Category: Testimony & Letters
CSG Testimony Re: Montgomery County Complete Streets Design Guide
July 21, 2020
Montgomery County Planning Board
8787 Georgia Ave
Silver Spring, MD 20910
Item 12 – Complete Streets Design Guide (Support)
Testimony for July 23, 2020
Jane Lyons, Maryland Advocacy Manager
Good evening and thank you to Chair Anderson and Planning Commissioners. My name is Jane Lyons and I’m speaking on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. We enthusiastically support the Complete Streets Design Guide.
Thank you and congratulations to the staff who worked on this project – who has yet again solidified Montgomery Planning as a national leader in creative suburban planning. We are pleased that the Complete Streets Design Guide is clear in prioritizing safety, sustainability, and vitality, and provides a roadmap for how to balance competing needs. When we prioritize street space correctly, streets can become an engine for healthy people, a healthy economy, and a healthy environment.
The biggest challenge in actualizing safe, green, vibrant streets is reengineering the county’s arterial roads, especially in lower income neighborhoods where traffic fatalities are more common. The vision in Thrive 2050 is for these arterials to become safe, green, multimodal boulevards, and this document will be a critical guide for those changes.
A few constructive comments:
• Page 55: We’d like it to be clear that a sidepath is always preferable to bikeable shoulders.
• Page 57: We recommend that bikeways be listed as a high priority for downtown boulevards, downtown streets, town center boulevards, and town center streets.
• Page 82: Bus shelters, in addition to BRT stations, should consider opportunities to provide additional passenger amenities such as seating, local area information, wayfinding, and real time traveler information.
• Page 88: We urge the county to update its policy for snow events. Especially in downtowns and town centers, the county – not the building owners – should be responsible for clearing snow on sidewalks, sidewalk ramps, and sidewalk-level bicycle facilities.
• Page 232: Public engagement should also include on-the-street direct outreach strategies, as well as strongly encourage paid community focus/advisory groups to ensure diverse input for major decisions.
• Finally, we ask that the design guide be open to amendment upon the completion of the Pedestrian Master Plan and Vision Zero Action Plan.
Implementing the Complete Streets Design Guide is key to achieving the county’s Vision Zero goal, as well as improving connectivity and helping shift mode-share away from single occupancy vehicles. We look forward to the comprehensive update of the Master Plan of Highways and Transitways that is necessitated by the guide, along with its implementation throughout new projects, resurfacing, construction, and maintenance. Wherever possible, we encourage the Planning Board, MCDOT, DPS, and the Council to codify the guide into law and regulation.
Thank you for your consideration.
CSG Testimony Supporting Montgomery County Bill 13-20
July 8, 2020
Montgomery County Council Council Office Building
100 Maryland Ave.
Rockville, MD 20850
Bill 13-20, County Property – Disposition – Affordable Housing (Support)
Public Testimony
Jane Lyons, Maryland Advocacy Manager
President Katz and Councilmembers, thank you for the opportunity to submit written testimony on Bill 13-20. Please accept these comments on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. We strongly support any efforts to make better use of our public land for affordable housing.
Bill 13-20 would require any disposition of property that will be used primarily for housing development must be 30 percent income-restricted, with 15 percent as moderately priced dwelling units (MPDUs) and the other 15 percent for households earning 50 percent of less of the area median income (AMI).
For too long, the county has not used its public land for its full potential. With many county properties located near high-capacity transit and land being a significant cost of construction, subsidized land costs makes deeper levels of affordability possible. At a time when we need 75 percent of new housing in the region to be affordable for low and middle income households, this legislation is common sense.
We would like to see this legislation go a step further. If county land dispositions meet certain requirements, such as being a certain distance from transit, it should be required for that land be used for affordable housing. There is nothing under current law prioritizing or requiring certain uses to be considered, or giving preference to experienced affordable housing developers as partners.
We need to re-imagine how we use public land, when being disposed of and when redeveloping. Libraries, community centers, and other public facilities should all be co-located with housing. Our region already has several examples of housing co-located with public facilities. We hope this legislation will be a first step for better using public land for the public good.
Therefore, we urge you to support Bill 13-20 and seek provisions to make it even stronger. Thank you for your consideration.
