In the Final Needs Study for PA Route 41 (1994), written for PennDOT by KCI, concluded that Route 41 needed PennDOT's attention to address four primary needs: Safety, Congestion, Infrastructure Improvements, and Multi-modal Capacity. In conjunction with professional transportation engineers and planners, including Smart Mobility, Inc., and Glatting, Jackson, Kercher, S.A.V.E. has proposed a concept plan for a two-lane alternative for the full length of the Route 41 corridor. This two-lane plan, punctuated by a series of roundabouts, satisfies all four needs outlined by KCI, and does so in a superior fashion than any four-lane alternative offered by PennDOT. As described elsewhere in this booklet, and in numerous studies, roundabouts would create the safest roadway possible, reduce congestion and traffic delays, and provide the best solution for multi-modal enhancements.

The two-lane "roundabout centered" plan could be designed, funded, and built, for the entire length of PA Route 41, much more quickly and at a fraction of the cost than any four lane alternative. Currently, PennDOT's schemes are only planning for approximately the southern half of the roadway, from the Delaware line to the Route 926 intersection, and construction is not even projected to begin until 2007.

COSTS and TIME LINES OF TWO-LANE PLAN VERSUS FOUR-LANE PLAN
Typical PennDOT four-lane plan (Delaware to PA926)
	Cost/mile	Total Cost
Chatham Bypass - 1.4 miles	$20 million	$28 million
Avondale Bypass - 2.6 miles	$20 million	$52 million
On-alignment widening - 5.8 miles	$9 million	$52.2 million
Estimated right-of-way purchase		$17.5 million
Project total		$149.7 million
Two-lane alternative (Delaware to PA926)
Avondale Bypass - 0.3 miles	$10 million	$3 million
Rural rehabilitation - 4.6 miles	$1.5 million	$6.9 million
Developed area rehab - 4.9 miles	$3 million	$17.15 million
Estimated right-of-way purchase		$2 million
Project total		$29.05 million
Two-lane alternative - PA926 to PA30
Full rehabilitation, intersection improvements, roundabouts		$17.75 million
Two-lane project total for entire roadway		$46.8 million
Estimate for a typical PennDOT four lane road, entire length		$245 million
Anticipated completion of two-lane project, entire roadway		2007 at latest
Anticipated completion of four-lane project, Delaware to 926		2007 at earliest
Anticipated completion of four-lane project, entire roadway		????

Setting aside the controversial Avondale bypass, the on-alignment project would be designed, funded and constructed in significantly less time, in part due to the minimal environmental impact of the two-lane roundabout alternative. There would be a Finding of No Significant Impact (FONSI) determination under NEPA regulations, thereby fast tracking the project to full design and construction with less extensive and less expensive environmental review.

S.A.V.E.'s alternative could be immediately accepted by PennDOT as the preferred alternative for the Route 41 project without further consideration in the ongoing NEPA process. Excepting the Avondale Bypass, the two-lane alternative would not be subject to the environmental impact statement ("EIS") requirements of the National Environmental Policy Act ("NEPA") by qualifying for a "finding of no significant impact" to the environment, otherwise known as a "FONSI" under NEPA. Nothing under NEPA requires PennDOT to complete the EIS process if it decides to modify the scope of project in a manner that results in no significant impact on the environment. Therefore, a compelling advantage to the two-lane alternative is that it can be implemented expeditiously so that critically-needed safety enhancements can be completed in a matter of months.

Under NEPA, before any major federal action that causes a significant impact to the environment can be approved, an EIS must be prepared comparing all the project alternatives and ensuring that there is a hard look at the potential environmental ramifications. By PennDOT's own admission, each of PennDOT's proposed four-lane alternatives would constitute a significant impact to the environment and will require that PennDOT prepare an EIS before choosing its preferred alternative.

An EIS is a detailed and complex document that takes years to prepare and must conform to the requirements of the Council on Environmental Quality (CEQ) and Federal Highway Administration FHWA) regulations (40 C.F.R. Parts 1500-1508 and 23 C.F.R. 771). In fact, after nearly a decade of study and analysis of PA 41 PennDOT is only at step five of its ten-step process for preparation of an EIS. An EIS for the PA 41 project can be as long as 300 pages not including references and will be open to extensive and time consuming public comment. In addition, the EIS process is wrought with potential pitfalls that will leave PennDOT vulnerable to expensive and time consuming litigation and may require, among other things, preparation of a new or supplemental EIS or abandonment of the chosen alternative.

