Despite a new climate action plan by TPB’s parent agency the Council of Governments, this Visualize 2045 makes no real changes and fails to reduce emissions any more than the last one.
On behalf of the Transform Maryland Transportation Coalition (formerly Save MD Transit), we thank you for your support of the Transit Safety & Investment Act during the 2021 General Assembly. The bill will help assure MTA’s current maintenance needs will be addressed over the next five years.
Montgomery County Council
100 Maryland Ave. 6th Floor
Rockville, MD 20850
March 17, 2022
We are writing with respect to the Council’s consideration of the draft County economic development plan. We urge you to support the removal of a recommendation on page 30 to “Cooperate with state and federal resources to facilitate expedient expansion of the American Legion Bridge, the Capital Beltway (Interstate 495) and I-270…” and to oppose any substitute language that suggests support for the toll lanes.
We appreciate the Council’s effort to seek efficient transportation in this corridor. Because the Maryland Department of Transportation’s Supplemental Draft Environmental Impact Statement (SDEIS) lacked key analyses, including on environmental justice and climate change, it would be a mistake to recommend the toll lanes project in the economic development plan. Without a complete SDEIS, the public and policymakers are denied a full understanding of the project’s impacts and an opportunity to provide input that could help shape final decisions.
Environmental Justice Concerns
The SDEIS did not include an environmental justice analysis to show whether the negative consequences of the toll lanes would fall disproportionately on communities of color and low-income residents. Instead, MDOT has deferred this analysis until the Final Environmental Impact Statement (FEIS). Because the public comment process ended on November 30, there will be no opportunity for the public to review the environmental justice analysis and provide input. Embracing the toll lanes without an environmental justice analysis is not consistent with the County’s Racial Justice and Social Equity Initiative which is aimed at making informed decisions to ensure equitable outcomes.
While MDOT has consulted with stakeholders regarding the impact of the toll lanes on the Morningstar Tabernacle No. 88 Moses Hall and Cemetery, it has not fully assessed the impact on all of the cemetery property, including all potential grave sites. MDOT cannot avoid or minimize disturbance of gravesites at the cemetery in this historic Black community, if it does not know where all the graves are located.
Failure to Study Impact on Climate Crisis
MDOT also failed to provide an analysis in the SDEIS showing how the operation of the toll lanes would impact greenhouse gas emissions. In its comments, the Maryland-National Capital Park and Planning Commission noted that the toll lanes would shift bottlenecks, but not eliminate congestion in the corridor. Their comments went on to state that, “While some of these bottleneck shifts were expected, the degree resulting from the proposed project is severe on I-270 north of I-370, on the Inner Loop on the top side of the Beltway, and on the Inner Loop in Prince George’s County.” These severe bottlenecks are likely to increase greenhouse gas emissions. It is critical that MDOT analyze emissions from the operation of the toll lanes and provide public review and comment. The County Council has established ambitious goals for reducing greenhouse gas emissions. But it cannot know whether its plan is adequate if it does not know the impact of the operation of the toll lanes.
While MDOT is planning to conduct an analysis of the greenhouse gas emissions from construction activity, they deferred it until the FEIS. This blocks the public and local policymakers from providing input and offering steps to mitigate emissions.
Purple Line 2.0
Last August, the entire Council urged the Board of Public Works (BPW) to delay a vote on the predevelopment contract with Transurban and allow the State’s bond counsel and financial advisor to review the contract. While the BPW did not heed your call, your request for due diligence was prudent. As you know, Capital Express Mobility Partners (CEMP) has challenged the award of the project to Transurban, arguing that their bid understated the costs of the project and that this would lead to cost overruns, and delays. The Montgomery County Circuit Court recently ruled that MDOT was wrong to ignore the substance of CEMP’s challenge and ordered the agency to review it. During the hearing, the judge expressed dismay that MDOT had not evaluated CEMP’s claims that the Transurban bid was not financially feasible. If CEMP’s claims are ignored, the County risks disruption that could far exceed the Purple Line debacle.
The omission of important analyses in the SDEIS, denying the public the opportunity to provide input and the failure of MDOT to exercise financial due diligence should give you pause. We urge you to strike the recommendation of the toll lanes project from the draft economic development plan.
