition of the 1-95 Corridor Coalition's Strategic Plan comes at avery important milestone in the history of the Coalition.
For ten years, the 1-95 Corridor Coalition has been working diligently to improve the manage-ment and operations of transportation systems in our region of the nation, emphasizing issues that transcend jurisdictional and modal boundaries. The U.S. Department of Transportation and other national, regional, state and local organizations have recognized the need to place increased emphasis on transportation management and operations to provide safer and more reliable service to the traveling public. In addition, this edition of our Strategic Plan occurs as discussions regarding the content of new Federal surface transportation authorizing legisla-tion are in full swing, with system management and operations issues receiving prominent consideration. And of course, the events of September 11, 2001 have prompted transporta-tion leaders to give priority consideration to protection of our citizens and critical transportation infrastructure. More than ever, our focus will be safety and security with mobility recognizing that managing our infrastructure is as important as building it.
The 1-95 Corridor Coalition is unique in many ways. Although we have no formal operational authority, issues are successfully addressed through projects and activities formulated through a consensus process involving representatives from our member agencies throughout the 13 state region. Our perspective encompasses both passenger and freight transportation, and all modes of travel, with special attention paid to intermodal mobility of people and goods. We conduct projects and programs that address a wide range of regional transportation issues involving congested urban areas, access to ports and airports, rural mobility, and travel to numerous tourist and recreational areas.
As our regional, national and international economies and societies become increasingly in-terdependent, it is clear that improved operation and management of the entire transportation network must be addressed in a coordinated and cooperative environment across multiple jurisdictions. Our primary strategies outlined more fully in the plan are: Information Manage-ment, Facilitate Deployment across Jurisdictions and Modes, and Learning and Information Sharing.
Using these strategies, the Coalition will continue to pursue its mission of enhancing a trans-portation network in the region that is safe, efficient, seamless, intermodal, and capable of supporting economic growth in an environmentally sound manner.
On behalf of all of the members of the 1-95 Corridor Coalition, and our professional support staff, let me express our determination to work together to tackle and overcome the very difficult challenges that lie ahead for our states, our region and our nation.
Sincerely, John Platt
Contents Executive Summary ... ...... i Introduction ..... . . . ..................... 1 The Evolution of the Coalition . ............................ 2 Membership and Organization .. . 3 Transportation Issues in the Region 5 Congestion ..................................... 5 Long-Distance Travel ..................................... 6 Mobility in Rural Areas ...................................... 6 Freight Movement ...................................... 7 Emergency Response and Security ...................................... 7 Charting Our Course . ..................fh .. .... 8 Vision, Mission, and Goals ..................................... 8 Guiding Principles ...................................... 8 Strategies ..................................... 9 Benefits and Accomplishments .................................. 10 Benefiting the Traveling Public ................. .................... 10 Benefiting Member Agencies ..................................... 12 Resources ...................................................................... .............. 13 C oncl usi on ................................................ 14
Executive Summary The 1-95 Corridor Coalition is an alliance of transportation agencies, toll authorities and related organizations, including law enforcement, from the State of Maine to the State of North Carolina with affiliate members in Canada. The Coalition undertakes projects and activities to improve the management and operations of the transportation network in the region, emphasizing issues that cross jurisdictional boundaries. The Coalition also provides a forum for key decision and policy makers to address and solve transportation management and operations challenges of common interest.
Efficient transportation is vital to the region's economic health, public welfare, and the environ-ment. The Coalition's region is home to the nation's Capital, the world's financial capital, several of the nation's largest metropolitan areas; and numerous tourist destinations, small towns, and rural communities. In 2000, the gross domestic product of the 13 state region was nearly $3 trillion. If the Coalition region were a separate country, it would have the 4th largest economy in the world, behind the United States, China, and Japan.
In order for the nation to thrive, the transportation facilities that serve the region's many vital governmental, business, industrial, agricultural, entertainment, and recreational activities must be managed and operated efficiently. The demand on the region's transportation facilities are tre-mendous, as the facts state:
- The Texas Transportation Institute calculates the value of the total hours of delay experi-enced in the region as over $20 billion per year
- The residents of the region take about 250 million long-distance trips per year (trips of more than 100 miles)
- In 1997, about 165 billion ton-miles of freight moved by truck in the region
- The security of the region's many critical transportation infrastructure links and freight shipments, particularly across the region's international border with Canada, has become more vital since September 11, 2001 The Coalition helps its member agencies by enhancing management of their transportation sys-tems and operation of their facilities and services. Issues are emphasized that transcend jurisdic-tional boundaries, such as management of major incidents and emergencies, and commercial vehicle safety and operational efficiency. Additionally, the Coalition works with member agencies and others to provide multimodal traveler information services with emphasis on long-distance trips and interoperable electronic payment systems. Since efficient and safe freight movement is critical to the economic vitality and security of the region and nation, the Coalition has also been adding value to its member agencies' efforts and leveraging strong relationships with private-sector organizations to improve freight management in the region.