RELEASE: CSG and Montgomery Open Streets Coalition Ask SHA for 19 Miles of Shared Streets
July 1, 2020
Mr. Greg Slater
Maryland Secretary of Transportation
7201 Corporate Center Drive
Hanover, MD 21076
Mr. Tim Smith, Administrator
Maryland State Highway Administration
707 North Calvert Street
Baltimore, MD 21202
RE: Shared Streets Treatments on Maryland State Roads in Montgomery County
To: Tim Smith MD SHA Administrator
Dear Secretary Slater and Mr. Smith,
On behalf of the undersigned organizations, we would like to offer a list of State Highways that would benefit greatly from a “Shared Streets” approach as is being used by Montgomery County Department of Transportation. Recently, SHA itself coordinated with MCDOT and Councilmember Tom Hucker’s office in the closing of the right northbound lane on MD-97 in downtown Silver Spring to facilitate outdoor dining.
We are proposing a similar treatment of longer stretches of some State roads to promote greater connectivity for bicyclists and pedestrians and make it safer for those who do not want to drive or do not have access to a car to make trips throughout Montgomery County walking or by bicycle. These could be commuting to work trips, or shorter ones to go buy groceries, visit the doctor, connect with trails or do other errands. It is vital to provide alternatives to cars that are safe, affordable and are useful in getting people between different parts of the County or even within a short radius of where people live.
The list below amounts to almost 19 miles of state roads. We understand that SHA may want to pilot this concept of partial closures to cars and suggest that the stretch on University Boulevard is a good place to start as it would connect the Wheaton CBD with Sligo Creek Parkway and neighborhoods east of the Parkway as well.
We look forward to your response and hope that you can work with MCDOT and members of the Maryland House and Senate and the Montgomery County Council.
Here is the list of roads we propose as candidates for a Shared Streets approach:
- University Blvd/MD-193 from Colesville Road/MD-29 to Viers Mill Road/Md-586 (3.0 mi) (Connects from Four Corners neighborhood to Sligo Creek Parkway and Trail to Wheaton CBD)
- Viers Mill Road/MD-586 from MD-193 to Matthew Henson Trail (works best in pairing with no. 1 above (2.7 mi) (Connects Wheaton CBD to Matthew Henson Trail)
- Frederick Road/MD-355 from Germantown Road/Md-118 to MIddlebrook Road (.8 mi) (Connects Montgomery College/Germantown Campus and Holy Cross Hospital/Germantown)
- Piney Branch Road/MD-320 from Sligo Creek Pkwy to New Hampshire Ave/MD-650 (1.4 mi) (Connects Sligo Creek Parkway and Trail, New Hampshire Elementary School, Flower Ave and Northwest Branch Trails)
- Old Georgetown Road/MD-187 from I-495 to Executive Blvd (2.6 mi) (Connects Bethesda Trolley Trail, Ratner Museum, Wildwood Shopping Center, Josiah Henson Museum and White Flint)
- Georgia Ave/MD-97 from Norbeck Road/MD-28 to OlneySandy Spring Road/MD-108 (3.5 mi) (Connects Leisure World, ICC Trail and Olney CBD)
- Georgia Avenue/MD-97 & 16th Street/MD-390 from I-495 Overpass to Colesville Road (1.5 mi) (Connects Forest Glen Metro and Montgomery Hills Shopping Center)
- East-West Highway/MD-410 from Georgia Ave/MD-97 to Connecticut Ave/MD-185 (3.2 mi) (Connects Silver Spring CBD, Rock Creek Trail, and Chevy Chase)
Paul Goldman, President, Action Committee for Transit
Jane Lyons, Maryland Advocacy Manager, Coalition for Smarter Growth
Alison Gillespie, President, Forest Estates Community Association
Kristy Daphnis, Chair, Pedestrian Bicycle Traffic Safety Advisory Committee
Peter Gray, Vice President, Board of Directors, Washington Area Bicyclist Association
cc: Montgomery County State Delegates and Senators, Montgomery County Council, Director MCDOT
495/270 P3 DEIS Comment Extension Letter
June 30, 2020
Dear Ms. Mar and Ms. Choplin,
We are writing on behalf of the undersigned organizations to request an extension of the public comment period. The proposed I-495 & I-270 Public-Private Partnership (P3) Program (Project) is likely to have significant impacts on water quality, air quality, and managed by the Maryland National Capital Planning Commission, and downstream on Rock Creek Park.
