Full opinion text
MEMORANDUM GASCH, District Judge. This case is before the Court on the parties’ cross-motions for summary judgment and plaintiffs’ motion for a preliminary injunction. Plaintiffs are the Coalition on Sensible Transportation, the North Bethesda Congress of Citizens Associations, the Sierra Club, and the Washington Area Bicyclists Association. Defendants are Elizabeth Dole, Secretary of Transportation, and Ray Barnhart, Administrator of the Federal Highway Administration (“FHWA”). Defendant-intervenors are Hal Kassoff, Administrator of the Maryland State Highway Administration (“SHA”), the City of Gaithersburg, Maryland, and the Mayor and Council of Rock-ville, Maryland. I. BACKGROUND At issue in this litigation is a project which would widen Interstate 270 (“I-270”), a highway which runs through Montgomery County, Maryland. 1-270 connects Interstate 70 with Interstate 495, the “Beltway” which encircles metropolitan Washington, D.C. The 1-270 corridor is a major transportation corridor and is a heavily travelled route for traffic to and from Washington, D.C. as well as communities such as Rockville and Gaithersburg. Substantial economic development along the corridor has caused increased traffic on and around 1-270. A. Description of the Project The 1-270 project would widen approximately 16 miles of highway, extending from the 1-270 spur (“spur” or “Y-split”) near Montrose Avenue north to the intersection with MD 121. Finding of No Significant Impact (“FONSI”), Administrative Record (“A.R.”) 357, at 1-1. This expansion of 1-270 is expected to cost more than $113 million and will take five years to complete. Id. (Table 1); A.R. 358. The 1-270 project may be divided into several parts. In the stretch of 1-270 running from the 1-270 spur to MD 124, the highway would be widened from six lanes to eight “mainline” lanes and four “continuous collector-distributor” (“CC-D”) lanes. Two CC-D lanes would be constructed in each direction on this stretch of 1-270. FONSI at II — 5—6, Plate 2. The CC-D lanes are designed to separate entering and exiting traffic from the mainline 1-270 lanes in order to facilitate the flow of “through” traffic. FONSI at II — 5. The CC-D lanes will be separated from the mainline lanes by a barrier that will be periodically interrupted by “slip ramps” that permit access from the CC-D lanes to the mainline lanes, and vice versa. Id. The traffic on the CC-D lanes would travel at lower speeds in order to promote safer ingress to and egress from the mainline lanes. Id. From MD 124 to MD 118, a distance of slightly more than three miles, 1-270 would be widened from six to eight mainline lanes. FONSI at II — 5—6, Plate 3. Finally, from MD 118 to MD 121, 1-270 would be widened from four to six lanes. Id. No CC-D lanes would be constructed along these stretches of 1-270. Id. In addition to these widenings of 1-270 itself, the project entails modification of the interchanges at Montrose Road, Middlebrook Rd./MD 118, and MD 28. FONSI at 11-10-15. B. Development of the 1-270 Project The possibility of widening 1-270 has been under discussion since the early 1970’s. See A.R. 9, 10, 11. Consideration of the instant project began in 1979, when the SHA developed a project planning prospectus which addressed conditions in the 1-270 corridor from the 1-270 spur to MD 121 and discussed proposals for improving traffic flow. See A.R. 32. This document was circulated to various federal and state agencies for comment and review. See A.R. 33, 34, 35. Thereafter a consultant was hired and project planning began in earnest. See A.R. 39, 40, 44, 45. The administrative record establishes that, between 1980 and 1983, project planners discussed and studied various matters related to construction along 1-270, including historic sites, A.R. 58, 64; archeological areas, A.R. 72, 75; environmental conditions, A.R. 73; noise levels, A.R. 69, 276; and air quality, A.R. 197, 199, 199a, 200. Planners also reviewed traffic patterns and forecasts. See A.R. 67, 71, 84, 92, 106,113, 123, 148, 151, 168, 169. Officials discussed means of improving traffic service and developed alternate proposals that included ramp metering, high occupancy vehicle (“HOV”) lanes, widening to eight lanes, and widening to eight lanes with CC-D lanes. See A.R. 63, 76, 77, 80, 81, 95, 139, 153, 173, 185. On June 11, 1983, the SHA held a public informational meeting on the 1-270 project and the alternatives under consideration. A.R. 168, 171. The meeting, held in Montgomery County, was attended by approximately 70 people, who commented on the proposals. A.R. 171. On August 3, 1983, the 1-270 project team decided that the eight-lane, CC-D lane proposal and the no-build alternative would be studied in detail. A.R. 180. Although it presented potentially the worst-case environmental effect, the eight-lane, CC-D lane proposal was deemed the “preferred alternative” because it provided the highest traffic capacity on 1-270 and the best service. Id. By the end of 1983, the SHA had prepared preliminary drafts of an environmental analysis (“EA”) and environmental statement required by Section 4(f) of the Department of Transportation Act, which concerns use of parkland in highway construction. See A.R. 193, 205, 208, 208a. This document was sent to the FHWA for comment and, after some revisions, was approved by the FHWA on January 13, 1984. See A.R. 229. On February 15, 1984, the SHA held a combined location/design public hearing on the 1-270 project in Rockville. See A.R. 225, 266. A report prepared in advance of the hearing and mailed to organizations on the SHA mailing list identified the proposals that had been studied and described the eight-lane, CC-D lane plan as the preferred alternative. See A.R. 225. The public hearing was attended by about 280 people, 28 of whom spoke for the record. FONSI at 1-3; see A.R. 266, vol. 1. In response to comments made at the public hearing, three alterations to the preferred alternative were adopted. These alterations involved shifting the roadway south of Montrose Road 24 feet to the west, shifting the roadway south of MD 28 30 feet to the east, and shifting the roadway between MD 28 and the proposed Gude Drive Bridge 43 feet to the west. FONSI at II-7-10. These shifts were made to move the highway farther away from certain residential areas. See A.R. 266, 258, 269. On April 30,1984, the FHWA determined that the public hearing requirements established by Section 128 of the Federal-Aid Highway Act had been satisfied. See A.R. 297. Thereafter, the SHA submitted the FONSI to the FHWA. A.R. 338. The FHWA concluded that the 1-270 project’s environmental impact was not significant and approved the SHA’s recommendation for a FONSI. A.R. 356, 357. The SHA then issued a public notice announcing that the Department of Transportation had given location and design approval for the 1-270 project. A.R. 362. C. Evaluation of Alternative Proposals During the administrative consideration of the 1-270 project, five alternatives were discussed: the no-build alternative; widening 1-270 to eight lanes without CC-D lanes; use of HOV lanes; ramp metering; and widening 1-270 to eight lanes with CC-D lanes. See FONSI at II-1-10. These proposals and the reasons for their rejection will be briefly discussed. 