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The biggest factor affecting Pennsylvania Avenue volume: the closed stretch in front of the White House. Once they did that, volume on Pennsylvania plummeted.

I'd rather have a bike lane on Constitution than on Pennsylvania. The safety improvement would be greater and more tourists would see it and take the idea home with them.

"4. How much oversight does TPB have over DDOT on this? Does anyone know?" None of this guaranteed to be anywhere near accurate, but I think that it depends on the type of federal funding DDOT is using. If CMAQ or STP, then the project has to find its way into the TPB's plans. If TE, I don't think the TPB has any dog in the funding hunt.

Regarding their last paragraph, AAA does some grammatical yoga that implies that all those plans and such are required of the TPB and DDOT for each project. I don't think that's actually the case.

Kati, where are you? Tell us why this isn't a naked attempt to slowroll and smother by reports. And this is a pilot project, that DDOT will be observing. Does AAA want to actually see observed results (rather than imperfect simulations), or do they want DDOT to rip everything out until all of these unnecessary wasteful ridiculous-on-their-face plans and forecasts are generated and carried out at great expense to DC?

The AAA makes the same mistake in this argument that most of the media coverage on the region's congestion makes, and the similar mistake that Paul DeMaio made about assessing a congestion charge in DC to fund transportation improvements in the _region_.

Most of the region's congestion is not in DC, it's in the suburbs.

Pennsylvania Avenue between Constitution and 15th Street NW is a little used street that has way too much capacity for the demand.

Arguments about the region's congestion wrt DC's streets are for the most part specious.

Sure roads like I, K, New York Ave. have significant congestion. But in terms of the overall road network they are exceptions.

If the AAA would have used the congestion argument to argue in favor of removing the restrictions in front of the White House then I would have thought they had guts.

Instead they should be seen as advocates first and foremost for automobile centricity, nothing more nothing less.

Let’s take a look at some recent history around AAA MA and "due process". I know there are different parties involved and different process. Not to mention the size of the projects don't even compare and I'm making a simplistic argument out of a complex issue but I think it is a fair representation of the AAA MA mindset in action.

Here is some quick background on the federal lawsuit Arlington filed last against the 395 HOT Lanes from the Washington Post on 8/20/2009:

The county contends that plans for high-occupancy toll (HOT) lanes on interstates 95 and 395 have proceeded without regard to the additional air pollution generated by increased traffic. "They don't really know what the true impact will be," said Stephen MacIsaac, the county attorney. "We think there will be a lot of air quality effects. We're saying: 'Wait a minute. Slow down. Let's do this all properly.' "

The suit, filed in U.S. District Court in Washington, specifically challenges a Federal Highway Administration decision to exempt the HOT lanes project from normal environmental scrutiny, an exemption based on the premise that it would have no significant impact on air quality. Naming federal and state officials, the suit also says that improper designs in two locations -- the Shirlington off-ramp and the Eads Street terminus -- would cause traffic congestion on local streets."

So Arlington is saying due process hasn't been completed and it appears legitimate questions remain (as Arlington prevailed in the initial court arguments last month). The county attorney even echos the eerily familiar argument of wait a minute, slow down and let's do this all properly. AAA MA must support this based on their current arguments against the pilot bike lanes, right? Not so fast.

This is from AAA MA‘s August 20th, 2009 Press Release (from their site in the News Release Archives) reacting to the suit:

“Hypocritical because the suit is being filed on environmental grounds, alleging the project could possibly have negative environmental impacts on parts of Arlington. Does Arlington not think that having a hundred thousand vehicles or more barely moving for miles every morning and evening has no bad environmental impact on its environment and citizens? Is this not the county that is urging more mass transit and car pooling as our transportation solutions and yet is now blocking a project that would encourage and expand carpooling and bus ridership by expanding the number of lanes that would be free to carpoolers and buses?”

OK, but didn’t AAA MA just say this in their comments to the Transportation Planning Board (TPB) a few days ago?

The full safety, environmental and traffic impacts of these proposals must be known before proceeding. Studies, complimented by the full public hearing and approval process, are needed to know exactly what that impact will be – on traffic, on safety and on the environment.

So wouldn't it seem logical that AAA MA would want to apply the due process argument to the HOT lanes? Especially considering the potential tremendous impact (positive and negative) on this region’s transportation network for decades to come? And in comparison to the pilot bike lanes they are basically irreversible. So I guess full environmental and impact studies are OK to forgo in AAA MA's eyes where they would appear to be most needed?