If the Avondale Bypass were separated out into a separate project, the two-lane plan qualifies for a FONSI under FHWA's categorical exclusions to the EIS requirements because it will: not "induce significant impacts to planned growth or land use; not require the relocation of significant numbers of people; not significantly impact cultural, historic, recreational or natural resources of Chester County; reduce air, noise or water quality impact in Chester County; and, not significantly impact travel patterns (23 C.F.R. § 771.117(a))". In fact, the S.A.V.E. Proposal is nearly identical to two of the examples of a categorical exclusion that is automatically eligible for a FONSI identified at 23 C.F.R. § 771.117(d):

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

(2) Highway safety or traffic operations improvement projects including the installation of ramp metering control devices and lighting.

In addition, one of the driving forces behind PennDOT's decision to perform an EIS, the substantial controversy caused by the massive four-lane proposals, will be eliminated, further supporting a FONSI. S.A.V.E. is the primary advocate for a sensible solution to PA 41's problems and, therefore, has been the most vocal opponent to PennDOT's four-lane proposals based on concerns about environmental impact. If PennDOT adopts the S.A.V.E. Proposal it will eliminate the "substantial controversy related to the project on environmental grounds."

Finally, even though PennDOT has informed interested parties that it intends to prepare an EIS for the PA 41 project, it can still issue a FONSI for the modified proposal. By modifying its proposal to exclude four-lane alternatives and to instead move forward with the S.A.V.E. proposal, PennDOT will mitigate the environmental impacts of the four-lane plans and avoid causing any significant impacts. This will allow PennDOT to avoid an EIS and issue a FONSI (Cabinet Mountains Wilderness v. United States Forest Service, 685 F. 2d 678, 682 (D.C. Cir. 1982), modification of a proposal to avoid causing significant environmental impact obviates the requirement to prepare an EIS).

In addition, PennDOT has barely begun to fulfill requirements under the national Historic Preservation Act Section 106, which mandates that whenever federal funds are involved in projects that have potential adverse effects on historic resources, the potential effects must be reviewed and minimized. The whole 106 process could be drastically foreshortened if the two-lane alternative is chosen, as the impact on historic resources would be minimal.

Chester County's national award-winning comprehensive plan, Landscapes, emphasizes that the Route 41 corridor is to remain a rural landscape, with natural open space and agricultural lands dominating the corridor, with revitalized town centers in Avondale, Chatham, Cochranville, West Grove and Atglen. The innovative use of roundabouts throughout the corridor would compliment the vision laid out in Landscapes for a sustainable future for the Route 41 community. Nowhere does Landscapes show areas designated "suburban" in the Route 41 corridor, in contrast to other roadways, such as Route 202. Landscapes also states [section 4.1.3] "the development of new highways which stimulate development in rural and natural landscapes should be discouraged."

A two-lane plan for PA Route 41 would also be most compatible with the Delaware Department of Transportation's plans for the segments of Route 41 from the Pennsylvania/Delaware state line through Hockessin where a traffic calming project will soon be implemented. In addition, DelDOT has no long range plans to widen DE Route 7 from the Pennsylvania line.

In short, roundabouts dovetail perfectly in a transportation plan that envisions a sustainable future for Route 41 and its communities, as they provide:

• Superior solutions to meet the four primary needs of the roadway: safety, capacity, infrastructure, inter-modality
• Minimal cost in shortest time frame
• Safest type of intersection control
• High Capacity
• Minimal delays
• Low air pollution emissions
• Encouragement for slow to moderate speeds
• Aesthetic enhancements
• Minimal impact on natural and historic resources throughout the corridor
• More favorable development of multi-modal alternatives.
• Consistency with national award-winning comprehensive plan for Chester County, Landscapes and community planning goals
• Eradication of induced traffic and induced development effects
• Regional compatibility with DelDOT's plans for traffic calming and two-lanes in Hockessin

Roundabouts are being installed all over this country and in Europe because of the extensive benefits they provide. A two-lane alternative proposal featuring a series of roundabouts along Route 41 from the Delaware State line to Gap, would create an innovative, state-of-the-art transportation project that could be a national model. Roundabouts are now found throughout the U.S. in rural, suburban and urban locations, but nowhere yet has an entire roadway been built featuring a series of roundabouts in a variety of settings to improve safety, reduce congestion and delay, minimize the alternative destructive footprint of a traditional major transportation improvement project, protect the environment and historic resources, lower emissions, and improve aesthetics. It is the only sensible, sustainable solution for Route 41, as well as other sensitive transportation corridors throughout the country.