1. No-Build The no-build alternative involved only normal maintenance of 1-270 without widening. FONSI at II-l. This alternative was rejected for failure to relieve traffic congestion. Id.; see also A.R. 361, at 1. The SHA concluded that, as development in the 1-270 corridor intensified, traffic volume on 1-270 and other roads in the corridor would increase. Without new construction to alleviate congestion, the SHA found that accident rates would increase and traffic would be diverted to other routes in the corridor, thereby increasing congestion on those routes. FONSI at II-l. 2. Widening to Eight Lanes Without CC-D Lanes This proposal would have added a traffic lane in each direction from the 1-270 spur to MD 121, so that there would be eight lanes from the 1-270 spur to MD 118 and six lanes from MD 118 to MD 121. FONSI at II — 2. The SHA rejected this alternate for several reasons. First, existing ramps along 1-270 would need to be lengthened, thus requiring “extensive right-of-way acquisitions and relocations resulting in greater overall adverse impact and substantially greater costs.” Id. Second, bridges passing over 1-270 would need to be reconstructed to accommodate the addition of new lanes. Id. Third, the alternative would not adequately handle traffic demand in 2010, the “design year” of the I- 270 project. Id.; see also A.R. 361, at 1. 3. HOV Lanes Under this proposal, additional lanes would be constructed and would operate as express lanes or HOV lanes. FONSI at II— 3. This alternative was rejected primarily as a result of estimated traffic patterns in the 1-270 corridor. Id.; A.R. 361, at 1. Projections indicated that a substantial portion of traffic on 1-270 was between communities in the corridor and that only a “relatively small percentage of traffic” was destined for the Washington, D.C. central business district. FONSI at II — 3. The SHA decided that the express-HOV lanes proposal would not significantly alleviate congestion. Id. at II — 4. In addition, bridges over 1-270 would have to be reconstructed to permit direct access to the express-HOV lanes. Id. 4. Ramp Metering This alternative called for installation of two-stage traffic lights on entrance ramps to 1-270. FONSI at II — 4. The metering would attempt to control the flow of vehicles onto 1-270 to ensure that traffic would not exceed capacity. Id. This proposal was considered in conjunction with the no-build and eight-lane alternates and rejected. Id. at II — 5. The SHA determined that metering would result in “no net savings in vehicle hours of travel” in the 1-270 corridor with metering the eight-lane alternate. Id. D. Project Impact on Parklands The FONSI includes a Section 4(f) statement that describes the parklands and conservation areas that will be affected by the 1-270 project and the steps that will be taken to mitigate harm in those areas. See FONSI at VII-1-11. In all, seven parks and conservation areas were examined: Til-den Park, Cabin John Regional Park, Rock-mead Park, Wootten Mill Park, Middle-brook Hill Neighborhood Conservation Area, Metropolitan Grove Road Park, and Seneca Creek State Park. The anticipated impact on these areas will be discussed separately. 1. Tilden Park This 79-acre park, operated by the Maryland National Capital Park and Planning Commission (“MNCPPC”), lies east of I-270. FONSI at VII-1-2. As the project was initially planned, 0.1 acre of Tilden Park would have been used for slopes abutting the highway. Id. at VII-4. Following the public hearing, however, the location of the 1-270 project was shifted, so that no property in Tilden Park will be affected. Id. 2. Cabin John Regional Park This 525-acre park, operated by the MNCPPC, is located on both sides of 1-270 between the 1-270 spur and Montrose Road. FONSI at VII-2. The 1-270 project will use more than 7.8 acres of the park in temporary easements to construct slopes abutting the highway. Id. at VII-5. While this use could be avoided through construction of a 7,150-foot retaining wall at a cost of $5,461,000, this proposal was rejected as imprudent and infeasible by both the MNCPPC and the SHA. Id. During the pendency of 1-270 construction, the MNCPPC will grant temporary easements to permit grading of the 7.8 acres. FONSI at VII-5. Thereafter, eight-foot retaining walls will be constructed in certain areas and the acreage will be landscaped, revegetated, and returned to the MNCPPC for use as parkland. Id. The FONSI indicates that the MNCPPC determined that this approach would be more natural and aesthetically acceptable than construction of a large retaining wall. Id. 3. Rockmead Park This 28-acre park lies on the west side of 1-270 directly south of the MD 28 interchange. FONSI at VII-2. While use of 1.1 acres of the park was originally contemplated, the SHA elected to avoid any encroachment onto the park through erection of retaining walls. Id. at VII-5. Noise barriers also will be provided along park property. Id. 4. Wootten Mill Park This 80-acre park, operated by the City of Rockville, lies east of 1-270 and south of the MD 28 interchange. FONSI at VII-3. It was originally thought that the project would encroach upon a strip of parkland between Watts Branch Parkway and 1-270 and would require permanent acquisition of 0.2 acre of parkland. Id. at VII-6. Later engineering studies determined, however, that no parkland need be acquired. See Affidavit of Neil J. Pedersen, Director of SHA Office of Planning and Preliminary Engineering, at 7 (May 19, 1986). 5. Middlebrook Hill Neighborhood Conservation Area This parcel of 11.5 acres is owned by the MNCPPC and is located on the east side of 1-270 near Seneca Creek State Park. FONSI at VII-3. During 1-270 construction, the MNCPPC will grant a temporary construction easement of 0.5 acre. Id. at VII-6. After construction is completed, this parcel will be revegetated and will remain under MNCPPC jurisdiction. Id. 6. Metropolitan Grove Road Park This 31-acre park is operated by the City of Gaithersburg and lies west of 1-270 and north of the MD 124 interchange. FONSI at VII-3. The project requires use of a strip of land 600 feet long and 40 feet wide, a total of 0.2 acre. Id. at VII-6. Temporary construction easements will be acquired for grading; thereafter the acreage will be landscaped and revegetated, and will remain under the jurisdiction of the City of Gaithersburg. Id. at VII-7. The City rejected a proposal to avoid any use of parkland through construction of 500-foot retaining walls at a cost of $500,000. Id. 7. Seneca Creek State Park This 5,127-acre park, operated by the Maryland Forest Service, lies on both sides of 1-270 south of Middlebrook Road. FONSI at VII-3. The 1-270 project requires use of 2 acres of land in strips varying in width from 10 to 80 feet. Id. at VII-7. The Maryland Department of Natural Resources will grant temporary easements for grading, and after construction is completed, the land will be revegetated. Id. The Department of Natural Resources rejected an alternative which would have avoided any use of the parkland through construction of a 2,750-foot retaining wall at a cost of $1,650,000. Id. On September 28, 1984, the Director of the Office of Planning and Program Development of the FHWA approved the above-noted uses of Section 4(f) land. A.R. 361. He determined that there were no feasible or prudent alternatives to such uses and that the 1-270 proposal included all possible planning to minimize harm to the parklands from such uses. Id. at 