As Richard Layman put so well "they should be seen as advocates first and foremost for automobile centricity, nothing more nothing less". So this is just an example of his observation in action.

And I guess we should take solace in the fact that AAA MA doesn't use hyperbole only towards cycling projects...

One of the reasons why I'm confused about the PA Avenue lanes, and why they are apparently so important to the cycling community, is precisely because of something Richard points out here: "Pennsylvania Avenue between Constitution and 15th Street NW is a little used street that has way too much capacity for the demand."

Yes, that's precisely right - and that's why I feel that the primary value of having bike lanes on Pennsylvania is more about symbolism than anything else. The safety argument (which, I believe, is somewhat faulty with bike lanes anyhow) seems to fit much better in other places in the city.

It is interesting that many of these AAA-MA environmental arguments seems to center on moving motor vehicles quickly. Suggesting that the damage is done when vehicles are moving slow or idling. I agree this does add pollution. So where are the rules or recommendations to just have less motor vehicles? Why is more capacity the only tool in the tool box (or trunk)? More capacity only encourage more motor vehicles, so by definition you will have more pollution. This kind of approach does not address the problem, which simply requires less pollution emitters. That would be AAA-MA blasphemy. So from where I sit AAA-MA is representing the polluters, which makes claims of environmental protection rather weak at best.

More capacity encourages more vehicles, but what's being discussed here is reducing capacity. I suppose there must be studies someplace that show taking away capacity means less vehicles will show up, but it's not some kind of nut-job assertion to suggest that taking away lanes of motorized traffic will increase congestion. I mean, it does sound rational.

To ask a broader question, how much capacity should a region provide for each type of mode of transportation? There are limits on funds and land. But there seems only be few limits on the number of vehicles that could show up and cause congestion. How do you re-balance, which is part of what PA Ave is about. I know I don't have the answer.

I find that suspect. I think what PA Ave is about is symbolism. If you want to talk about re-balance, there's a million and one better places for that.

twk, that is a good question. And besides the tricky problem of trying to balance demand for roads with supply of capacity, our transpo authorities need to have the expertise and systemic incentives to practice true performance management of their systems. That means looking at what road facilties cost to operate, establishing goals on serving all travellers on the system, and where the facility is not performing or contributing to the goals, being encouraged to pursue asset 'disposal', such as how DDOT is dedicating overcapacity on Penn Ave, M St SE/SW, and other places to other primary uses.

Chris, I use Penn Ave regularly to bike from near SE to the Reagan Bldg and K St areas, and the lanes will be an enhancement for me, although Penn Ave is so undercapacity now that it's actually one of the better streets for biking in traffic. Plus, the promenading of Penn Ave in front of the WH that made auto traffic plummet has the opposite effect on biking, Penn Ave could become a major east/west bicycling corridor in the city. So, I personally think Penn Ave is well-suited.

I do acknowledge symbolism is a big part of the push for this project, and I don't think that is a bad thing. But what other major roads in DC would be better candidates in balancing the needs for safe connections to desirable locations for bicyclists, and possessing all of that unused capacity?

Chris, I don't think this is about symbolism. When DDOT put together the bike plan 5 years ago, Penn was identified as a future bike lane street - long before Blumenauer challenged them to do it. There is a symbolic element for sure, but it really is about transportation.

I've said it before, but bike lanes can often serve people who won't ride without them. So if you bike on Penn now, these lanes might seem useless to you. But there are people who are scared to. These lanes will encourage them to ride, and since more cyclists make for safer cycling, this improves safety.

It is a bit like Braille on elevator buttons. You don't need it and I don't need it, but some people do.

Hi darren:

I'm not sure what you are referring to by your smother and slowroll comments. Could you clarify? Sorry! I just want to make sure I address the right concern instead of taking a stab in the dark.

Darren, you've pointed to the problem I'm trying to highlight: "Penn Ave is so undercapacity now that it's actually one of the better streets for biking in traffic."

We have to live with that fact that there are limited resources, and it's simply not possible to spend all the money in the world on building separated bike lanes on all streets in the city.