The Maryland Department of Transportation – State Highway Administration (MDOT SHA) and the Federal Highway Administration (Agencies) have indicated they will soon make available for public comment the Draft Environmental Impact Statement (DEIS) for the proposed Project. This DEIS will describe the proposed action’s impacts on the environment as well as the impacts of alternatives and plans to mitigate the impacts. The document also will describe the environmental analysis conducted on the impacts of construction and operation of the new roadway. It is critical that the public have an adequate opportunity to meaningfully review the DEIS and submit comments to ensure that the Agencies’ analysis is complete and fairly considers all the options for the Project.
We believe that allowing sufficient time for a well-considered review and thorough comments on the DEIS will lead to better evaluations, a more efficient process, and solutions that protect environmental resources, including Rock Creek. Due to the evolving situation with COVID-19, it is even more imperative that the public be given sufficient time to submit comments on the DEIS. Over the last few months, several of the undersigned organizations have submitted Freedom of Information Act and Maryland Public Information Act requests to the Agencies, the
timely fulfillment of which would have assisted our reviews of the DEIS. These requests were denied, ignored, or delayed.
The Project is one of the largest of its type ever proposed, expected to cost billions of dollars, and have significant environmental impacts. We expect the DEIS and its dozens of appendices and corresponding data to be thousands of pages. In regular times, for a proposed action such as this, the Agencies should reach an agreement to provide a longer time period and if not, the lead agency should easily find good cause to provide an extended comment period beyond 60 days from publication in the federal register. See 23 U.S.C. § 139(g)(2)(A); 42 U.S.C. § 4370m–4(d). Not doing so would not allow for meaningful public review and comment.
These are not normal times. The emergency COVID-19 pandemic, and corresponding mandatory and voluntary restrictions, necessitate a longer public comment period. Like your agencies and other interested parties, our groups are working remotely while dealing with other responsibilities, generally without the use of office equipment such as printers for large files. Communications within our organizations, with members, and with others in the public that are interested in participating in the process are also delayed. The public’s ability to review and comment on the DEIS is currently hampered and requires more time than normal. Both of your agencies have recognized the difficulties caused by the pandemic. Both agencies have delayed providing electronic records in response to our public records requests (beyond statutory deadlines) based on asserted difficulties caused to the Agencies by the pandemic.1 It would be arbitrary for the Agencies to now deny the pandemic does not present good cause for a longer comment period.
We appreciate the Agencies’ commitment that the public comment period will extend beyond the minimum-required 45 days and that the Agencies desire to allow full participation by the public and interested stakeholders. Forty-five days, or anything close to that, is clearly not sufficient. The undersigned organizations therefore request that the Agencies provide at least 120 days for public comment on the DEIS. This amount of time is necessary with increased uncertainty over the ability to re-open safely in a way that will allow the public to view documents in a timely manner. This time frame is also consistent with other Environmental Impact Statement comment periods such as the Washington Union Station Expansion Project and the Farmington Resource Management Plan.
We look forward to your affirmative response to this request.
Respectfully submitted,
As an example, despite previously agreeing to provide non-exempt responsive records to one of our February 18 requests by April 30, MDOT SHA then requested that we “extend the 10-day period for providing a time and cost estimate, as well as the 30-day period for responding to your request, until 10 days after the date that [Maryland’s] state of emergency is lifted.” MDOT SHA stated: “Complying with the statutory timeframes of your PIA request at this time is not feasible given the state of emergency and recognized health risk that the coronavirus poses to all Marylanders, including State employees responsible for identifying, retrieving, and reviewing documents and responding to your request.” We still have not received any responsive records.