4. E. Other Effects of the Project 1. Displacement and Relocation of Individuals The FONSI anticipates that the 1-270 project construction will displace a total of 11 residences and require relocation of 25 individuals. FONSI at IV-1. All relocations will be accomplished pursuant to the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, Pub.L. No. 91-646. The project will provide a lead time of 18 to 24 months to accomplish these relocations. Id. at IV-1-2. At the MD 28 interchange, seven residences, two of which are already owned by the SHA, will be displaced. FONSI at IV-1. A total of 14 individuals, none of whom are minorities, will be relocated. Id. The FONSI notes that these relocations would have been required under any of the build alternatives and would have been desirable for safety reasons even under the no-build alternative. Id. A Relocation Assistance Report prepared for the SHA states that there is sufficient housing available to accomplish these relocations. Id. at IV-2. The proposed alternate for the Middle-brook Road interchange would require displacement of three residences and relocation of 10 persons, all of whom are minorities. FONSI at IV-1-2. A study found that there is no adequate housing available within the financial means of these people, so that “housing as a last resort is indicated.” Id. at IV-2. The Montrose Road interchange construction will displace one non-minority residence. FONSI at IV-2. Sufficient housing is said to be available for relocation of the owner-occupier of this residence. Id. 2. Water Quality Construction may cause sedimentation that could adversely affect aquatic species. FONSI at IV-3. The SHA will use erosion and sediment control methods to minimize the impact of this sedimentation upon water quality. Id. The SHA also will provide stormwater management facilities to filter out pollutants such as heavy metals and trash that will be discharged from the I-270 right-of-way. Id. at IV-3-4. 3. Wetlands Three types of wetlands will be affected by the 1-270 project. FONSI at IV-4-6. The first type, seasonally flooded basins or flats, will be affected primarily along Watts Branch, due to construction of the MD 28 interchange, and along Gunner Branch, due to construction of the Middle-brook Road interchange. Id. at IV-4. In all, approximately six acres of these wetlands will be lost due to widening of the roadway and grading into the floodplain. Id. The FONSI notes that the only alternative to this loss of wetlands is to forgo construction of the MD 28 and Middlebrook Road interchanges. FONSI at IV-4. Other alternatives, such as relocation of streams rather than piping, were rejected. Id. at IV-4-5. The FONSI states that a six-acre loss “represents a negligible reduction” in this type of wetland in the project area. Id. at IV-4. The second type of wetland affected is inland fresh meadow. FONSI at IV-5. Half an acre of this type of wetland, about 10 percent of the meadow in the project area, will be lost. Id. The FONSI describes this loss as negligible. Id. These wetlands are to be replaced at locations to be selected by the Department of Natural Resources. Id. Approximately four acres of inland open fresh water, the third type of wetland, will be lost through sedimentation caused by the construction. FONSI at IV-5. Most of this acreage loss is due to the MD 28 and Middlebrook Road interchange construction. Id. The FONSI states that this loss of habitat is negligible, as it amounts to only a small portion of the total amount of inland open fresh water available along streams in the project area. Id. at IV-5-6. The FONSI concludes that there is no practicable alternative to the above-noted loss of wetlands and that the project will employ all practicable methods to minimize harm to wetlands. FONSI at IV-7. 4. Wildlife Habitat The FONSI acknowledges that various terrestrial habitats will be lost due to project construction, with a resulting reduction in wildlife populations inhabiting those areas. FONSI at IV-7. The FONSI states, however, that this loss of wildlife habitat is proportionately negligible. Id. 5. Noise Noise levels at 33 noise-sensitive areas along the project were monitored by the SHA. FONSI at IV-8. Fourteen of the 33 areas currently have ambient noise levels higher than the FHWA noise abatement criteria of 70 dBA. Id. Under the no-build alternative, predicted noise levels would exceed 70 dBA at 21 of the 33 areas. Id. Under the project, predicted noise levels would exceed 70 dBA at 24 areas. Id. The FONSI states that noise barriers will be recommended at six locations that represent 13 of the noise sensitive areas. Id. The cost of these barriers is estimated at $4 million. Id. 6. Air Quality Testing indicates that the project will produce concentrations of carbon monoxide 1-2 parts per million higher than would exist under the no-build alternative. FONSI at IV-8. Under either the project or the no-build alternative, there would be no violations of the National Ambient Air Quality Standards in either 1990 or 2010. Id. II. DISCUSSION Plaintiffs allege that three statutes were violated during the consideration and approval of the 1-270 project: Section 102(2)(C) of the National Environmental Policy Act of 1969 (“NEPA”), 42 U.S.C. § 4332(2)(C); Section 4(f) of the Department of Transportation Act, 49 U.S.C. § 303(c) (1983 Supp.); and Section 128 of the Federal-Aid Highway Act, 23 U.S.C. § 128 (1982). The Court will consider these arguments in turn. A. Violation of NEPA Plaintiffs assert that defendants violated NEPA in two respects. First, they contend that defendants acted improperly by failing to prepare an environmental impact statement (“EIS”) prior to approval of the 1-270 project. Second, they assert that the EA and FONSI developed by defendants were inadequate as a basis for determining not to prepare an EIS. 1. Statutory Provisions and Standard of Review Section 102(2)(C) of NEPA provides that [A]ll agencies of the Federal Government shall— (C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on— (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between the short-term uses of man’s environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. 42 U.S.C. § 4332(2)(C) (1982). This statute was “designed to promote human welfare by alerting governmental actors to the effect of their proposed actions on the physical environment.” Metropolitan Edison Co. v. People Against Nuclear Energy, 460 U.S. 766, 772, 103 S.Ct. 1556, 1560, 75 L.Ed.2d 534 (1983). As the Supreme Court has noted, Section 102(2)(C) “serves twin aims”: The first is to inject environmental considerations into the federal agency’s decisionmaking process by requiring the agency to prepare an EIS. The second aim is to inform the public that the agency has considered environmental concerns in its decisionmaking process. Through the disclosure of an EIS, the public is made aware that the agency has taken environmental considerations into account. Weinberger v. Catholic Action of Hawaii, 454 U.S. 139, 143, 102 S.Ct. 197, 201, 70 L.Ed.2d 298 (1981). Where, as here, an agency determines that a “major Federal action” will not “significantly affect the quality of the human environment,” the agency is required to “explain its finding of no significant impact in a ‘concise public document’ called an ‘environmental assessment.’ ” Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 1430 (D.C.Cir.1985) (quoting 40 C.F.R. §§ 1501.4(aMb), 1508.9 (1984)). The EA must “provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact.” 40 C.F.R. § 1508.9(a)(1) (1984). Moreover, the EA must “provide convincing reasons why a ... project with ‘arguably’ potentially significant environmental impact does not require a detailed impact statement.” Maryland-National Capital Park & Planning Comm’n v. United States Postal Service, 487 F.2d 1029, 1040 (D.C.Cir.1973). An agency’s decision not to prepare an EIS is reviewed under the “arbitrary and capricious” standard. See Mid-Tex Elec. Co-op., Inc. v. FERC, 773 F.2d 327, 339 (D.C.Cir.1985). There are four inquiries for the reviewing court: (1) whether the agency took a ‘hard look’ at the problem; (2) whether the agency identified the relevant areas of environmental concern; (3) as to .the problems studied and identified, whether the agency made a convincing case that the impact was insignificant; and (4) if there was an impact of true significance, whether the agency convincingly established that changes in the project sufficiently reduced it to a minimum. Id. (quoting Sierra Club v. Peterson, 717 F.2d 1409, 1413 (D.C.Cir.1983)); see also Sierra Club v. United States Dept. of Transportation, 753 F.2d 120, 127 (D.C.Cir.1984). The court’s review is strictly limited, however. While the court must “insure that the agency has considered the environmental consequenees[,] it cannot ‘interject itself within the discretion of the executive as to the choice of the action to be taken.’ ” Strycker’s Bay Neighborhood Council, Inc. v. Karlen, 444 U.S. 223, 227-28, 100 S.Ct. 497, 499-500, 62 L.Ed.2d 433 (1980) (per curiam) (quoting Kleppe v. Sierra Club, 427 U.S. 390, 410 n. 21, 96 S.Ct. 2718, 2730 n. 21, 49 L.Ed.2d 576 (1976)). 2. Failure to Prepare an EIS Plaintiffs’ first argument is that the I-270 project requires preparation of an EIS. There is no question that the project is a “major Federal action” under NEPA. See 40 C.F.R. § 1508.18 (1985) (defining “major Federal action”). The parties do dispute, however, whether the 1-270 project will “significantly affect the quality of the human environment.” This Court thus must determine whether, upon consideration of the project and any mitigation measures, the defendants have “convincingly established” that the project will have no significant impact. See Mid-Tex Elec. Co-op., Inc., 773 F.2d at 339. In addressing this question, the Court is guided by standards established by the Council on Environmental Quality regulations for implementing NEPA, 40 C.F.R. §§ 1500-1508 (1985) (“CEQ regulations”). These regulations are binding on federal agencies, and their interpretation of NEPA is entitled to substantial deference. See Andrus v. Sierra Club, 442 U.S. 347, 357-58, 99 S.Ct. 2335, 2340-41, 60 L.Ed.2d 943 (1979); Foundation on Economic Trends v. Heckler, 587 F.Supp. 753, 764 n. 2 (D.D.C.1984), aff'd in part and vacated in part, 756 F.2d 143 (D.C.Cir.1985). The CEQ regulations provide that agencies shall determine whether impact is “significant” by considering both the “context” and the “intensity” of the proposed action. 40 C.F.R. § 1508.27 (1985). Consideration of “context” involves review of an action’s short- and long-term effects on “society as a whole (human, national), the affected region, the affected interests, and the locality.” 40 C.F.R. § 1508.27(a). Where a project is “site-specific,” significance “would usually depend upon the effects in the locale rather than in the world as a whole.” Id. The “intensity” determination focuses upon the “severity of impact” and involves ten separate factors. See 40 C.F.R. § 1508.27(b). The factors relevant to this case include: beneficial and adverse impacts; proximity to wetlands and park-lands; whether the effects on the quality of the human environment “are likely to be highly controversial”; whether the project “is related to other actions with individually insignificant but cumulatively significant impacts”; and whether the project “threatens a violation of Federal, State or local law or requirements imposed for the protection of the environment.” Id. § 1508.-27(b)(1), (3), (4), (7), (10). a. “Context” of the 1-270 Project Since the 1-270 project is “site-specific,” this Court must concentrate upon the short- and long-term effects of the project in the “locale” of the project. 40 C.F.R. § 1508.27(a). The scope of review thus is limited to the site of the 1-270 project and “its immediate surroundings.” Sierra Club v. Marsh, 769 F.2d 868, 881 (1st Cir.1985). Plaintiffs identify two short-term effects of the 1-270 project. First, they note that project construction will cause disruption of traffic, increased noise, and potential safety problems. The Court finds, however, that these short-term effects are contextually insignificant. Construction of the 1-270 project will be “phased” to minimize disruption of traffic, and during peak travel hours the same number of lanes that currently exist on 1-270 will remain open to traffic. See A.R. 229, at 35; Affidavit of Neil J. Pedersen, Director of the SHA Office of Planning and Preliminary Engineering, at 7 (May 19, 1986). Moreover, mitigation efforts will be undertaken to alleviate noise and safety concerns. See FONSI at VIII-34. Second, plaintiffs note that construction will affect approximately 11 acres of parkland along 1-270. That acreage, however, represents only a small fraction of all parkland in the 1-270 corridor. Furthermore, that parkland is already significantly affected by its close proximity to the current highway. In the long-term, the 1-270 project will result in displacement of 11 residences, some loss of wetlands and terrestrial habitats, and construction of various storm water facilities, noise barriers, and retaining walls. See FONSI at IV-1-8, VII-5. Through provision of relocation assistance, relocation of some wetlands, and adoption of other mitigation measures, however, these effects will be minimized. Moreover, as has been noted previously, project planners have concluded that these effects are proportionately negligible in view of the total residential population and amount of wetlands in the project area. The FONSI and EA reflect that these conclusions were based upon adequate study, and the Court finds that these conclusions were not reached arbitrarily or capriciously. In addition, the Court notes that this project involves modification of a major existing highway. This factor is clearly relevant to consideration of the “context” of this project. From the administrative record, it is apparent that 1-270 already substantially affects the environment in the 1-270 corridor; the widening of that highway simply does not constitute an additional substantial effect upon the project “locale” when viewed in that context. See Hanly v. Kleindienst, 471 F.2d 823, 831 (2d Cir.1972), cert. denied, 412 U.S. 908, 93 S.Ct. 2290, 36 L.Ed.2d 974 (1973). b. “Intensity” of the 1-270 Project Beneficial and Adverse Impacts. Under 40 C.F.R. § 1508.17(b)(1), project planners are required to consider both “adverse and beneficial” impacts of a project. The “adverse” impacts have been briefly noted above. To these may be added two “beneficial” impacts: improved traffic service on 1-270, and increased growth and development in communities along 1-270. The FONSI makes clear that the 1-270 project