I'm sure these lanes will be used, no doubt about it. And, I'm sure they're an enhancement - I will probably start using them (I have already, through the cones), mainly because the motorists in the remaining lanes will likely have an expectation that I must, regardless of what the law says. Further, I'm sure it will give some people a sense of security (although, again, for safety's sake, I don't think any cyclist anywhere should have a sense of security).

But the question is still there: If PA Ave is one of the easier streets to ride on a bike in traffic, why has it been targeted (as opposed to some other street where the need is greater) for this project if not for the symbolic value?

And, leading from that, is the cost of the project worth the symbolic value? (Please look at this in context: PA Ave IS symbolic mostly - it's wides for ceromonial purposes, for instance - and we are coincidentally or not in an city election cycle in DC.)

Another question: If cyclists are so afraid to ride on one of the easiest major streets in the city without the bike lane, how do they plan on getting to PA Ave to ride those few blocks? I suppose they can take one of the regular (non-separated) bike lanes, but then you run into a real problem: those bike lanes aren't necessarily any safer than riding on the road with traffic.

Kati, Don S pretty well describes it. When the issue is additional highway capacity through my neighborhood (the I-395 HOT lanes), AAA MA is there to slag NEPA.

But when the issue is bike facilities, AAA MA is all about adherence to the same process. Personally, my opinion is cast on where your hearts lie, but in the interest of "dialog", why?

Chris, I can respect and even agree with a lot of that vehicular cyclist view personally, but I'm speaking from the perspective of a 'seasoned' rider. I distrust some bike lanes, i'm comfortable mixing it up on Penn Ave, etc etc.

But I put great stock in the observed and stated preference studies that show new and casual riders will be attracted to ride by separated facilities, whether the safety is real or perceived. And I put faith in the belief that I am better off if there are more cyclists out there. I think the Penn Ave lanes will draw people out to take more trips by bike, and I'm willing to subject myself to either using those lanes or invoking the wrath of a fire-breathing AAA MA member to achieve that end.

I agree with a most of what you say Darren, but again I'm asking in the context of allocating resources.

I am concerned a great deal, however, about new and casual riders attracted to riding because of the perceived safety of bike lanes. This is, in fact, my primary concern (and why I wince a little at comments I've read from others - not you! - that I'm not taking into consideration new cyclists).

The "perceived" safety of a bike lane is reduced quite a bit when the infrastructure is truly separated (like on PA Ave). But (putting aside the crash-fests that such street furniture creates for bike races in Europe), what about getting to and from such separated facilities? You can't build them everywhere! And what about the crunch zone at intersections (nothing can prevent that)?

Again, I'm not disagreeing with the idea that this is an enhancement; not I'm even saying that the symbolism is all bad; and I'm certainly not saying that AAA aren't advocates for polluters. I'm just saying that, in terms of resources, this might have been a poor thing to prioritize and that I think more money ought to be spent on educating cyclists (beginning or otherwise) about how to ride with confidence on city streets with or without bike lanes. But, that's not quite as sexy either.

We have to live with that fact that there are limited resources, and it's simply not possible to spend all the money in the world on building separated bike lanes on all streets in the city.

There are limited resources, but to some extent money for bike facilities is not the issue. The issue is places to put them. Besides DDOT isn't planning to put in bike lanes on all streets, just the streets in the bike plan (and probably more since the action agenda came out)

If PA Ave is one of the easier streets to ride on a bike in traffic, why has it been targeted (as opposed to some other street where the need is greater) for this project if not for the symbolic value?

Several reasons. One is low hanging fruit. It is easier to put in bike lanes where traffic lanes/parking do not have to be removed. DDOT did a lot of this early on. Next is to add bike lanes on roads that are overbuilt - roads that can go on a road diet. That is where DDOT is now. If AAA is going to fight adding bike lanes on a road that is overbuilt, imagine the fit they'll have when DDOT tries to add bike lanes to roads that are congested (as they're doing with the other cycletracks downtown) Another reason is that even on roads that are overbuilt, bike lanes have value. They make filtering much easier. They induce cycling. Third, if the road is overbuilt, then people speed. DDOT may want to take out a lane anyway. They could widen the sidewalk or the median; add in a bus only lane that they can't/won't enforce; or add in a bike lane. They chose the latter. But adding the bike lane slows traffic. I might ask what DDOT should have done with this lane if not turn it into a bike lane?