In the new century, the Coalition continues to expand its perspective by paying increased attention to areas of growing national and regional concern. For example, in the area of travel information in rural areas, the Coalition is supporting development and regional integration of systems that disseminate information related to road conditions and tourism. In the area of intermodal goods movement, the Coalition is working to extend the use of concepts that provide timely information on ship/rail arrivals and departures, cargo statuses, drayage operations, and traffic conditions to improve landside access to ports. Inthe area of public safety and security, the Coalition is working with member agencies and others to enhance coordination among transportation, emergency management and medical service organizations - focusing on more complete coverage across jurisdictions.
i
II 1 THE TRANSPORTATION NETWORK IN THE REGION WILL BE SAFE, EFFICIENT, SEAMLESS, INTERMODAL AND WILL SUPPORT ECONOMIC GROWTH IN AN ENVIRONMENTALLY RESPONSIVE MANNER.
WE WORK TOGETHER TO IMPROVE MULTIMODAL TRANPORTATION SERVICES IN THE REGION THROUGH INFORMATION SHARING AND COORDINATED MANAGEMENT AND OPERATIONS.
I OUR GOALS ARE TO IMPROVE MOBILITY FOR PEOPLE AND GOODS, ENHANCE SAFETY FOR'ALL TRAVELERS, AND IMPROVE THE ECONOMIC VITALITY OF THE REGION.
Throughout its life, the Coalition's long-term vision has remained a constant guide. Its mission has broadened as the Coalition has evolved, and its goals and strategies have changed to meet the new challenges confronting member agencies and the region.
A.-a The Coalition's Guiding Principles Add value to member agency programs Leverage resources by investing in projects and activities of its members and private sector organizations Achieve greater efficiency through coordinated deployments Communicate, cooperate, coordinate, and gain consensus Serves as a neutral forum and honest broker II
Three Strategies the Coalition Applies in Defining its Work Activities Learning and Information Sharing
- Facilitate communication and learning among members and partners
- Conduct forums and provide training on topics of critical importance
- Foster networking in support of sharing experiences and mutual education 2 Information Management
- Provide easier access to information for system management and operation
- Provide a source of long-distance travel information that will be disseminated to the traveling public
- Provide a source of information to support future investment decisions of the Coalition and its member agencies E3 Facilitate Deployments across Jurisdictions and Modes.
- Promote multimodal and intermodal coordination
- Encourage interoperability among jurisdictions
- Foster adoption of standards and procedures that promote deployment
- Coordinate information exchange to enhance the speed of deployment and seam-less operations The success of the Coalition is a direct reflection of the countless hours, unlimited energy, and expertise that volunteers from member agencies devote to achieving the Coalition's vision, mis-sion and goals. The Coalition will continue to recruit new volunteers with skills in emerging pro-gram areas such as information management, emergency response, freight movement, electronic payment methods, and security. In addition to contributing volunteer time, the Coalition's member agencies will continue to provide matching funds to further support Coalition projects and activi-ties.
Continuing federal investment in the activities of the Coalition will help the U.S. Department of Transportation achieve its program goals related to safety, transportation security and emergency management, congestion management, freight management, equity, and convenience while ad-vancing specific transportation management and operations initiatives throughout the region.
The members of the 1-95 Corridor Coalition recognize that the region's complex and growing trans-portation management and operations problems must be addressed through an institution that provides a mechanism for coordinating and resolving issues in a spirit of cooperation and consen-sus. The 1-95 Corridor Coalition will continue to evolve in directions that allow it to effectively serve the needs of its member agencies and the traveling public for seamless and effective transporta-tion system management and operations across all modes of travel.
iii
SAFETY AND SECURITY WITH MOBILITY STRATEGIC PLAN 2002 S E C T I o N Introduction The 1-95 Corridor Coalition is an alliance of transportation agencies, toll authorities, and related organizations, includ-ing law enforcement, from the State of Maine to the State of North Carolina, with affiliate members in Canada. This organization provides a forum for key decision and policy makers to address transportation management and opera-tions issues of common interest. Working together, the Coalition's myriad state, local and regional agencies ac-complish far more than any individual agency could by working alone.
Through projects and activities, the Coalition supports member agencies who, in turn, manage and operate the transportation systems that serve the traveling public. Over the last decade, the Coalition has served as a successful model for multi-state/jurisdictional interagency cooperation and coordination and has undertaken demonstration projects that have now become universally deployed.
Efficient transportation is vital to the region's economic health, public welfare, and the environment. The Coalition region is home to the nation's Capital, the world's financial capital, several of the nation's largest metropolitan areas; and numerous tourist destinations, small towns, and rural communities.
This Strategic Plan first provides context in the form of back-ground on the Coalition's evolution, membership, and or-ganization, and a statistical overview of transportation in Efficient transportation is vital to the regional and the the region. These are followed by the core components of nation. the Strategic Plan: Vision, Mission, and Goals; Guiding Principles; and Strategies. The core components explain the rationale for a variety of projects and other activities that member agencies, working in cooperation with each other through the Coalition, initiate to improve the region's economic vitality, mobility, and security. These projects and activities are detailed in the Coalition's Business Plan. Fi-nally, the Strategic Plan highlights benefits of the Coalition's work, and describes the resources that will be needed to continue to support that work.