350 Montgomery County
Audubon Naturalist Society
Baltimore Transit Equity Coalition
Biodiversity for a Livable Climate
Cedar Lane Unitarian Universalist Church Environmental Justice Ministry
Central Maryland Transportation Alliance
Chesapeake Bay Foundation
Chesapeake Physicians for Social Responsibility
Citizens Against Beltway Expansion
Coalition for Smarter Growth
Friends of Sligo Creek
Glen Echo Heights Mobilization
Greater Farmland Civic Association
Greater Greater Washington
Howard County Climate Action
Interfaith Power & Light (DC. MD. NoVA)
League of Women Voters of Maryland
Maryland Legislative Coalition
Maryland Sierra Club
National Parks Conservation Association
Neighbors of the Northwest Branch
Rails to Trails Conservancy
Save Our Seminary
Sligo Creek Golf Association
Smart Growth Maryland
The Climate Mobilization Montgomery County
Washington Area Bicyclist Association
Woodside Forest Civic Association
The Coalition for Smarter Growth submits the following comments in response to the Notice of Availability of the I– 495 & I–270 Managed Lanes Study Supplemental Draft Environmental Impact Statement (SDEIS) and Updated Draft Section 4(f) Evaluation. We have also signed onto and endorse the comments submitted by the Maryland Chapter of the Sierra Club and separate comments by the Maryland Transit Opportunities Coalition.
On Wednesday, the three-person Maryland Board of Public Works is scheduled to vote on the contract to widen I-495 and I-270 with four private toll lanes. This vote is happening before critical financial and risk analyses and a final environmental impact statement are complete. We are calling on the Board to delay the vote.
Good government demands that members of the Board of Public Works and the public should know the full fiscal, environmental, and social risks of this project by completing the environmental impact study before the Board of Public Works votes — certainly before locking Maryland into a long-term, exclusive contract.
To be clear, we agree that we need to address the Beltway and I-270, but the process has been distorted from the beginning because of the power of the toll road companies and Governor Hogan starting with the conclusion first and failing to objectively consider alternatives.
Evaluation of alternatives is particularly important because the highway expansion will harm hundreds of acres of parkland, wetlands, and waterways, as well as lead to more noise, air pollution, stormwater runoff, and greenhouse gas emissions.
Here’s how you can help:
- Join the rally Wednesday morning! At 8:45am on August 11, join us and our environmental and community partners at a rally/press conference tomorrow morning. The plan is to gather at 8:45am at the Treasury Building at 80 Calvert St. in Annapolis. More info about speaker to come. Directions and parking options here.
- Call Comptroller Peter Franchot: Before 10am on August 11, call Board of Public Works member and State Comptroller Peter Franchot at 410-260-7801. Here’s what to say: My name is X, and I am a resident of (insert city). I’m calling to urge Comptroller Franchot to delay a vote on the I-495 & I-270 initial contract until after the final Environmental Impact Statement is complete and we know the risks. Talking points can be found here.
- Testify or submit written comments as soon as possible:
- Submit written testimony to firstname.lastname@example.org, email@example.com, and Treasurer@treasurer.state.md.us
- You can testify in-person at the Treasurer’s Office in Annapolis or virtually. Send request to firstname.lastname@example.org and specify you want to testify in opposition on item 11-GM.
This project isn’t worth the high cost to parks, streams, neighborhoods, taxpayers, and drivers. Instead of investing in transit-oriented communities — especially in Prince George’s County — it condemns residents of the east side of our region to forever having more costly, long commutes. Read more in CSG’s executive director’s op-ed in the Baltimore Sun.
COALITION FOR SMARTER GROWTH
For Immediate Release
July 21, 2021
Stewart Schwartz, Executive Director, 703-599-6437
Transportation Planning Board Re-Vote on Governor Hogan’s Toll Lanes
Governor Hogan’s strong-arming further exposes biases and flaws in Beltway/270 study, and the distortions of the P3 approach
Today, the regional Transportation Planning Board voted to reinstate the Beltway/I-270 toll lanes project in the long-range transportation plan for air quality modeling. The revote followed a massive political campaign by Governor Hogan, including threats to cut projects, removals of toll road opponents and appointments of supporters, and weak promises of additional investment in transit.
“Rather than establishing the merits of his toll lanes project, Governor Hogan has reinforced the serious bias and flaws in his approach to the Capital Beltway and I-270,” said Stewart Schwartz, Executive Director of the Coalition for Smarter Growth. “He started with the conclusion that he wanted private toll lanes and has failed to analyze comprehensive alternatives.”