And, leading from that, is the cost of the project worth the symbolic value? (Please look at this in context: PA Ave IS symbolic mostly - it's wides for ceromonial purposes, for instance - and we are coincidentally or not in an city election cycle in DC.)

Well, since I think the benefit is more than symbolic, it's hard to answer this question. Nor do I know the cost of the bike lanes (though I think it's been reported) or how to quantify the symbolic value. I will only reply that symbolism - or signaling - does have a value greater than zero.

Another question: If cyclists are so afraid to ride on one of the easiest major streets in the city without the bike lane, how do they plan on getting to PA Ave to ride those few blocks?

You don't need continuous bike lanes/paths to induce cycling (though it does help). Some streets are fine as is, but Penn is a big wide street with speeding and buses and trucks. Adding bike lane brings it into the cycling universe of a wider swath of cyclists.

You seem to admit that the bike lanes will induce cycling. Am I reading that wrong?

And if so, isn't that a good enough reason? It almost seems you're bothered by the fact that some people are so illogical that they won't just bike it now.

If this is a cost/benefit question I'll ask you what project SHOULD DDOT be funding that they aren't? What has a better benefit for this cost?

Since you answered my last question in a comment simultaneous to mine, I'll respond,

I think more money ought to be spent on educating cyclists (beginning or otherwise) about how to ride with confidence on city streets with or without bike lanes. But, that's not quite as sexy either.

DDOT already picks up the bill for WABA to teach Confident City Cycling courses for free - as well as do in-school safe biking education. The only place to go from there is to pay people to take the classes (or require people to). What kind of education are they missing?

Chris, regarding lack of connections to the Penn Ave lanes, risk tolerance is not a binary thing. The presence of an extended lane may induce a hypothetical bicyclist to hold their breath on 15th St for a few blocks, or maybe an existing user of the E St NW bike lanes deviates to Penn Ave, or maybe the presence of a Class I facility on America's main street spurs community demand for connections. There's already a number of connections in work (4th St, Met Branch, 9th St), there should be no lack of feeder facilities.

Regarding education, I think it's necessary, but if your goal (as mine would be if I ran things) is to encourage substantial growth in the bicycle mode share to provide safety, congestion relief, GHG reduction, and a recognition with the general public of bicycling as transportation, I would say that no amount of education on safe riding is going to motivate the masses to join us on an unmodified Penn Ave, and we have decades of history to demonstrate that. Relying solely on education and our existing infrastructure guarantees a status quo that may be marginally safer.

Regarding resource allocation, I'm with WC, I don't know the project cost of this, but even if we accept that there's only a finite number of places we could plunk down a bike track, I can't think of anywhere I would rather have it.

And finally, I should clarify that while I am comfortable on the existing Penn Ave, I still wouldn't classify it as a safe/easy ride. There's still plenty of cabbie madness, tour bus cavitating, Fast and the Furious action, and Facebooking drivers to contend with, just that I find it to be at a tolerable level. Most others would/could not contend with it, and while education can prepare folks for it, only a few will possess a willingness.

AAA, quoted from Don S.s Post: "...a project that would encourage and expand carpooling and bus ridership by expanding the number of lanes that would be free to carpoolers and buses..."

Yeah, right. People want to carpool more, but there just ain't enough lanes. The truth? Simple: More lanes for cars = more drivers. More drivers = more potential customers/members/money. People sign up to get roadside assistance, and the association (company) uses the members as tools to advocate for their own self interests/growth.

Combine the Penn Ave tracks with the increase in the bike share program and there will be two important hurdles removed for many "would be" cyclists. If you live in the burbs, you will be able to leave your car parked somewhere and move around without searching for parking spaces. You won't have to think about the security aspects of your own bike, or face that overwhelming crazy notion of commuting "all the way" into work on bike. Not every street needs to have bike lans/tracks. Once tentative riders are rolling they will venture off the tracks and lanes. It's like learning to swim. The cycletrack is a good way to get your feet wet. Should they work on the intrersections? Absolutely. Simplify, simplify, simplify. But perhaps that will come with time.

I guess what it all boils down to for me is this: the only bike lanes that add safety for the cyclist are those that are truly separated - and even those have some safety problems. That doesn't mean that bike lanes don't have some value; but I think that value is mainly increased efficiency for the cyclist.