1
SAFETY AND SECURITY WITH MB3ILITY S E C T I 0 N The Evolution of the Coalition The Coalition has evolved to meet its members' complex trans-portation management challenges and needs. The Coalition be-gan in the early 1990's as an informal group of transportation pro-fessionals working together to more effectively manage major high-way incidents that impacted travel across jurisdictional boundaries.
In 1993, the Coalition was formally established to enhance trans-portation mobility, safety, and efficiency in the region. Under the last two Federal-aid highway program authorization acts, the
-T Intermodal Surface Transportation Efficiency Act (ISTEA) in 1991
- -b.-- and the Transportation Equity Act for the 21 StCentury (TEA-21) in
- - -- , __ .;, ,- Nr I 1998, the Coalition received federal funds to support its continu-
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Rural travel information is an important aspect of During the late 1990s, the focus of the Coalition's program evolved the Coalition's work. from studying and testing intelligent transportation systems (ITS) technologies to a broader perspective that embraced integrated deployments and coordinated operations. The Coalition's perspec-tive evolved from a concentration on highways to one that encom-passes all modes of travel and focuses on the efficient transfer of people and goods between modes. While facilitation of regional incident management among corridor transportation and public safety agencies remains a key part of the Coalition's focus, today
_ the Coalition emphasizes information management as the under-x ; So -Juts i-=
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Is ;- - Ads % -is ran FF-G:g The Coalition supports its member agencies by enhancing trans-23 _ > _ f portation systems management and operation of their facilities
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- ,;$+iJ_4-t+oive= . .. ment systems. Since efficient and safe freight movement is criti-The Coalition is improving long distance trip cal to the economic vitality and security of the region and nation, planning. the Coalition has also been adding value to its member agencies' efforts and leveraging strong relationships with private-sector or-ganizations to improve freight management in the region.
In the new century, the Coalition continues to expand its perspec-tive by paying increased attention to areas of growing national and regional concern. For example, in the area of travel informa-tion in rural areas, the Coalition is supporting development and regional integration of systems such as Traveler Information On-line (TRIO), sponsored by Maine, New Hampshire, and Vermont; and Travel Shenandoah, sponsored by Virginia. Both of these systems disseminate information related to road conditions and 2
STRATEGIC PLAN 2002 tourism, such as lodging and recreational activities. In the area of intermodal goods movement, the Coalition is working to extend the use of concepts developed in the Port Authority of NewYork and New Jersey's Freight Information Real-time System forTransport (FIRST).
The FIRST system provides timely information on ship/rail arrivals and departures, cargo statuses, drayage operations, and traffic con-ditions to improve landside access to New York and northern New Jersey ports. Finally, in the area of public safety and security, the Coalition is working with member agencies and others to enhance coordination among transportation and emergency management and medical services organizations-focusing on more complete and co-ordinated coverage across jurisdictions.
S E C T I 0 N Membership and Organization The lifeblood of the Coalition is the work of member agency volun-teers structured under the following Program Track Committees: Pro-gram Management, Inter-Regional Multimodal Traveler Information, Coordinated Incident Management, Commercial Vehicle Operations, Intermodal Transfer of People and Goods, and Electronic Payment Services. These volunteers develop and oversee annual programs of projects and activities in the Program Track functional areas. A steer-ing committee, consisting of senior transportation management and More is accomplished by learning and working operations officials from member agencies, coordinates the work of together.
the Program Track committees. An executive board, consisting of chief executives from member agencies, provides policy and program-matic guidance. A small staff of professionals provides support and conducts the Coalition's day-to-day business. Projects and activities are undertaken by Coalition staff, the Coalition's consultant support team, or through member agency procurement processes.
The Coalition is neither a chartered regional transportation authority nor an incorporated entity. Itoperates through an agreed-upon set of procedural guidelines. Membership does not involve payment of dues, and no formal agreement exists among its members. Despite its "vir-tual" nature, the Coalition's partnership is strong, real, and growing.
The Coalition enables its myriad state, local, and regional member Member agency volunteers are the Coalition's agencies to accomplish far more together than they could alone. Ul- energizing force.
timately, the beneficiaries of these efforts are the people who travel and consume the goods that move throughout the region.
3
SAFETY AND SECURITY WITH MOBILITY AExecutive Director Executive Board I I
Staff l [ Steering Committee l A Consultant Teaml Program Track Committees
, rr# -f 4-J'S,<N2 3> 45)c~" #6 ,itJ5Ata Program Inter-Regional Coordinated Commercial Intermodal Electronic Management Travel Incident Vehicle sfer ofe Managme nformatvon Management Operations People Services
-Task Forces'. HOGs Regions Subcommittees IEN New England Passenger Training NewYork Freight Outreach Delaware Valley Standards Potomac ISCOM Strategic Planning The Coalition develops and coordinates its work through functional area program tracks.