Signed by,
Jeanne Braha, Executive Director, Rock Creek Conservancy Josh Tulkin, Director, Sierra Club, Maryland Chapter
On behalf of the following organizations:
350 Montgomery County
Audubon Naturalist Society – Woodend, Chevy Chase, MD
Baltimore Tree Trust
Beaverdam Creek Watershed Watch Group
Cedar Lane Unitarian Universalist Church Environmental Justice Ministry
Central Maryland Transportation Alliance
Chesapeake Bay Foundation
Chesapeake Physicians for Social Responsibility
Citizens Against Beltway Expansion [CABE]
Cleanwater Linganore Inc
Climate Parents of Prince George’s County
Coalition for Smarter Growth
Conservation Montgomery
DontWiden270.org
DoTheMostGood Montgomery County
Forest Glen Citizens Association
Friends of Sligo Creek
Greenbelt Advocates for Environmental and Social Justice
Greenbelt Climate Action Network
Indian Spring Citizens Association
Indivisible Howard County
League of Women Voters of Maryland
Maryland Campaign for Environmental Human Rights
Maryland Legislative Coalition
National Parks Conservation Association
Neighbors of the Northwest Branch
North Hills of Sligo Creek Civic Association (NHSCCA)
Our Revolution Maryland
Parkwood
Preservation Maryland
Prince George’s County (MD) Peace & Justice Coalition
Rapid Shift
Regents Square Condominium (Rockville)
Rock Creek Conservancy
Rogue Tulips Consulting & Association Management
Sierra Club, Maryland Chapter
Takoma Park Mobilization
The Ocean Foundation
University Park Community Solar LLC
Washington Area Bicyclist Association
Wicomici Environmental Trust, Ltd.
West Montgomery County Citizens Association (WMCCA)
Woodside Forest Civic Association
cc: Linda Strozyk DeVuono, Office of the Attorney General, LDeVuono@mdot.maryland.gov
CSG Comments on the Draft Regional Transit Plan for Central Maryland
Thursday, June 18th, 2020
Maryland Transit Administration & Regional Transit Plan Commission
6 St. Paul St.
Baltimore, MD 21202-1614
Re: Comments from Thirty Organizations on the Draft Regional Transit Plan for Central Maryland
Dear Maryland Transit Administrator Kevin Quinn and the Regional Transit Plan Commission,
Thank you for your leadership in the process to create a Regional Transit Plan that is vital to residents in the region. Public transit will always be a necessary service that keeps health care and other vital systems running both during a global pandemic and in the absence of one. The COVID-19 crisis has further reinforced that we need to make structural changes to our public transit system to address inequities and ensure that everyone has access to the important places in their communities. The Regional Transit Plan can address these deficiencies and can also serve as a critical tool to employ in the economic recovery of the region by both creating jobs and allowing people to get to jobs. Every $1 billion invested in transit supports and creates over 50,000 jobs. While the Draft Regional Transit Plan’s overarching goals are well-chosen, the plan should be improved to significantly address inequities that disproportionately impact people of color, people with disabilities and other marginalized communities and to set a higher bar to improve access, reliability, and protect our environment.
We, undersigned groups encourage you to strengthen this important plan by enacting the following measures:
- Improve access to frequent transit connected to employment centers for marginalized communities and reduce the number of disconnected communities. Everyone deserves to be able to travel to the places where they live, work, and play. Everyday, communities of color have disproportionately less access to critical destinations due to redlining and structural racism. The neighborhoods in Baltimore with the highest percentage of people traveling more than 45 minutes to get to work and also taking transit are predominantly Black communities. The plan should provide strategies and targets to substantially increase access to frequent transit service for communities of color and other marginalized communities to connect to employment centers. The plan should also reduce the census blocks with disconnected communities–communities where there is over 5% unemployment and over 20% of workers are commuting over 45 minutes to get to work.
- Improve the reliability and accessibility of transit for people with disabilities. Our public transit system must work for everyone. People with disabilities are disproportionately impacted by inadequate transit. The plan should significantly increase On Time Performance of Paratrasit and upgrade the percentage of stops and stations that are ADA accessible at a much faster pace than 25% every 10 years. The plan should also include strategies that provide users with better notification systems of vehicle arrival times and provide an analysis of the number of vehicles needed. It is important that the plan include measures to increase the number of wheelchair accessible vehicles and provide special funding for transit services for health care.
