Submitted via email to oplanesMLS@mdot.maryland.gov
November 30, 2021
Jeffrey T. Folden, P.E., DBIA
Direction, I-495 & I-270 P3 Office
Maryland Department of Transportation
State Highway Administration
707 North Calvert Street
Mail Stop P-601, Baltimore, MD 21202
Re: Coalition for Smarter Growth’s Comments on the I-495 and I-270 Managed Lanes Study Supplemental Draft Environmental Impact Statement an Updated Draft Section 4(f) Evaluation
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.
The SDEIS and Section 4(f) evaluation are insufficient and do not fully consider the impacts of the proposed expansion, a massive alternation to our landscape that comes at an extremely high cost to neighborhoods, community health, the natural environment, and taxpayers. At the same time, there was no meaningful consideration of viable alternatives to constructing new toll lanes. Therefore, we request that the U.S. Department of Transportation Federal Highway Administration and the Maryland Department of Transportation State Highway Administration (together, henceforth referred to as “the Agencies”) stop and restart this process to fully address all gaps in the current SDEIS and fulfill the requirements of the National Environmental Policy Act (NEPA) and Section 4(f).
The main points of our comments that we submitted November 2020 regarding the original Draft Environmental Impact Statement still stand and were not adequately addressed by the SDEIS: the purpose and need is narrow, biased, and does not screen alternatives accurately; the traffic modeling assumptions are deeply flawed; transit, land use, and comprehensive alternative solutions were not taken into consideration; environmental and community impacts are significant and the analysis is inadequate; taxpayer dollars will be used ineffectually and irresponsibly; and the equity analyses are incomplete.
Failure to achieve purpose and need: The purpose and need is inappropriately narrow and crafted to favor the selection of a pre-determine private high-occupancy toll option. Even so, the traffic modeling information included in the SDEIS confirms that the Project will not achieve its stated purpose and need, and the proposed segmentation will only create new bottlenecks that do not lead to an overall reduction in traffic congestion. In fact, Table 3-8 shows negligible improvement for 2045 travel times in the general-purpose lanes, and worse travel times for the I-495 Outer Loop from I-270 to I-95, the I-495 Inner Loop from Virginia 193 to I-270, and the I-495 Inner Loop from I-95 to MD-5.
Further data in the SDEIS states that drivers traveling south down I-270 in general purpose lanes would only save 2 minutes and 36 seconds during morning rush hour, and that the evening return trip north would increase by 10 minutes and 6 seconds. If the Project will not bring significant improvement to the general-purpose lanes, then the benefits of the Project will only be enjoyed by those who can afford the cost of daily tolls.
Traffic modeling flaws: The traffic modeling is deeply flawed as discussed in the Sierra Club comments which include the analysis of transportation modeler Norm Marshall, of Smart Mobility, Inc. Beyond his analysis it is also the case that the project fails to adequately assess the benefits accrued from both increased telework due to the ongoing COVID-19 pandemic, including the federal government’s new policy to support long-term telework options, and the $132 million I-270 Innovative Congestion Management project.
Failure to analyze a comprehensive land use, transit, demand management and equity-oriented alternative: The study isolated transit alternatives in such a way that they were designed to fail. Transit works when fully integrated with a land use solution. Therefore, we repeatedly pressed for a comprehensive transit, land use, and system/demand management solution. At the core of this solution is building out transit-oriented centers on the east side of the DC region – particularly in Prince George’s County. This majority Black community has 15 underdeveloped Metro stations and its residents have some of the longest average commutes in the nation due to lack of jobs on the east side of the region. Maryland’s investment in transit-oriented development in Prince George’s would bring jobs closer to residents, reducing demand on the Beltway and balancing out the east-west flows on the north side of the Beltway.
In contrast, the tolling approach to the Beltway will mean a large percentage of Black residents will have the choice of paying very high tolls for long commutes or sitting in the continued general-purpose lane traffic upon which the private toll operator depends to generate their profits from the toll lanes. In addition, segmenting the project may even add to the inequity because it places all of the transportation investment on the wealthy, western side of the Maryland suburbs. Previous expansion of I-270 in the late 1980s was confirmed in a 1999 Washington Post story and subsequent study by the Metropolitan Washington Council of Government’s Transportation Planning Board to have shifted jobs and investment away from D.C. and Prince George’s County to the wealthier, whiter western Montgomery County.
Failure to study this comprehensive and more equitable transit-oriented development alternative is a fatal flaw in the SDEIS.
Shared-use path: We echo the concerns of the Washington Area Bicyclists Association about the exclusion of Option 1, for a shared-use path connection along the American Legion Bridge, which would connect to both MacArthur Boulevard and the C&O Canal Towpath, in the SDEIS. We believe there are feasible solutions to the National Park Service’s concerns about
maintenance costs and environmental damage during construction, and we oppose the rejection of this option on grounds that it will increase use. The intention of a shared-use path connection is to encourage active, low-carbon commuting and recreation, and eliminating an option that would further those goals the best is antithetical to public goals. Without a direct connection to
the C&O Canal Towpath, the next nearest access point would be two miles away.
Conclusion: Even with the inadequate analysis provided, the Project cannot be justified due to its associated environmental, community, and public health impacts. The Agencies should select the No Build alternative and then restart the process with the full proper analyses, including a comprehensive land use, transit, and system/demand management solution that will increase accessibility, reduce travel times, VMT, reduce environmental impacts, and offer a more equitable and sustainable transportation solution.