was intended to affect traffic by alleviating serious congestion on 1-270 and by reducing the number of congestion-related traffic accidents. See FONSI at III— 1-3. This purpose is reflected elsewhere in the record. See A.R. 361, at 1. To the extent that the project will improve traffic service and reduce accidents, it will have a “beneficial” effect on “the quality of the human environment.” Another beneficial effect of the 1-270 project is that it will facilitate economic development in the 1-270 corridor. This purpose of the project also is evident from the record. See FONSI at 1-2; A.R. 361, at 1. The Court notes, however, that all highway projects will have some “beneficial” effects upon traffic service and economic growth. There is nothing to suggest that the effects emanating from the 1-270 project will be of such magnitude as to differentiate the project from other highway or transportation projects, particularly when the current existence of 1-270 is considered. Thus, this “intensity” factor has little weight for purposes of this case. Proximity to Parkland and Wetlands. Another “intensity” factor is a proposed action’s proximity to parkland and wetlands. See 40 C.F.R. § 1508.27(b)(3). Here the 1-270 project is in close proximity with at least seven parks and three categories of wetlands. See FONSI at VII-1-7, IV-4-6. Approximately 11 acres of parkland will be directly affected by the project, and 10 acres of wetlands will be lost. Defendants argue, and the Court agrees, that when mitigation measures are considered, the project’s impact upon parkland and wetlands is insignificant. The 11 acres of parkland will be affected only for the pendency of temporary construction easements and thereafter will be graded, reseeded, revegetated, and returned to the jurisdiction of supervising authorities. In addition, some wetlands will be relocated, and mitigation measures will be employed at other wetland areas to minimize harm. See FONSI at IV-4-7. Moreover, the project’s impact on parkland and wetlands will be insignificant for other reasons. First, the affected properties constitute only a small fraction of the total amount of parkland and wetlands in the project area. Second, the affected parklands are not actively used at present, and they are already in close proximity with the current 1-270 roadbed. See FONSI at IV-1-7; see also Hanly v. Kleindienst, 471 F.2d at 831. Public Controversy. Plaintiffs assert that the 1-270 project is “highly controversial” within the meaning of 40 C.F.R. § 1508.27(b)(4). Defendants contend that this “intensity” factor is not implicated because only a small percentage of all residents in the 1-270 corridor participated in the public hearing on the project and no federal, state, or local agencies actively opposed the project. Courts have interpreted 40 C.F.R. § 1508.27(b)(4) to refer to “instances where ‘a substantial dispute exists as to the size, nature, or effect of the major federal action rather than to the existence of opposition to a use.’ ” Town of Orangetown v. Gorsuch, 718 F.2d 29, 39 (2d Cir.1983) (quoting Hanly v. Kleindienst, 471 F.2d at 830), cert. denied, 465 U.S. 1099, 104 S.Ct. 1592, 80 L.Ed.2d 124 (1984); see also Foundation for North American Wild Sheep v. United States Dep’t of Agriculture, 681 F.2d 1172, 1182 (9th Cir.1982); Rucker v. Willis, 484 F.2d 158, 162 (4th Cir.1973). Plaintiffs must produce some evidence of controversy; the mere filing of a suit is not sufficient. Fund for Animals v. Frizzell, 530 F.2d 982, 988-89 n. 15 (D.C.Cir.1975) (per curiam); see also No East-West Highway Comm., Inc. v. Chandler, 767 F.2d 21, 15 (1st Cir.1985). In this case, the record of the February 15, 1984 public hearing includes 307 comments from individuals, state and local officials, and civic associations regarding the 1-270 project. A review of that record reveals both support for and opposition to the project. See generally A.R. 266, vols. 1 & 2. In assessing whether a project is “highly controversial,” however, “certainly something more is required besides the fact that some people may be highly agitated.” Fund for Animals, 530 F.2d at 988-89 n. 15. Nor does the number of critical comments, when considered in light of the residential population of the 1-270 corridor, warrant a finding that there is “substantial dispute” about the 1-270 project. See West Houston Air Committee v. Federal Aviation Administration, 784 F.2d 702, 705 (5th Cir.1986). It also is significant that no “local, state or federal agency charged with environmental responsibility” opposed the 1-270 project. See West Houston Air Committee, 784 F.2d at 705. Plaintiffs assert that a further indicium of public controversy is the 1-270 project’s apparent facial inconsistency with community and regional , master plans which contemplate widening 1-270 to eight lanes. See A.R. 229, at 49-50. The Court rejects this contention, however. While several courts have concluded that NEPA requires closer scrutiny when a federal project will serve to “override” local zoning protections, see Maryland-National Capital Park & Planning Comm’n, 487 F.2d at 1087; Hanly v. Kleindienst, 471 F.2d at 831, those holdings are inapplicable to the instant case for two reasons. First, under Maryland law, master plans are not final and binding zoning laws; rather, they are “continually subject to modification in light of actual land use development.” Montgomery County v. Woodward & Lothrop, Inc., 280 Md. 686, 376 A.2d 483, 493 (1977), cert. denied, 434 U.S. 1067, 98 S.Ct. 1245, 55 L.Ed.2d 769 (1978). Second, local planning directors charged with interpretation of the relevant master plans have stated that the 1-270 project is consistent with those plans. See Affidavit of Jennifer Russel, director of planning for the City of Gaithersburg (May 19, 1986); Affidavit of J. Michael Davis, director of planning for the Mayor and Council of Rockville (May 19, 1986). Thus, the 1-270 project will not “override” local zoning protections. The Court’s review of the record leads it to find that project planners reasonably concluded that the 1-270 project was not “highly controversial.” While plaintiffs and others may vigorously oppose the project, that opposition simply is not sufficient under governing case law. Cumulative Significance. Plaintiffs also assert that 40 C.F.R. § 1508.27(b)(7) is implicated by this case because three other highway projects related to the 1-270 project are underway in the 1-270 corridor. A brief description of the three projects follows. The first project involves reconstruction and improvement of the 1-270 interchange with MD 124 (“MD 124 project”). This project was undertaken to relieve traffic congestion and queueing at the interchange which resulted in delays along mainline I-270. See MD 124 Project FONSI, Supplemental Administrative Record (“S.A.R.”) B, at 9. The FONSI for the project was approved by the FHWA on March 6, 1981. See id. at 1. The MD 124 project will have the beneficial effects of improving traffic service and reducing congestion-related accidents. Id. at 9. The project also would increase noise levels beyond design standards at two sites and require acquisition of more than five acres of commercial property. Id. at 7. Measures will be employed to minimize the project’s impacts upon more than four acres of floodplain. Id. at 14. The second project involves construction