4
STRATEGIC PLAN 2002 S ET C TrIatIs in th Transportation Issues in the Region The Coalition's projects and activities address several important aspects of travel in the region: congestion, long-distance travel, mobility in rural areas, freight movement, and emergency response and security.
Land Area Poputlallon Congestion lUn1ted Stats; The region encompasses 268,000 square miles-about 7% of the area of
- 73% the 50 states, and about 10% of the landmass of the contiguous 48 states.
United States The region's population of just over 75 million comprises about 27% of the Coarition American population. With 27% of the nation's population living on 7% of its land, the Coalition is very densely settled. The overall residential den-sity of the region is 281 persons per square mile-5 times the average The density of the Coalition region population density of the rest of the United States.
leads to congested travel Most of the Coalition region's population-about 72%, or 55 million resi-dents-lives in its 45 major metropolitan areas, as defined by the Year 2000 U.S. Census. In contrast, for the United States as a whole, only half of the population resides in major metropolitan areas. The 55 million met-ropolitan area residents in the Coalition region live on 76,000 square miles, with an average density of about 733 persons per square mile.
As a natural consequence, the region is home to some of the most con-centrated transportation demand in the country, and therefore, some of the most congested highway facilities and longest daily commute times.
A decade previous, the New York City/Northern New Jersey metropolitan area lost some 348 million hours per year to traffic delay. By 1999, that number had grown 64% to 566 million hours per year. The Texas Trans-In the New York City area, congestion grew portation Institute calculates the value of the total hours of delay experi-by 64% in ten years. enced in the region's 13 states and the District of Columbia as over $20 billion per year. Today, more than 15% of the region's workers have commutes longer than 45 minutes.
Congestion in the region continues to worsen despite the fact that a vari-ety of transportation modal options exist. Thirty-two percent of the resi-dents in the region travel to work by modes other than driving by itself, contrasted with 25% in the rest of the country.
Congestion in the region is not limited to highways. Core capacities in transit systems from Boston to Washington, D.C., will also be exceeded during the next 20 years. Nationwide, transit ridership in the year 2000 reached its highest level in more than 40 years, and indications are that the trend will continue. At some of the Coalition region's major airports, as few as 70% of monthly take-offs, and 62% of arrivals, occur on time.
Amtrak's passenger miles in the Northeast Corridor are expected to rise Rail traffic is projected to grow significantly from 1.7 billion in 2002 (2/3 of national ridership) to 3.5 billion by 2025.
over the next 25 years.
Simultaneously, freight demand for the same track will continue to grow, causing severe constraints in areas such as Baltimore and NewYork City.
5
SAFETY AND SECURITY WITH MOBILITY Long-Distance Travel The residents of the Coalition region take about 250 million long-distance trips per year (trips of more than 100 miles). About 65% of long-distance trips in the region are taken for pleasure, 22% for business purposes, and 13% for personal-business purposes.
About 77% of these long distance trips are made by personal vehicles.
However, because of the population density and the variety of modal options available, residents in the region actually drive about 35% fewer miles in long-distance trips than do residents in the rest of the country (1,600 miles per year versus 2,500 miles per year). As illustrated in the table below, public-mode trips, i.e., those by air, rail, and bus, play a sig-nificant role in serving long-distance travel in the region. The 27% of the nation that resides in the region takes 62% of the nation's long-distance rail trips and 35% of the nation's long-distance intercity bus trips.
Long Distance Trips by Mode: 1-95 Coalition Region vs. Rest of USA Coalition Regioni 193,935,634 47,555,435 7,498,288 3,110,689 650,748 252,815,701 Rest of USA 631,863,029 140,280,283 13,905,171 1,944,854 1,623,634 789,799,455 Total 825,798,663 187,835,718 21,403,459 5,055,543 2,274,382 1,042,615,156 Mode Share:
Coalition Region 76.7% 18.8% 3.0% 1.2% 0.3%
Rest of USA 80.0 17.8% 1.8% 0.2% 0.2%
Mobility in Rural Areas Although much of the population is associated with one of the Coalition region's 45 major metropolitan areas, the region is actually characterized by a variety of settlement patterns and subsequent travel flow patterns.
In fact, as illustrated in the adjacent map, about 70% of the land area in the region is not associated with one of these metropolitan areas.
The 28% of the population, or 20 million residents, that lives outside of the region's metropolitan areas, in its small town and rural areas, has an average density of about 103 persons per square mile. The density of the region's population in rural areas is still about twice the average of the population density of the nation as a whole. Thus, the region's rural trans-portation issues differ fundamentally from rural transportation issues in much of the rest of the country, and the region's rural transportation is-sues differ from the region's metropolitan area transportation issues.
