December 31, 1999

Ms. Anita Everhard, Executive Secretary
PA State Transportation Commission
555 Walnut Street – 9th Floor
Harrisburg, PA 17101-1900

Subject: SAVE 2-Lane Alternative, PA Route 41, Delaware State Line to Gap PA

Dear Ms. Everhard:

We write to voice support for the alternative highway solution developed by the citizen group, SAVE (Safety, Agriculture, Villages, Environment), for the PA Route 41 corridor in Chester County. This alternative is designed to address the real highway needs in the corridor while minimizing unnecessary construction and highway capacity expansion.

We understand that there are serious transportation problems which need solutions in this Route 41 corridor. There are safety problems which need to be addressed. There are equally troubling congestion problems, especially in villages such as Avondale. However, we believe that the conventional transportation solutions being proposed by PennDOT, which feature significantly expanded traffic capacity through bypasses and additional lanes, will ultimately induce even more serious transportation and environmental problems.

The Conservancy supports the SAVE 2-lane Alternative solution because it will provide traffic solutions at minimum cost and with minimum secondary impacts. Our reasoning is as follows.

• At the top of our list of concerns is minimizing growth inducement in this sensitive and valuable area. Historically, no single factor has increased development pressure more than new highway construction. Development pressures are already beginning to be felt in this corridor. Highway alternatives which add significantly to effective highway capacity through bypasses and additional lanes will most certainly induce significant additional development pressures. Not only will development proliferate and intensify at highway and bypass intersections, but residential development will further leapfrog out into the agricultural countryside, as has happened countless times and in numerous places throughout Chester County. In fact, this induced development itself will rapidly come to overtax the new highway as well as the local rural "feeder" roads, quite possibly creating more serious traffic problems than are being faced at present.
• Additional development is not desirable in this corridor. Route 41 cuts through the largest remaining expanse of prime farmland in Chester County and, we believe, in the Philadelphia metropolitan area. Like neighboring Lancaster County, this is a tremendously fertile agricultural community. This point is vividly demonstrated by the recently adopted Chester County Landscapes plan wherein the corridor is broadly classified as "Rural Landscape" and "Natural Landscape," where infrastructure is to be limited. Construction of a new highway would not be compatible with the recommendations in Landscapes.
• Significant state and county monies have already been spent to purchase agricultural easements in this corridor in order to preserve farming and protect natural areas. An impressive number of private landowners have donated conservation easements on literally thousands of acres of land in these municipalities. We believe that there simply are no other examples of this kind of private landowner commitment in the eastern United States. As impressive as these efforts might be, the majority of the land still remains vulnerable and unprotected. A development-inducing highway project could seriously undermine these vitally important land stewardship efforts.
• Route 41 also cuts through a corridor which is comprised of multiple headwaters areas, including the Brandywine Creek, the Red Clay Creek, and the White Clay Creek. These streams flow to regionally important water supply systems and environmentally sensitive waterways and waterbodies. As a result of a variety of programs, such as the pending Wild and Scenic Rivers status for the White Clay, significant federal and state funds are being directed into these watersheds to both remediate existing problems and prevent new problems from developing. Conventional growth-inducing highway alternatives can be expected to have a significant adverse impact on these water resources, both in terms of water quality and water quantity, and are inconsistent with all of these good efforts.
• Although there are some meaningful exceptions, many of the rural municipalities which will be affected have ordinances that are ineffective in dealing with induced development pressures. In fact, large portions of the existing prime farmland are currently zoned for large lot residential development, and are, therefore, vulnerable to developer advances.
• We believe that the PennDOT termination of the study area at PA 926 is misleading and short-sighted. We believe that the remainder of the PA 41 corridor north of 926 to Gap will have to undergo comparable expansion soon and therefore should be included in the study area. Because the environmental impact statement (EIS) being prepared will not address this zone, important potential impacts will not be assessed. Furthermore, we are concerned that the EIS will not fully assess the secondary impacts which are so critical in this project, especially the question of induced development.
• Lastly, if new highway construction and/or a significantly expanded capacity alternative is selected, project funding should be made contingent upon each municipality’s adoption of essential growth management regulations (possibly to be specified and approved by the Chester County Planning Commission), all of which should be specified in signed Memos of Agreement between PennDOT and the municipalities.

We urge the Commission to consider the above points thoroughly before a decision is made. We believe that every effort should be made to investigate and apply carefully defined, "low profile" solutions to this highway problem, as advanced by SAVE in the 2-Lane Alternative.

Please contact Wesley Horner (610-388-8352) at our office if you have any questions. We appreciate this opportunity to comment.

Sincerely,

Kathryn A. Saterson
Director
Environmental Management Center
Brandywine Conservancy