of an interchange in the vicinity of the MD 189/1-270 overpass (“MD 189 project”). The Environmental Assessment for the MD 189 project expressly states that it is related to the 1-270 project and is intended to relieve congestion along 1-270 by providing an additional means of access from 1-270 to the City of Rockville’s central business district. See S.A.R. G, at 5. A FONSI for the MD 189 project was approved on April 8, 1982. See S.A.R. H. The MD 189 project will have the beneficial effects of improving traffic service, reducing congestion-related accidents, and facilitating additional economic development in the central district of the City of Rockville. See S.A.R. G, at 5-10. Three residences will be displaced, and two properties which are eligible for the Maryland Historic Site inventory, but which were found not locally significant by a state historic preservation officer, will be acquired. Id. at 20, 23. Federal noise level standards will be exceeded at five locations. Id. at 29. In addition, the FONSI noted that the MD 189 project was “controversial” and opposed by a number of local residents. See S.A.R. H, at 1, V-l-28. The third project will construct an entirely new interstate highway, 1-370 (“1-370 project”). This new highway will extend from 1-270, at a point approximately one mile north of the Shady Grove Road interchange, for three miles east to an access road to the Shady Grove Metrorail station. See S.A.R. D, at i. The 1-370 project is intended to facilitate the use of the Washington, D.C. area metrorail system and to relieve traffic congestion at the I-270/Shady Grove Road interchange. Id. Moreover, the 1-370 project encompasses construction of stretches of mainline and CC-D roads on 1-270. See Affidavit of Neil J. Pedersen, Director of SHA Office of Planning and Preliminary Engineering, at 6-10 (June 2, 1986). An EIS on the 1-370 project was approved by the FHWA on August 4, 1982. See S.A.R. D. The 1-370 project is intended to have the beneficial impacts of improving traffic conditions, encouraging use of the Metrorail system, and facilitating economic development in Montgomery County. See S.A.R. D, at 1-10. The project will displace 30 individuals and a number of businesses. Id. at 83, 87-88. The project also will affect to varying degrees regional topography, geology, and water resources. Id. at 102-06. Approximately 1200 feet of stream bed will be relocated. Id. at 106. In addition, several aquatic and terrestrial habitats will be affected. Id. at 111-13. The project will result in noise levels greater than design noise levels at seven locations. Id. at 127, 29. Finally, the 1-370 project will require permanent acquisition of .07 acre of Muddy Branch Park and .14 acre of Summit Hall Park. See S.A.R. F, at 4. Additionally, .25 acre of Muddy Branch Park and .20 acre of Summit Hall Park will be subject to use during the duration of temporary construction easements. Id. To invoke 40 C.F.R. § 1508.27(b)(7), a plaintiff must provide some evidence of ongoing or planned related projects. See No East-West Highway Comm., Inc., 767 F.2d at 26. As the above discussion establishes, the MD 124, MD 189, and 1-370 projects clearly are “related” to the 1-270 project, in that each of the three projects will affect 1-270 by reducing congestion and facilitating access. Initially, it may be argued that while these highway projects are “related” in the general sense noted above, they may not be “related” within the meaning of 40 C.F.R. § 1508.27(b)(7). Each of the highway projects has a purpose independent of the purpose of the 1-270 project, and each project will serve that purpose regardless of whether 1-270 is widened. Thus, the determination of whether the effects of these projects and the 1-270 project should be aggregated may be found to “require[ ] the weighing of a number of relevant factors, including the extent of interrelationship among proposed actions and practical considerations of feasibility.” Kleppe v. Sierra Club, 421 U.S. at 412, 96 S.Ct. at 2731. Making such a determination clearly “requires a high level of technical expertise” in the area of traffic analysis and highway engineering and management and thus “is properly left to the informed discretion of the responsible federal agencies.” Id. Furthermore, even if the Court did conclude that the impacts of these projects should be aggregated, and that such aggregation would reveal a “cumulatively significant impact,” the Court would find that this factor does not mandate preparation of an EIS for the 1-270 project. The obvious purpose of 40 C.F.R. § 1508.27(b)(7) is to require project planners to recognize the cumulative effects of related highway projects and thereby to advance NEPA’s goal of encouraging informed public scrutiny of the environmental effects of federal actions. See Sierra Club v. Marsh, 769 F.2d at 881; Conner v. Burford, 605 F.Supp. 107, 108-09 (D.Mont.1985). The Court believes that this purpose has been served with respect to the I- 270 project. It is clear from the record that 1-270 project planners knew of the “related” projects and apprised the public of the existence of such projects. See FONSI at II— 10; A.R. 229, at 39. Moreover, as has been discussed, each of the “related” projects was the subject of extensive study and public disclosure in its own right: EAs and FONSIs were prepared for the MD 124 and MD 189 projects, and an EIS was prepared for the 1-370 project. In addition, each of the three projects was the subject of a public hearing. Thus, this is not a case where project planners have attempted to minimize public scrutiny by hiding the effects of these projects. To be sure, project planners could have gathered together in one document a comprehensive description of all impacts arising from these projects. The Court is mindful, however, of the Supreme Court’s admonition that a reviewing court may not “impose upon an agency its own notion of which procedures are ‘best’ or most likely to further some vague, undefined public good.” Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., 435 U.S. 519, 549, 98 S.Ct. 1197, 1214, 55 L.Ed.2d 460 (1978); see also Piedmont Heights Civic Club v. Moreland, 637 F.2d 430, 441 (5th Cir.1981) (“NEPA does not require an agency to restate all of the environmental effects of other projects presently under consideration.”). Threatened Violation of Environmental Laws. The final “intensity” factor requires consideration of whether a project threatens a violation of federal, state, or local environmental laws. See 40 C.F.R. § 1508.27(b)(10). Here plaintiffs argue that the 1-270 project involves Section 4(f) of the Department of Transportation Act, 49 U.S.C. § 303(c), which establishes standards to protect parkland from use in highway projects. As will be discussed infra, the Court concludes that the 1-270 project did not violate or “threaten” violation of Section 4(f). c. Analysis Under the law of this circuit, this Court must determine whether defendants “convincingly established” that the 1-270 project will not “significantly affect the quality of the human environment” in order to justify their decision not to prepare an EIS. Here application of the CEQ regulations indicates that defendants have met that burden. For reasons stated previously the Court believes that the “context” of the 1-270 project supports a finding of no significant impact. In addition, only two of the ten “intensity” factors are arguably implicated by the project, and those two factors have little weight under the circumstances of this case. In view of these considerations, and the many mitigation measures which have been incorporated into the project, the Court concludes that 1-270 project planners have convincingly justified their decision not to prepare an EIS. Here the defendants “conducted a thorough analysis of the proposed action and imposed specific measures to address the relevant areas of environmental concern.” Cabinet Mountains Wilderness v. Peterson, 685 F.2d 678, 684 (D.C.Cir.1982); see also Sierra Club v. United States Department of Transportation, 753 F.2d at 129. 