For example, because the region's rural population is less wealthy than its metropolitan area population, and multimodal travel options are gen-The Coalition's program addresses a wide erally less available or accessible to its rural population, auto use in rural variety of travel characteristics. areas is more essential. While 27% of the region's metropolitan-area a
STRATEGIC PLAN 2002 population lives in households with no autos, only 22% of the rural-area population lives in households with no autos. People in rural areas travel about 30% more long-distance miles by car than people in metropolitan areas, due mainly to the greater affordability of and access to commer- :9 :4 -41 l cial aviation in metropolitan areas.
Freight Movement During the past several decades, significant changes in the logistics of the freight distribution process have resulted in smaller and more fre-quent freight shipments and less inventory stored in warehouses. This has had a massive effect on the amount of truck travel on the region's highways. In 1997, about 165 billion ton-miles of freight moved by truck in the region. According to national statistics, freight volume doubled between 1975 and 1995, and forecasts predict the volume will double Changes in distribution logistics are leading again by 2025. to a dramatic increase in freight traffic.
In 21 of the region's airports, air cargo grew by 28% between 1995 and 2000. Nationally, air cargo is expected to jump from 12 billion to 44 billion ton-miles by 2025. During the 1990's, container traffic at 7 of the region's ports (New York/New Jersey, Baltimore, Philadelphia, Wilmington, Bos-ton, Richmond and Portland) increased by 47%.
Port operations, and port connections by truck and rail, will become in-creasingly taxed. Over the next decades, a new generation of megaships could double the amount of intermodal container traffic and create surges of demand within the ports and on the connecting transportation sys-tems. Port operations, intermodal connections, and surface transporta-tion operations must all be dramatically improved to deal with these ex-pected volume increases.
Emergency Response and Security The events of September 11, 2001 left an indelible mark on the region.
Transportation officials learned a great deal about the region's transpor-tation systems from the attacks in New York City and Washington, D.C.
One clear lesson was the need to improve communications and informa-tion sharing among emergency response and transportation manage-ment agencies, especially across jurisdictional boundaries. Because of the proximity and size of the region's large metropolitan areas, these issues must be addressed not only across local jurisdictional boundaries, but also across several state boundaries.
The security of the region's many critical transportation infrastructure links and freight shipments, particularly across the region's international border with Canada, has become more vital since September 11, 2001. Emergency response and security are critical regional concerns.
The ability to monitor and share information about cargo, containers, ve-hicles, and operators across information systems operated by different agencies in different jurisdictions will take on ever-increasing significance as the volume of freight traffic on the region's transportation facilities grows dramatically over the coming years.
7
SAFETY AND SECURITY WITH MOBILITY S E C T I 0 N4 I Av V
Charting Our Course Vision, Mission, and Goals Throughout its life, the Coalition's long-term vision has remained a con-stant guide. Its mission has broadened as the Coalition has evolved, and its goals and strategies have changed to meet the new challenges con-fronting member agencies and the region. Together, these guidance state-ments assure that the Coalition will move in a strong, consistent direc-tion, with the ability to tailor new action agendas to best respond to chang-THE TRANSPORTATION ing conditions and member and user needs.
NETWORK IN THE RE13ION WILL BE SAFE, EFFICIENT, SEAMLESS, INTERMODAL Guiding Principles AND WILL SUPPORT ECONOMIC G3ROWTH IN AN The Coalition is guided by a set of principles that shape both what it does ENVIRONMENTALLY and the ways in which its members collaborate.
RESPONSIVE MANNER.
The Coalition adds value to member agency programs by doing things that would otherwise not get done. For example, the Coalition enhances the ability of member agencies to provide important information to travel-ers that may greatly reduce unnecessary delays and economic costs by WE WORK TOGETHER TO providing traffic management system operators with information on ma-IMPROVE MULTIMODAL jor incidents in other jurisdictions through its electronic Information Ex-TRANPORTATION SERVICEB IN change Network (IEN).
THE REGION THROUGH INFORMATION SHARING AND The Coalition leverages resources by investing in projects and activities COORDINATED MANAGEMENT in which its members and/or private sector organizations are also invest-AND OPERATIONS. ing, thereby extending the value of the individual investments. For ex-ample, a study of rail bottlenecks and potential solutions in the southern portion of the region, known as the Mid-Atlantic Rail Study, exemplifies cooperation across jurisdictions and the pooling of resources among the OUR GOALS ARE TO IMPROVE Coalition's five contributing states: Delaware, Maryland, New Jersey, Penn-MOBILITY FOR PEOPLE AND sylvania, and Virginia; and three private railroads: Amtrak, CSX, and GOODS, ENHANCE SAFETY Norfolk Southern. This partnership undertaking would likely not have FOR ALL TRAVELERS, AND occurred without the collaboration available through the Coalition's spon-IMPROVE THE ECONOMIC sorship.
VITALITY OF THE REGION.
The Coalition invests in projects and activities that achieve greater effi-ciency through coordinated deployments. Many Coalition activities demonstrate this principle. For example, the Coalition supports the work of its members and the Federal Motor Carrier Safety Administration to achieve improved commercial vehicle safety and operational efficiency through the national Commercial Vehicle Information System and Net-works (CVISN) deployment program.