I'll agree that bike lanes have a side effect of encouraging more to ride their bikes. Which is great! But there's a down side to that, which is the false sense of security bike lanes bring. I am convinced that this false sense of security has led to some of the fatalities - so, in my mind, it's serious business.

I'm familiar with the courses WABA offers, but I believe there's a mixed message by that organization because their advocacy for bike lanes seem to have the coinciding implication that bike lanes bring safety.

So, all of this is probably the fundamental disagreement we'll have to simply respectfully disagree on.

But, to your points:

*I think my problem with DDOT's decision to apparently prioritize PA Ave is that it seems to me to be the least needed from the cyclists' perspective and that it is perhaps the most visible. I'm not sure how else to phrase it. Maybe it's low fruit, but from my perspective, political capital is being spent (ie, against AAA) where the accomplishment is needed the least. I would have saved my firepower for a less visible location where it would have had more value to the cycling public.

With regards to spending money on educationing cyclists about riding safely, I don't know what to say. I just know that what's happening right now isn't all that effective, and I simply don't see the passion (overall, I mean) about educating cyclists on safe riding that I do behind building infrastructure. I dunno, maybe the city should be re-doubling the public education campaigns outside of classes?

I would have saved my firepower for a less visible location where it would have had more value to the cycling public.

Where would that be?

Almost any place other than 7 or 8 blocks of Pennsylvania Avenue, which is probably the most visible place possible.

@ Darren:

Ok, it took my a bit to wrap my mind-brain around this because the conversation sort of jumped around a bit. pardon the slow response.

In both cases, as Don S. pointed out, AAA is calling for environmental impact to be considered. And, in both cases, they are questioning which will be better for the area.

In each case, AAA has noted that the environmental impact should be studied. In the case of the HOT lanes, the position is that traffic congestion could lead to increased emissions which take it's toll on the environment, which is also noted in AAA's response to the PA Ave lanes. I don't see it as conflicting (though I do see what you are getting at).

Adding a lane of highway capacity is going to cut down on GHG emissions, but that the Penn Ave bike lane project will raise them?

AAA MA wants a full EIS on the I-395 widening/HOT?

And because we're all about the magic of empirical study, this is a pilot project, that DDOT will be observing. Does AAA want to actually see observed results (rather than imperfect simulations), or do they want DDOT to rip everything out until all of these unnecessary wasteful ridiculous-on-their-face plans and forecasts are generated and carried out at great expense to DC?

What does AAA MA think of the San Francisco bike facility injunction? Is this newfound interest in NEPA a preview trailer for our future?

@Kati
I am a little confused about AAA-MA's position on motor vehicle pollution. Maybe you can try to explain. How is that DOT's end up with the responsibility to mitigate motor vehicle pollution while AAA seems to be advocating for increased motor vehicle use? At the same time AAA-MA uses pollution concerns to force DOT's into particular solutions.

How can you complain about the water quality while inviting more pee'ers into the pool?

What is AAA-MA position on reducing environmental impacts by reducing the number of emitters?

Many of us have our opinions of where we think AAA stands. I would like AAA to explain it themselves.

@Kati – I don’t see how you can argue that AAA MA is pushing for the environmental impact to be studied in both cases.

In both cases, as Don S. pointed out, AAA is calling for environmental impact to be considered. And, in both cases, they are questioning which will be better for the area.

No, that is not what I pointed out at all. I was pointing out that AAA MA’s application of what it believes to be proper due process is different in each case.

In each case, AAA has noted that the environmental impact should be studied. In the case of the HOT lanes, the position is that traffic congestion could lead to increased emissions which take it’s toll on the environment, which is also noted in AAA's response to the PA Ave lanes. I don't see it as conflicting (though I do see what you are getting at).

Once again not true. In the case of the 395 HOT Lanes AAA MA is stating the exact opposite and attacking Arlington County for pushing for an environmental impact study. AAA MA is simply going along with the assumption that by adding more capacity congestion will be reduced and therefore there will be an overall positive environmental impact for the whole project. What fact is AAA MA using to back this claim up? None was presented in the press release attacking Arlington’s decision. Does this establish that AAA MA has the right to use opinion in lieu of process if they feel it is better for the area? Isn’t that the grounds on which the organization claims it is attacking DDOT on in regard to the pilots?

So please explain to me again how this is not conflicting?