“The toll lanes would reinforce the East-West economic divide in our region condemning Prince George’s commuters to either paying very high tolls or sitting in the general-purpose lane traffic that the toll road companies depend on to generate their profits. A far better alternative is Maryland investment in transit-oriented development on the east side of the region, which would increase jobs, shorten commutes, even out the flows on the Beltway and Metrorail, and help address the E-W economic and racial divide,” said Schwartz.
“The P3 process in Virginia and Maryland is resulting in undue influence by multinational corporations, prejudging and biasing the outcome of environmental and alternatives studies,” said Schwartz. “The premature approval of 495Next in Virginia created a threat of a bottleneck at the American Legion Bridge, which has become a way to force concerned Virginia and Maryland jurisdictions to support the further extension of the toll lanes into Maryland.”
“Not only are we not getting objective evaluation of alternatives, these projects also fail to adequately fund good, effective transit, and include non-compete clauses that potentially block important transit investments such as future Metrorail or light rail at the American Legion Bridge.”
“It is astounding to see our local and state leaders pressing forward with massive highway expansion in the face of the existential threat of climate change. In the past weeks, we have heard more about the melting of ice sheets in the Arctic, Greenland, and Antarctica, massive fires in the Western US, deadly flooding in Europe, the US and China, and shellfish cooking on the beaches of Canada amid record heat waves,” said Schwartz. “As this vote took place today, the DC region has a Code Orange, unhealthy air due to particulate pollution from the haze from massive Western wildfires.”
“Going forward, we are urging the Maryland Board of Public Works to delay action on contracts until completion of the environmental impact studies and the addition of a TOD/transit/demand management alternative,” concluded Schwartz.
Our thanks to the following elected officials and their jurisdictions who stood up for fighting climate change, and for transit and sustainable, equitable communities: Mayor Patrick Wojahn (College Park), Mayor Emmett Jordan (Greenbelt), County Executive Marc Elrich ( Montgomery County), Mayor Bridget Newton (Rockville), Councilmember Kacy Kostiuk (Takoma Park), Mayor Pro Tem Adrian Boafo (Bowie), Delegate Marc Korman (MD House), and Councilmembers Brooke Pinto, Charles Allen, and Christina Henderson (DC).
July 20, 2021
Hon. Charles Allen
Chair, National Capital Region Transportation Planning Board
Re: TPB Vote on Capital Beltway/I-270 and the Long-Range Transportation Plan
Chair Allen and members of the TPB:
I will keep our comments short:
- Governor Hogan and MDOT have:
- Completely failed to objectively study alternatives to the toll lanes
- Put the P3 negotiations and contracts ahead of completion of the EIS, and biased the entire process for private toll lanes.
- Run a scorched-earth political campaign which demonstrates their bias.
- The toll lane deals for 495Next in Virginia and for Maryland not only lack the commitment to transit funding we need, the non-compete provisions appear to prevent future Metrorail at the American Legion Bridge and other transit investments.
- Climate change is an existential threat. Contrary to MDOT arguments, highway expansion increases driving and CO2 emissions. It is astounding to see massive highway expansion proposed while the Arctic and Antarctic melts, the West burns, Europe floods, and shellfish cooks on the beaches of Canada.
- The toll lanes would reinforce the East-West economic divide in our region condemning Prince George’s commuters to either paying very high tolls or sitting in the general-purpose lane traffic that the toll road companies depend on to generate their profits.
- A far better alternative is Maryland investment in transit-oriented development on the east side of the region, which would increase jobs, shorten commutes, even out the flows on the Beltway and Metrorail, and help address the E-W economic and racial divide.
Therefore, we urge you to stand by your vote to remove the toll lanes from the TPB’s long range plan and honestly to take the same step for the 495Next project – in order to force objective consideration of alternatives, the climate impacts, and the development of the most sustainable and effective alternative with the least impact on parks and communities.
We are running out of time on the climate and are failing to do what needs to be done to address the E-W economic and racial divide. We need your leadership.
May 4, 2021
House Committee on Transportation & Infrastructure
Subcommittee on Railroads, Pipelines, and Hazardous Materials
2167 Rayburn House Office Building
45 Independence Ave SW
Washington, DC 20515
Hearing: “When Unlimited Potential Meets Limited Resources: The Benefits and Challenges of High-Speed Rail and Emerging Rail Technologies”
Testimony for May 5, 2021
Jane Lyons, Maryland Advocacy Manager
Please accept these comments on behalf of the Coalition for Smarter Growth, the leading organization in the Washington, DC region advocating for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way to grow and provide opportunities for all. We have strong partnerships with business, conservation, and affordable housing organizations, and received the 2017 Regional Partnership Award from the Metropolitan Washington Council of Governments.