The 'four Cs": communication, cooperation, coordination, and con-sensus, are another guiding principle that shapes both projects and the ways in which members work together. For example, the Coalition sup-ports work related to the interoperability of short-range communication a
STRATEGIC PLAN 2002 technology between electronic toll collection and commercial vehicle elec-tronic screening applications. It also supports work related to achieving the goal of integrating the payment of highway tolls, public transportation fares and consumer purchases.
The Coalition serves as a neutral forum and honest broker for discussion of transportation issues that are important to the corridor and the nation. Co-sponsorship of important conferences and workshops with organizations such as the U.S. Department of Transportation and ITS America reflect the 4 Coalition's ability to work with national organizations on topics that merit at- Ci tention and collaborative work. The Coalition has held information exchange 8 forums regularly since its inception. The forums provide valuable opportuni- The Coalition brings people together to shar ties for members to share experiences and insights and to learn from each information and solve problems other on topics such as integrated implementation of the 511 national travel information telephone number; commercial vehicle operations, safety, and security; and emergency transportation operations preparedness and re-sponse.
Strategies The Coalition applies three strategies in defining its work activities:
Learning and Information Sharing. The Coalition provides organiza- LEARNING AND tional and technical support to foster learning and information sharing INFORMATION SHARING among Coalition member organizations and with others in order to:
- Facilitate communication and learning among members and partners
- Conduct forums and provide training on topics of critical importance
- Foster networking in support of sharing experiences and mutual edu-cation.
Information Management. The Coalition helps develop and manage INFORMATION information systems that: MANAGEMENT
- Provide easier access to information that will assist member agen-cies with system management and operation
- Provide a source of long-distance travel information that will be shared with the traveling public through a variety of public and private dis-semination methods
- Provide a source of information to support future investment deci-sions of the Coalition and its member agencies.
Facilitate Deployments across Jurisdictions and Modes. The Coali- FACILITATE tion accelerates coordinated system management and operations by fa- DEPLOYMENTS cilitating deployments of cross-jurisdictional and multimodal programs and services in order to:
- Promote multimodal and intermodal coordination
- Encourage interoperability among jurisdictions
- Foster adoption of standards and procedures that promote deploy-ment
- Coordinate information exchange to enhance the speed of deploy-ment and seamless operations.
9
SAFETY AND SECURITY WITH MOBILITY S E C T I 0 N Benefits and Accomplishments Throughout its existence, the Coalition has benefited the traveling public and member agency personnel in numerous ways. The Coalition's projects and activities will continue to focus on providing the benefits associated with coordinated and seamless transportation manage-ment and operations services.
Benefiting the Traveling Public Incident and emergency response. The public experiences fewer unnecessary delays and fewer secondary accidents due to dramati-cally improved coordinated responses to both small and large-scale incidents and emergencies. These improvements are a direct result of the learning, information sharing, and personal relationships estab-lished during regular meetings of the Coalition's Highway Operations Groups. This trend was particularly evident in the aftermath of the September 11, 2001 tragedies when the trust rooted in personal rela-tionships established through the Coalition helped overcome the over-load and destruction of communications systems. The Coalition is working with its members and other groups and organizations to con-tinue to improve incident and emergency response capabilities by im-Coordinated response reduces delay caused proving coordination among transportation, emergency, medical, and by incidents.
telematics organizations throughout the region.
Coordinated operations. Travelers will increasingly be able to ob-tain advance notice of operational problems and experience fewer delays as the Coalition helps to coordinate traffic management and traveler information services throughout the region by developing an expanded, enhanced, and more accessible information system archi-tecture. This architecture will allow transportation agencies to auto-
.11 I .11 Z4 -I lo VA 9 M-11 V 4:.r-.,#9 1.1 matically obtain or share travel times, the locations and impacts of construction activities and major incidents, roadway condition data, and other important travel information. This activity leverages the in-vestments made in the Coalition's existing lEN and the transportation management and traveler information systems of member agencies.
The IEN was one of the nation's earliest successes at a regional ar-chitecture through which information is electronically shared among multiple transportation agencies-at a geographic scale still unprec-edented.
- 44. 1 Traveler information. Travelers avoid delays associated with planned construction activity through the Coalition's popularTraveler Alert Map.
More than 300,000 copies of the Map are distributed twice a year to Information sharing enables operators to provide advance warnings.
the traveling public and transportation companies at rest areas and welcome centers, and by member agencies' public affairs offices. Trav-elers can also gather information through Web sites and other meth-10
.r STRATEGIC PLAN 2002
-t ods as a result of seed funding that the Coalition provided to help estab-lish systems in New England and along the 1-81 Corridor. Travelers will be able to easily obtain current travel information as the Coalition works with its members to coordinate the implementation of the national 511 travel information telephone number across state boundaries. Travelers will also be able to make better long-distance travel decisions as the Coalition encourages establishment of a capability that will allow inter-city travelers to pick the best options for their trips based on factors such as travel time, cost, and mode.