3. Inadequacy of EA and FONSI Plaintiffs’ second argument under NEPA is that the EA and FONSI prepared for the 1-270 project were inadequate bases for determining whether an EIS was required. By regulation, an EA is designed to “assist in determining the need for an EIS.” 23 C.F.R. § 771.119(a) (1985). The EA therefore must, inter alia, define the scope of the proposed project, identify alternatives, and determine which aspects of the project have potential for environmental impact. Id. § 771.119(b). Plaintiffs assert that the 1-270 EA and FONSI performed none of these functions. Plaintiffs’ contentions will be considered. a. Improper Segmentation Plaintiffs first argue that the 1-270 EA failed to properly define the scope of the project because the 1-270 project was improperly “segmented” from the three related highway projects and from the 1-270 “spur” or “Y-split.” In assessing this claim, the Court is again guided by federal regulations. FHWA regulations require that any FONSI for a highway project “shall evaluate a project which”: (1) Connects logical termini and is of sufficient length to address environmental matters on a broad scope; (2) Has independent utility or independent significance, i.e., is useable and a reasonable expenditure even if no additional transportation improvements in the area are accomplished; (3) Will not restrict consideration of alternatives for other reasonably foreseeable transportation improvements. 23 C.F.R. § 771.111(f) (1985). These regulations reflect the general rule that NEPA does not permit agencies to avoid review of cumulative effects by dividing projects into components. See, e.g., Kleppe v. Sierra Club, 427 U.S. at 410, 96 S.Ct. at 2730; National Wildlife Federation v. Appalachian Regional Comm’n, 677 F.2d 883, 890 (D.C.Cir.1981); Scientists’ Institute for Public Information, Inc. v. Atomic Energy Comm’n, 481 F.2d 1079, 1086-88 (D.C.Cir.1973). Illegal segmentation has been found in a number of highway construction cases. See, e.g., Swain v. Brinegar, 542 F.2d 364 (7th Cir.1976) (en banc); Indian Lookout Alliance v. Volpe, 484 F.2d 11 (8th Cir.1973); Named Individual Members of San Antonio Conservation Society v. Texas Highway Dep’t, 446 F.2d 1013 (5th Cir.1971), cert. denied, 406 U.S. 933, 92 S.Ct. 1775, 32 L.Ed.2d 136 (1972). Project Termini and Length. The 1-270 project has its north terminus at MD 121 and its south terminus at the 1-270 spur or Y-split and measures sixteen miles. Within that stretch, construction also will occur with respect to the MD 124, MD 189, and 1-370 projects. Plaintiffs assert that each of these separate construction projects must be deemed “termini,” so that the I-270 project itself will consist of intermittent stretches of highway of varying lengths and with separate termini. The Court rejects this contention. The MD 124 and MD 189 interchange construction projects will not themselves involve any construction along mainline I-270, save for construction of off-ramps and on-ramps at the new MD 189 interchange. Project planners thus reasonably concluded that the points of construction for the MD 124 and MD 189 projects were not properly deemed termini of the 1-270 project. The 1-370 project, on the other hand, will involve substantial construction on 1-270, including building of 2.5 miles of mainline and CC-D roads along 1-270, a bridge to carry 1-270 traffic over 1-370, and noise barriers and retaining walls along 1-270. This 1-370 construction will significantly “interrupt” the 1-270 project and thus may constitute a “terminus” for purposes of 23 C.F.R. § 771.111(f)(1). It does not follow, however, that improper segmentation has occurred, since 1-270 project planners could reasonably have concluded that the 1-370 area was a “logical” terminus. Courts have found that a “major crossroad” is a logical terminus for a highway. See, e.g., Adler v. Lewis, 675 F.2d 1085, 1097 (9th Cir.1982); Swain v. Brinegar, 542 F.2d at 370. In addition, it appears that significant portions of 1-370 construction were in fact included in the 1-270 environmental review process. See Affidavit of Neil Pedersen, at 7-8 (June 2, 1986). Any “segmentation” of the 1-270 and 1-370 projects thus did not improperly remove impacts from environmental consideration. A more pressing concern is whether the southern terminus of the 1-270 project— the spur or Y-split — is “logical.” As the “Y-split” name implies, this section of highway splits 1-270 in two to facilitate access to and from 1-495, the Capital Beltway. Each leg of the Y-split currently has four mainline lanes and no CC-D roads. The Court concludes that project planners reasonably found that the Y-split was a logical terminus. Because the sole function of the Y-split is to channel traffic from the Beltway to mainline 1-270, the Y-split may properly be described as a “traffic generator” with respect to 1-270. “Traffic generators” are commonly regarded as logical termini for highway projects. See, e.g., Lange v. Brinegar, 625 F.2d 812, 815-16 (9th Cir.1980). Swain v. Brinegar, 542 F.2d at 370. Independent Utility or Significance. The second requirement set by FHWA regulations is that a highway project must have independent utility or significance. See 23 C.F.R. § 771.111(f)(2). The previous discussion of the MD 124, MD 189, and 1-370 projects reveals that each of those projects has a utility or significance apart from the 1-270 project. Similarly, the 1-270 project has utility or significance independent of those projects, since the contemplated widening of 1-270 will alleviate traffic congestion without regard to the MD 124, MD 189, and 1-370 projects. While the projects are related, in that each will affect traffic conditions on 1-270, they have independent utility in that each project “can serve its transportation purpose whether or not the other projects are built.” Piedmont Heights Civic Club, Inc. v. Moreland, 637 F.2d at 440. In addition, the 1-270 project has utility and significance independent of any improvement to the Y-split because approximately 45 percent of all traffic on 1-270 is “intracorridor” in that it leaves the highway prior to the Y-split. See FONSI at Plate 8. Thus, the project has independent utility because it will serve state and local needs. See Lange v. Brinegar, 625 F.2d at 815-16. Consideration of Other Projects. The final factor cited in the FHWA regulations is whether a project will “restrict consideration of alternatives for other reasonably foreseeable transportation improvements.” 