We have been strong supporters of major rail improvements in the Northeast corridor, but are convinced that the proposed Baltimore-Washington Superconducting Magnetic Levitation (SCMAGLEV) project is the wrong technology and design for the Washington-Baltimore corridor and the NE Corridor as a whole. Therefore, we urge you to not provide federal financial support to this project. Instead, we urge significant investments in both the Amtrak and commuter rail improvement programs.
The project would have a negative impact on racial and social equity. Construction would plow through majority Black Prince George’s County, but the residents of Prince George’s County would not be able to take advantage of the project, since the technology and design speed are such that there will only be stops in DC, at BWI Airport, and at Penn Station in Baltimore. Environmental Justice (EJ) communities would be disproportionately impacted, with 80 percent of impacted parcels located in EJ communities.
Furthermore, the high projected cost of a one-way ticket sends a signal that this project is for the wealthiest white-collar commuters, not those who will suffer from the damage wrought by the project or those who need more accessible, frequent, and affordable transit. A $60 ticket for the SCMAGLEV would be about seven times more than an existing MARC commuter rail ticket for the same trip ($8) or existing Amtrak Acela ticket ($46).
We are also concerned about the project’s negative effect on existing taxpayer investments in transit. The project is already diverting attention from repairing and improving our existing MARC and Amtrak infrastructure. If public funding is required for the Maglev, it could divert hundreds of millions of dollars in addition to fare revenue lost due to reduced ridership on Amtrak and MARC.
The Maglev is a potential public-private partnership, and recent experience with P3s in Maryland and other states suggests that public funding will be required. Given that Maglev is a multi-billion dollar technology yet to be implemented anywhere in the U.S., this project could require significant public funding.
The limited time savings is also not worth the cost and risk. The Acela Express between DC and Baltimore currently takes 30 minutes. While Maglev would cut time spent on the train in half, it doesn’t account for time spent getting to the station. The average total trip would go from 90 minutes to 75 minutes, which is not worth the risk, nor the costs to equity and environmental quality.
Investing in the Maryland MARC and Amtrak NE Corridor expansion plans would more effectively serve the transit needs of our region and the NE Corridor. Upgrades to the existing rail system could also more easily be extended to other destinations like New York and Boston, than would be the case with Maglev which would need entirely new right-of-way through the very densely developed Northeast. Existing rail stations are located in more central and well-established transit hubs, like DC’s Union Station. A much more cost-effective solution would be to invest in improving our existing infrastructure and upgrade over time to high-speed rail standards.
In conclusion, we urge you to pursue upgrades to the nation’s existing rail infrastructure, including high-speed rail, in lieu of the SCMAGLEV. Thank you for your time.
Maryland Governor Larry Hogan announced a major shift in state transportation spending to prioritize the maintenance and expansion of roads and bridges over investment in mass transit projects.
While unveiling plans to spend $2 billion on roads — including $845 million on entirely new projects — at an Annapolis news conference on Thursday, the governor finally revealed his highly-anticipated decisions for two light rail proposals.
Hogan gave conditional approval to the $2.4 billion Purple Line in the D.C. suburbs but axed the $2.9 billion Red Line in Baltimore. The latter project’s plan to build a $1 billion tunnel was labeled a “fatal flaw.”
Roads are “top priority”
“I’ve made it very clear that building, maintaining, and fixing Maryland’s roads and bridges is our top transportation priority and it is a top priority of our administration,” the Republican governor said.
“In January, our administration inherited a state infrastructure that for years had been severely underfunded. The previous administration slashed funding for local road improvements by up to 96 percent,” said Hogan, whose statewide road building plans mark a clean break from that recent past.
The governor called for $1.3 billion to be added to the $625 million already in the Maryland Department of Transportation’s construction budget for a slew of road and bridge jobs — from widening congested corridors such as Rt. 404 and studying congestion relief on I-270 to repaving 2,000 miles of state highways and “fixing every single structurally deficient bridge in the state.”
Purple Line survives — for now
Since taking office Hogan has called the 16-mile light rail line from Bethesda to New Carrollton too expensive, ordering the four contractor teams competing for the construction bid to shave hundreds of millions from the its growing price tag.