Intermodal passenger movements. Passenger movements between Newark International Airport and local, regional, and national rail ser- I vices were improved when the Coalition supported Amtrak, New Jersey 511 will become a source of regional travel Transit, and the Port Authority of New York and New Jersey in preparing information.
for the opening of the Newark Airtrain rail station. The Coalition pre-pared guidelines for integrating communications among rail operators during significant delays and led orientation sessions about the new intermodal link and customer service needs given to more than 600 employees and airport service providers. The Coalition is continuing to assist by assessing the potential for further integration with other pas-senger information systems in the area.
Freight movement safety and efficiency. Working in cooperation with the Federal Highway Administration and the Federal Motor Carrier Safety Administration in the U.S. Department of Transportation, the Coalition improved the safety and reduced the cost of freight movements on com-mercial vehicles. The Coalition accomplished this by sponsoring training courses and workshops and by providing technical assistance services for CVISN program development. For example, the Coalition enabled participating states to rapidly implement the U.S. DOT's SAFER system Trips involving multiple modes are being software into commercial vehicle safety inspection programs. Informa- made more efficient.
tion that previously took as long as 9 months to reach the national data-base that identifies carriers with poor safety inspection and accident his-tories is now uploaded in real time.The Coalition also enabled the devel-opment of One-Stop Credentialing and Registration in NewYork. This is e N_-11 11 _ 5l-VA AZI-40 a Web-based interface to four legacy systems that allows commercial vehicle operators to apply for and receive credentials much more effi- _ - Z.g ciently than New York's previous system.
The Coalition will increase motor carrier participation in the CVISN pro-gram by sponsoring a pilot program that demonstrates the use of a single cram -,._1 transponder that supports both electronic toll collection and commercial vehicle electronic screening applications.
The Coalition will reduce the cost of freight movement by investing in the development and use of port and rail information management systems.
The Coalition plans to improve security by investing in the testing, evalu-ation, and deployment of technologies related to vehicle safety and ve-hicle and driver identification for safety and security screening. Commercial vehicle movements are safer and more efficient.
I1
SAFETY AND SECURITY WITH MOBILITY TVIZI Electronic payment of transportation services. The Coalition will make payment for transportation services much easier and more con-venient by facilitating discussions about establishing an electronic pay-
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- 'gi '^-' h -' A'"
.k1.t~~~it,_-7A i a ment method and process that integrates payment for tolls, public trans-portation, parking, and other transportation and commercial services.
Benefiting Member Agencies Information sharing. The Coalition Connection Web site (www.i95coalition org) offers a wealth of information to personnel in mem-F - - ber agencies; other professionals; and, via links to other Web sites, Payment for transportation services is more directly to travelers in the region. The Coalition's e-mail forums provide convenient. a convenient way for transportation operations personnel throughout the region to collect information on specific questions or topics of gen-eral interest.
Learning. The Coalition's Information Exchange Forums, typically at-
_i ,KI tended by 75 to 100 participants, offer opportunities for personnel from member agencies to learn and share information on important topics.
Past Forums have addressed issues such as public relations, staff hir-ing and retention, telecommunications resource sharing with private providers, and techniques for clearing incidents quickly. To further en-hance learning among transportation professionals, the Coalition pro-vided seed money to form the Consortium for ITS Training and Educa-tion (CITE). Led by the University of Maryland, in conjunction with more than 70 university partners worldwide, CITE uses distance learning to train graduate students and transportation professionals in system management and operations. In addition to those offered through CITE, The Coalition's website is a rich source of the Coalition supports training activities in areas such as innovative information. incident management techniques, new national standards, and traffic management center operator training.
Reducing system deployment risk. The Coalition has been lowering the cost and risk of implementing transportation management systems by advancing the development and use of national standards through various testing, evaluation, and training activities.
< t>w< - i-4e Improving transportation analyses. The Coalition is helping to im-prove the multi-jurisdictional analysis of proposed capacity-enhancing and operational improvements by sponsoring the development of infor-mation systems that will assist member agencies in analyzing the move-ment of people and freight across jurisdictions.
Ai' v;;-:x klf__,X, w^5;~h
-- ,_ -4 Tools are being developed to facilitate multi-jurisdictional analyses.
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STRATEGIC PLAN 2002 S E C T I C1 Nx V I Resources The success of the Coalition is a direct reflection of the countless hours, unlimited energy, and expertise volunteers from member agencies devote to achieving the Coalition's vision, mission, and goals. Volunteers from mem-ber agencies participate in leadership roles, on program track committees and various task forces, and as project managers. Agencies that are mem-bers of the Coalition provide procurement services for Coalition projects and loan staff for full-time Coalition staff assignments.
Need for the Coalition's services will continue to grow and evolve, both geo-graphically and programmatically, requiring that volunteer personnel resources also continue to grow and evolve. This will be accomplished by recruiting new volunteers with skills in emerging program areas such as information management, emergency response, freight movement, electronic payment methods, and security.