23 C.F.R. § 771.111(f)(3). Plaintiffs argue that improvement of the Y-split is “reasonably foreseeable” and that the widening of 1-270 prior to the Y-split will necessarily restrict consideration of alternatives for Y-split improvement. See Swain v. Brinegar, 542 F.2d at 370; Named Individual Members, 446 F.2d at 1023. The Court rejects this argument. As was noted previously, the Y-split already consists of eight lanes. As such, the eight mainline lanes of a widened 1-270 will simply match the capacity of the current Y-split. Moreover, project planners may reasonably have concluded that the addition of the four CC-D lanes north of the Y-split would not restrict consideration of potential improvements to the Y-split. The purpose of the CC-D roads is to facilitate ingress to and egress from mainline 1-270 with respect to interchanges along 1-270. Since there is no interchange at the Y-split, continuation of the CC-D roads past the Y-split is not mandated. In addition, defendants note, their traffic analysis indicates that 45 percent of all trips along 1-270 terminate prior to the Y-split. The Court has considered plaintiffs’ arguments and has concluded that defendants have complied with the FHWA regulations and have not impermissibly segmented the 1-270 project. The administrative record establishes that defendants took a “hard look” at the project and reached reasonable conclusions that have a substantial basis in factual evidence included in the administrative record. See Baltimore Gas & Elec. Co. v. Natural Resources Defense Council, Inc., 462 U.S. 87, 97-98, 103 S.Ct. 2246, 2252-53, 76 L.Ed.2d 437 (1983). That is all that NEPA requires. b. Consideration of Alternatives Plaintiffs’ second contention as to the adequacy of the EA and FONSI is that they failed to adequately discuss and analyze alternatives to the 1-270 project. An examination of the record establishes that this claim has little merit. As an initial matter, it should be noted that the FHWA regulations require only that an EA “identify” alternatives to a proposed project. See 23 C.F.R. § 771.-119(b). The EA on the 1-270 project identified five alternatives — no-build, eight lanes, ramp metering, HOY lanes, and the selected project — and discussed the reasons for rejection of the nonselected alternatives. See A.R. 229, at 31-38. An agency’s consideration of alternatives is reviewed under a “rule of reason”; the agency need only set forth those alternatives sufficient to present a reasoned choice. Natural Resources Defense Council, Inc. v. Morton, 458 F.2d 827, 833-38 (D.C.Cir.1972); accord, Vermont Yankee Nuclear Power Corp., 435 U.S. at 551, 98 S.Ct. at 1215. NEPA is not violated so long as the agency takes a “hard look” at alternatives and explains its reasons for rejecting them. See Baltimore Gas & Elec. Co., 462 U.S. at 97-98, 103 S.Ct. at 2252-53; Culpeper League for Environmental Protection v. U.S. Nuclear Regulatory Comm’n, 574 F.2d 633, 634 (D.C.Cir.1978) (per curiam). The 1-270 project EA makes clear that the alternatives were rejected for failure to adequately address traffic congestion on 1-270. See A.R. 229, at 30-37. The administrative record reveals that these conclusions were based on adequate study and analysis of traffic patterns. See A.R. 275, 185, 92. The record also reveals that the physical effects of these alternatives were studied. See A.R. 173, 168, 104, 73. The record thus establishes that the FHWA took a “hard look” at the alternatives and that its conclusions about traffic congestion and the resulting effect on the “human environment” “have a substantial basis in fact.” Izaak Walton League of America v. Marsh, 655 F.2d 346, 371-72 (D.C.Cir.), cert. denied, 454 U.S. 1092, 102 S.Ct. 657, 70 L.Ed.2d 630 (1981). The sort of exhaustive analysis urged by plaintiffs, encompassing every conceivable effect of each alternative, simply is not required by NEPA. See Vermont Yankee Nuclear Power Corp., 435 U.S. at 551, 98 S.Ct. at 1215. c. Failure to Analyze Impacts Plaintiffs’ final argument as to the adequacy of the EA and FONSI is that defendants failed to properly analyze various impacts likely to arise from the 1-270 project. With respect to the adequacy of defendants’ analysis of impacts on noise levels, water quality, air quality, wildlife habitat, and wetlands, the Court rejects plaintiffs’ claims. The FONSI and EA each discuss these impacts in significant detail, and the agency’s consideration of those impacts was properly informed by studies included in the administrative record. See A.R. 66, 73, 197, 199, 199a, 200, 276; see also A.R. 229, at 20-30, 52-76; FONSI at IV-1-8. Under “rule of reason” review, the Court concludes that the agency took a “hard look” at these likely impacts and that its conclusions had a “substantial basis in fact.” See Izaak Walton League, 655 F.2d at 371-72; Culpeper League for Environmental Protection, 574 F.2d at 634; Concerned About Trident v. Rumsfeld, 555 F.2d 817, 827 (D.C.Cir.1976). Plaintiffs also contend that defendants failed to adequately assess the 1-270 project’s impact upon the Capital Beltway. The Court disagrees. The FONSI makes clear that planning for improvements to the Beltway are under separate consideration and that those contemplated improvements were factored into the 1-270 project. See FONSI at 1-1-2, VIII-22. Studies of Beltway traffic conditions were made as part of the Beltway project and simply were not repeated in the 1-270 administrative record. See Affidavit of Neil Pederson, at 3 (June 2, 1986). Consideration of Beltway traffic conditions thus did occur and was sufficient to satisfy NEPA. As one court has noted, so long as a project’s “underlying data base included the approved projects and pending proposals, the ‘statutory minima’ of NEPA has been met.” Piedmont Heights Civic Club, 637 F.2d at 441. B. Section h(f) Plaintiffs’ second challenge to the 1-270 project is brought under Section 4(f) of the Department of Transportation Act, 49 U.S.C. § 303. The provision relevant to this case provides: The Secretary may approve a transportation program or project requiring the use of publicly owned land of a public park, recreation area, or wildlife or waterfowl refuge of national, State, or local significance, or land of an historic site of national, State, or local significance ... only if— (1) there is no prudent and feasible alternative to using that land; and (2) the program or project includes all possible planning to minimize harm to the park, recreation area, wildlife and waterfowl refuge, or historic site resulting from the use. 49 U.S.C. § 303(e). The framework for judicial review under Section 4(f) was established by the Supreme Court in Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 91 S.Ct. 814, 28 L.Ed.2d 136 (1971). The Overton Park Court noted that the determination of an alternative route’s “feasibility” under Section 4(f)(1) “admits of little administrative discretion”; an alternative may be rejected as infeasible only if the Secretary can find “that as a matter of sound engineering it would not be feasible to build the highway along any other route.” 401 U.S. at 411, 91 S.Ct. at 821. In addition, the “prudency” determination required by Section 4(f)(1) also does not permit a “wide-ranging endeavor” by the Secretary. Id. Rather, the Court concluded, the very existence of [Section 4(f)] indicates that protection of parkland was to be given paramount importance. The few green havens that are public parks were not to be lost unless there were truly unusual factors present in a particular case or the