@ Don. Not arguing so much as stating my perspective that the issue at the heart of both seems to be emissions impact centered. Perhaps I'm misinterpreting? Anyway, I'm pushing your questions (along with those from twk & darren) to P&G for an "official" response since I can't really tell you, off the cuff, what the thought process is behind all of this. To be fair, that may be why my response wasn't quite what you were looking for.

Thanks again for the comments/questions.

Here are the replies. I'm going to try the magic of formatting to make these a bit more readable.

@darren Adding a lane of highway capacity is going to cut down on GHG emissions, but that the Penn Ave bike lane project will raise them? There is no way to determine whether or not that is the case as complete studies were not done. That said, if the additional lanes cause traffic to move at reasonable speeds during rush hours, this could reduce emissions because cars, trucks and buses emit less when moving at 30-50 mph than when creeping in heavy congestion as is the case currently. At those low speeds/no speeds, vehicles are at their worst in emissions. Additionally, HOT lanes are expected to be heavy with buses and car pools, thus moving higher volumes than typical lanes. But all of this is speculation until we have real studies from DC indicating impacts. Hence our concerns.


AAA MA wants a full EIS on the I-395 widening/HOT? We do believe the impacts of major transportation changes should be studied and in the case of Arlington and the HOT lanes, both the Virginia and the federal government have agreed that adequate study of the impacts has been done.

And because we're all about the magic of empirical study, this is a pilot project, that DDOT will be observing. Does AAA want to actually see observed results (rather than imperfect simulations), or do they want DDOT to rip everything out until all of these unnecessary wasteful ridiculous-on-their-face plans and forecasts are generated and carried out at great expense to DC? AAA Mid-Atlantic is simply exercising its right to publicly question this process and voice its dissent. As the lanes are clearly being added without regard to proper process, it would be silly to request their removal. Again, AAA Mid-Atlantic is merely voicing concerns over the manner in which these lanes were implemented and their potential impact.

What does AAA MA think of the San Francisco bike facility injunction? AAA Mid-Atlantic would defer to AAA Northern California’s expert opinion on the matter as they would have a better feel for the cadence of the area’s population. AAA Mid-Atlantic would say that the bicycle injunction was certainly unfortunate and unfair. AAA M-A's position remains that public transit improvements are important for any city with a diverse commuter culture, when proper procedure is followed and the end result is one that is most agreeable and fair to all commuter groups.

@twk What is AAA-MA position on reducing environmental impacts by reducing the number of emitters? The number of emitters is less relevant than the type and speeds of vehicles. If we all drove low emissions vehicles, we could drive many times the distances we drive today and emit far less than today's fleet. And, if we could drive without gridlock, our emissions would also be significantly less. Thus, numbers of emitters is not the key factor.

@Don S. In the case of the 395 HOT Lanes AAA MA is stating the exact opposite and attacking Arlington County for pushing for an environmental impact study. AAA MA is simply going along with the assumption that by adding more capacity congestion will be reduced and therefore there will be an overall positive environmental impact for the whole project. What fact is AAA MA using to back this claim up? None was presented in the press release attacking Arlington’s decision. AAA Mid-Atlantic defers to the state and federal highway engineers who have studied these HOT lanes and others who assert that the HOT lanes will significantly improve congestion in the corridor, which is some of the nation's worst.

@Kati
Thanks for the reply. I think the number of emitters is a factor not to be ignored. More vehicles leads to more congestion. More roads bring more cars through induced demand. Now you are back to slower speeds and more pollution and asking for more roads. I believe this ratchets up the pollution level faster than fleets get replaced with low emission vehicles.

I don't think any DOT should be obliged to accommodate an unlimited number of motor vehicles. One tool on the tool box should be limiting the number of cars/trucks. It is a method to add a bound to the problem of how much and what kind on infrastructure to keep things moving at an optimal speed. I think congestion pricing should be considered in this region. If the roads are becoming a limited resource, why should they all be free?

Unfortunately cars are inefficient people movers from a real estate perspective. This region needs more and better options. Walking, biking and transit should, in my opinion, be accommodated before cars. Make no mistake, I think we need cars. I have one, but I try to not use it as often as possible (it is low emission and 50 mpg). It is not my first choice mode.

I still get the sense that AAA-MA is using environmental concerns to get more capacity to relieve congestion rather than any real concern about pollution.

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