In addition to contributing volunteer time, the Coalition's member agencies have provided over $79 million in matching funds (through federal fiscal year 2001) to further support Coalition projects and activities. This clearly demon-strates the value of the Coalition's programs to its members. Member agency matching funds are either identified as project-specific matches or contrib-uted to a pooled fund that supports general activities such as management of the Coalition Connection web site, Information Exchange Forums and train-ing activities. Increasingly, the Coalition will look to leverage its investments by providing seed or supplemental funding to projects supported by member agencies with their own funding resources.
As a result of provisions in both the ISTEA and TEA-21 federal-aid highway program authorizing legislation, the U.S. Department of Transportation has provided $52.2 million in funds (through federal fiscal year 2001) that the Coalition has invested in projects and other activities, and for staff and con-sulting support costs. Federal fiscal year 2003 is the last year authorized by the TEA-21 legislation. New federal-aid highway program authorizing legis-lation will cover federal fiscal year 2004 and beyond.
Continuing federal investment in the activities of the Coalition will help the U.S. Department of Transportation achieve its program goals related to safety, transportation security and emergency management, congestion manage-ment, freight management, equity, and convenience while advancing spe-cific transportation management and operations initiatives throughout the Mid-Atlantic and Northeast. These initiatives include deployment of a traffic management and travel information infrastructure, including deployment of related national standards; coordinated deployment of the national 511 travel information telephone number; CVISN deployment, including related secu-rity applications; compatible short-range communications applications; and integrated electronic payment methods and processes.
The Coalition will continue to manage its resources effectively by using es-tablished and comprehensive management processes and information sys-tems, including budget allocations, monitoring of project progress and spend-ing, and completed project financial and results information.
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SAFETY AND SECURITY WITH MOBILITY S E C T I 0 N v VI Conclusion The Northeast and Mid-Atlantic region of the United States hosts many of the nation's vital governmental, business, industrial, agricultural, entertainment, and recreational activities. In order for the nation to thrive, the transportation facilities that serve these activities must be managed and operated efficiently. Since many of the trips resulting from these activities, whether trans-porting freight or people, cross over multiple state and authority jurisdictional boundaries, no single operating entity is respon-sible for the overall efficiency, safety, comfort, or cost of travel, or its effects on the environment.
The members of the 1-95 Corridor Coalition recognize that the 1 region's complex and growing transportation management and operations problems must be addressed through an institution that provides a mechanism for coordinating and resolving is-sues in a spirit of cooperation and consensus. The 1-95 Corri-dor Coalition will continue to evolve in directions that allow itto effectively serve the needs of its member agencies and the trav-eling public for seamless and effective transportation system management and operations across all modes of travel.
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STRATEGIC PLAN 2002 15
v .- A "More than ever, our focus will be safety and security with mobility recognizing that managing our infrastructureis as importantas building it."
- John Platt Chair, Executive Board, 1-95 Corridor Coalition Executive Director, New York State Thruway Authority 1-95 CORRIDOR COALITION ww 195coalitionna-g
? 0 1-95 Corridor Coalition Members Spring 2002 American Association of Motor Vehicle Massachusetts Turnpike Authority Administrators Metropolitan Transportation Authority (New York)
American Automobile Association Foundation for Metropolitan Transportation Authority (New York)
Traffic Safety Bridges and Tunnels American Bus Association National Capital Region Transportation Planning American Trucking Association Foundation Board Amtrak Association of American Railroads National Industrial Transportation League Baltimore Metropolitan Council National Private Truck Council Coalition of Northeastern Governors New Brunswick (Canada) Department of Connecticut Department of Transportation Transportation Delaware Department of Transportation New Hampshire Department of Transportation Delaware River and BayAuthority New Jersey Department of Transportation Delaware River Port Authority New Jersey Highway Authority Delaware Valley Regional Planning Commission New Jersey Transit District of Columbia Department of Public Works New Jersey Turnpike Authority Federal Highway Administration New York City Department of Transportation Federal Motor Carrier Safety Administration New York State Department of Transportation Federal Railroad Administration New York State Bridge Authority Federal Transit Administration New York State Thruway Authority Greater Bridgeport (CT) Transit Authority North Carolina Department of Transportation High Speed Ground Transportation Association Pennsylvania Department of Transportation Intermodal Association of North America Pennsylvania Turnpike Commission International Bridge, Tunnel & Turnpike Association Port Authority of New York and New Jersey ITS America Rhode Island Department of Transportation Maine Department of Transportation South Jersey Transportation Authority Maine Turnpike Authority TRANSCOM Maryland Department of Transportation (and U.S. Department of Transportation Office of Maryland State Highway Administration) Intermodalism Maryland Transportation Authority Vermont Agency of Transportation Massachusetts Highway Department (and Executive Virginia Department of Transportation Office of Transportation and Construction)
I llSAFETY AND SECURITY WITH MOBILITY