- All bus replacements should be for zero emission buses starting in 2024. We need to travel in ways that keep us and our planet healthy. Most of our buses run on diesel fuel that spew out pollution that makes us sick and exacerbates climate disruption. The plan should include a target and strategies that lead to the full transition to a zero-emission transit fleet by requiring that in 2024, all bus replacements be for zero emission buses. Each zero-emission bus reduces pollution as much as taking 27 cars off the road. This goal is achievable, needed to protect public health, and consistent with the goals of comparable jurisdictions. New York City is transitioning 100% of their fleet to electric by 2040.
- Provide faster service to reduce people’s commute times. If people are spending less time traveling each day, they can spend more time with their loved ones. If people can get from point A to B faster on public transit, they will use it more. Currently, people can reach fewer than 1 in 10 jobs in the Greater Baltimore region in less than 45 minutes on transit. While the draft plan recognizes that faster service is important, it does not offer concrete targets. The plan should set targets to substantially reduce peoples’ commute times.
- Provide concrete strategies to pay for the plan. Investing in public transit benefits communities across the region. If we want to see the benefits in the plan, we need to fund them. The plan should develop concrete strategies for identifying federal, state, and local funding and leveraging funding to meet the needs of the plan, with an emphasis on funding strategies in the next 5 years.
- The plan should have consistent short-and long-term goals for improving transit and details of what transit improvements will occur in early priority corridors. The plan should provide 5-year and 25-year targets for each objective: providing faster, more reliable service; growing ridership; increasing access to jobs and opportunities; improving the customer experience; being more equitable; and preparing for the future. MTA should include assessments on how strategies under these objectives will slow the growth of vehicle miles traveled (VMT) in the region and explain how the corresponding decline in greenhouse gas emissions aligns with the Administration’s Greenhouse Gas Reduction Act Plan. The draft plan does not offer consistent metrics; instead it uses different baselines and target years for different indicators. MTA should provide a baseline of current conditions so the public can understand how the conditions are being improved and so that improvements can be reliably monitored and measured. The plan should also outline what transit improvements will occur in early priority corridors identified in the plan and outline the corridors that MTA will study.
Thank you for your consideration of these proposed improvements. Please note the improvements outlined in this letter are by no means exhaustive but outline some of the key measures that should be improved.
Sincerely,
Niamh McQuillan, Co-Lead, 350 Baltimore and Climate Reality Project Baltimore
Klaus Philipsen, FAIA, ArchPlan
Liz Cornish, Executive Director, Bikemore
Nanci Wilkinson, Chair, Environmental Justice Ministry, Cedar Lane Unitarian Universalist Church
Steven Hershkowitz, Maryland Director, Chesapeake Climate Action Network
Gwen L. DuBois MD, MPH President, Chesapeake Physicians for Social Responsibility
Emily Ranson, Maryland Director, Clean Water Action
Jane Lyons, Maryland Advocacy Manager, Coalition for Smarter Growth
Floyd Hartley, Chair, CARS (Consumers for Accessible Ride Services)
Donald M. Goldberg, Executive Director, Climate Law & Policy Project
Eric Norton, Director of Policy & Programs, Central Maryland Transportation Alliance
Robin Murphy, Executive Director, Disability Rights Maryland
Lore Rosenthal, Program Coordinator, Greenbelt Climate Action Network
Liz Feighner, Hoco Climate Action
Richard Deutschmann, Climate Action Team Lead, IndivisibleHoCoMD
Joe Uehlein, President, Labor Network For Sustainability
Richard Willson & Lois Hybl, Co-presidents, League of Women Voters of Maryland
Henry Bogdan, Policy Director, Maryland Nonprofits
Rachel London, Esq., Executive Director, Maryland Developmental Disabilities Council
Kim Coble, Executive Director, Maryland League of Conservation Voters
Cecilia Plante, Co-Chair, Maryland Legislative Coalition
Josh Tulkin, Director, Maryland Sierra Club
Ronza Othman, President, National Federation of the Blind of Maryland
Timothy Judson, Executive Director, Nuclear Information and Resource Service
Cheryl Barnds, Rapid Shift
Mark Southerland, Ph.D.Legislative Director, Safe Skies Maryland
Diana Younts, Takoma Park Mobilization Environment Committee
Tafadzwa (Taffy) Gwitira, Founder and farmer, Tele Farm
Jimmy Rouse, Co-Founder, Transit Choices
W. Phil Webster, Unitarian Universalist Legislative Ministry of Maryland