On Thursday, the governor announced his intention to reduce the state’s upfront commitment for construction by $500 million by 1) running trains less frequently (every 7.5 minutes instead of 6 minutes) and making other unspecified changes to the Purple Line’s scope, 2) asking the private sector firm that wins the long-term concession to front more cash, and 3) squeezing more money out of Montgomery and Prince George’s counties.
“Under our more efficient and more cost effective version of the Purple Line, the state’s share of the project will be $168 million, a fraction of the original proposal,” Hogan said. “By reducing this cost, we free up hundreds of millions of dollars for other important projects across Maryland.”
The Purple Line’s route and number of stations will not be changed, said Maryland Secretary of Transportation Pete Rahn.
Will counties show Hogan the money?
Montgomery County executive Ike Leggett has said his county is tapped out, but released a statement following Hogan’s news conference indicating a willingness to work with state officials.
“I look forward to further discussions with the Governor over every aspect of the Purple Line — cost, design, construction schedule, and the role Montgomery County will be able to play in making the Purple Line a reality,” Leggett said.
“Prince George’s County has already committed an extraordinary amount for local governments to contribute toward a state project. I will thoroughly review this proposal along with my budget, finance, economic development, and transportation advisers to assess what this means for Prince George’s County,” said the county executive Rushern Baker in a post-news conference statement.
Transit advocates cautiously praised the project’s conditional approval but were concerned ongoing negotiations over price could further delay a project whose construction was scheduled to begin this year, buttressed by the promise of $900 million in federal aid.
“This is a big lift for Montgomery and Prince George’s County,” said Stewart Schwartz, the executive director of the Coalition for Smarter Growth, a group that opposes highway projects in favor of public transit.
“It is our hope that it doesn’t cause protracted negotiations. It is our hope that the governor is willing to give a little and put more state dollars back into the project, but the key is to not lose the federal funding,” Schwartz said.
Sec. Rahn indicated the state will be ready to make a decision on which contractor team submitted the most effective design changes in the next four to five months, essentially ruling out construction until 2016.
I-270 set for congestion study
There may be no group happier about the idea of spending $2 billion on roads and bridges than AAA Mid-Atlantic, one of the most vocal critics of former Governor Martin O’Malley.
“Governor Hogan hit a grand slam,” said AAA’s Lon Anderson, who echoed Hogan’s criticism that the O’Malley administration siphoned money from the state transportation trust fund for wasteful purposes. “I look at it as a rebalancing. Each administration comes in and sets priorities. The O’Malley administration came in and made transit its focus.”
Anderson said the Maryland Department of Transportation intends to use $100 million to study congestion relief on I-270 similar to how Virginia plans to transform I-66: use existing or additional lane capacity to manage congestion through tolls, HOV restrictions, or boosting bus transit.
“They want to make this a showcase for how technology can help better manage traffic,” Anderson said. “They are going to ask contractors and seek ideas and bids about what they would do on a certain budget to make 270 work better.”
The $100 million will fund a test program called “Innovative Congestion Reduction Strategies.”
A mix of roads and rails
Transit advocates reacted negatively to Hogan’s frugal approach to the Purple and Red Lines on the same day he threw $2 billion at highways, but transportation policy experts said the governor faces a difficult balance in such a diverse state.
“The governor has made it clear he has a priority to fix the roads throughout the state,” said Paul Lewis, director of policy and finance at the Eno Center for Transportation, a D.C. research group.
The suggestion that any project — highway or transit — will reduce congestion is dubious, Lewis said.
“If you look at the projections over the next 25 years, the region is supposed to grow by a million people and that will lead to congestion. The Metropolitan Washington Council of Governments estimates there will be another 400,000 drivers on the road by 2040,” Lewis said.
“Congestion is going to increase regardless of whether the Purple Line is built. It is more of an economic tool that will help shape new patterns of development in the region. It is an accessibility project that helps diversify the transportation mix to provide options for people,” Lewis said.
In fact, the economic development benefits of the Purple Line were key selling points when local officials relentlessly lobbied Hogan in recent months.
“In a growing region you need to have a diversified transportation network. Most people do get around by the roads but that is not just single occupancy vehicles, It’s also transit buses and carpoolers. Transit is part of that mix,” said Lewis, who said the Eno Center evaluates all projects together rather than separating out highway investments from transit.
Read original article here.