July 29, 2022 

Baltimore Regional Transportation Board 
1500 Whetstone Way 
Suite 300 
Baltimore, MD 21230 

RE: Draft 2023-2026 Transportation Improvement Program (TIP) 

Dear Members of the Baltimore Regional Transportation Board (BRTB): 

Thank you for the opportunity to provide input on the Draft 2023-2026 Transportation Improvement Program (TIP) for the Baltimore region. The TIP can be simply described as the list of regional transportation projects using federal funds over the next four years. However, we believe it is important to look at this document not simply as a collection of individual projects, but as a program that reflects our region’s transportation priorities. 

Many of the undersigned organizations have submitted comments for the region’s last two TIPs. In the 2021 TIP letter we wrote: 

“Unfortunately, this Draft TIP does not prioritize spending in a way that will do anything but worsen the interwoven crises facing our state and our world. The COVID-19 pandemic is an acute crisis that has highlighted how black people and other communities of color have been disproportionately impacted by poor air quality. Meanwhile, the climate crisis continues to mount with the transportation sector as the number one source of greenhouse gas emissions. And the racial and economic disparities underlying it all are, in part, due to decades of transportation and land use decisions designed to exclude and segregate black people.” 

In the 2022 TIP letter we referenced that passage and then wrote: 

“Those realities have not fundamentally changed in the last year. Despite some improvements in spending by category, the 2022-2025 TIP is still heavily tilted towards spending on fossil fuel infrastructure that exacerbates more problems than it purports to solve. In the previous TIP we noted that the $1.3 billion for highway capacity was 650 times the $2 million programmed for transit capacity. In this year’s TIP, there are zero dollars for transit capacity. So despite a reduction in the highway capacity category (still almost a billion dollars), mathematically speaking, the region is now spending infinitely more on new highways than it is on new transit. The consequence of spending priorities like these is ever more driving. No wonder Maryland was setting new highs for vehicle miles traveled per capita shortly before the pandemic.” 

Now for the Draft 2023-2026 TIP we could re-submit those same comments verbatim, and they would still hold true. The 2023 TIP still has zero dollars for transit capacity or commuter rail capacity, but $900 million for highway capacity. In fact, the one positive step that the BRTB took in last year’s TIP, not adding any new highway capacity projects, has been reversed. The 2023 TIP adds four new highway capacity projects into the project pipeline. We believe that this region is in a deep transportation hole and the first step in getting out of it is to put down the shovel on adding more road capacity. We ask the BRTB to remove from the Draft 2023-2026 TIP the four highway capacity projects listed in Table II-2. 

As highlighted in our 2021 letter, many of the elected officials who serve on the Board have expressed a desire to invest in a multi-modal transportation system that reduces our dependence on cars. Unfortunately, the reality continues to fall short of the rhetoric as evidenced in the regional spending priorities the BRTB approves each year. As regional leaders, you have options to change the status quo. 

For example, the BRTB could use annual federal surface transportation funding for transit, bike and pedestrian infrastructure rather than continuing its practice of spending them exclusively on roads. In fact, Section IIA of the Draft TIP states: 

“The TIP is required to take full advantage of the increased flexibility of Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) capital funds. MDOT provides a “statement of concurrence” that consideration of this provision (flexing funds) has been utilized in the development of all state initiatives.” 

The two largest sources of flexible federal funds are the National Highway Performance Program (NHPP) and the Surface Transportation Block Grant Program (STBG). However, according to the tables summarizing federal aid for each fiscal year from FY 2023 through FY 2026, there are zero NHPP or STBG funds being flexed to transit. 

If the region does not take the necessary step of redirecting these funds away from widening roads and towards sustainable transportation, then we will continue on a business as usual path that continues to hold this region back from reaching its full potential economically, socially, and environmentally. 

Sincerely, 

1199 SEIU United Healthcare Workers East, Maryland/DC 
Audubon Mid-Atlantic 
Baltimore MARC Riders 
Bikemore 
Cedar Lane Environmental Justice Ministry
Central Maryland Transportation Alliance
Clean Water Action 
Climate Reality, Baltimore Area Chapter Coalition for Smarter Growth 
Downtown Residents Advocacy Network (Baltimore) 
Howard County Climate Action 
Indivisible Howard County 
Labor Network for Sustainability
Maryland Nonprofits
Maryland Sierra Club
MLC Climate Justice Wing
The Fund For Educational Excellence
Transit Choices

CC: Mike Kelly, BMC
Todd Lang, BMC 
Regina Aris, BMC 
Keith Kucharek, BMC