November 27, 2024

Montgomery County Planning Board
2425 Reedie Dr, 14th Floor
Wheaton, MD 20902

Re: Item 7 — Master Plan of Highways and Transitways (MPOHT)  – 2024 Technical Update 

Dear Chair Harris and members of the Planning Board:

Please accept these comments on behalf of the Coalition for Smarter Growth (CSG). CSG is the leading organization in the D.C. metro region advocating for walkable, inclusive, transit-oriented communities as the most sustainable and equitable way for our region to grow and provide opportunities for all.

We thank the Planning Board and Planning staff for taking note of the volume of public feedback on M-83, and scheduling additional hearings to consider M-83’s removal from the Master Plan of Highways and Transitways.

M-83 is not the right way forward to provide better transportation options Upcounty. It is an outdated plan from a different era of planning and engineering, and it is fundamentally out of step not only with what we know today about the vital connections between environmental and human health—but also with what we know today about best practices to address transportation needs. Fortunately, the county is well on its way to implementing a much more effective mix of bus rapid transit and local street safety improvements that, per the County’s 2017 supplemental report, will reduce vehicle miles traveled, increase transit ridership, and reduce rush hour delays on I-270.

M83 is based on obsolete travel and land use assumptions

SHA traffic data shows that traffic volumes on most of the major north-south roads in the MD 83 corridor have declined and did so even before the pandemic. SHA had forecast 34-48% growth in traffic volumes on MD 355 by 2030, but traffic volumes on 355 peaked in 2014 and 2017. Other roads — MD 27, MD 124, MD 108, Clarksburg Rd/Stumptown Rd, Snowden Farm Parkway — haven’t seen increases in traffic volumes according to SHA data. Since the pandemic the vast increase in telecommuting and the huge vacancies in office park buildings is likely contributing to further declines in peak hour driving. 

M83 would generate higher volumes of traffic in the Upcounty – while failing to provide alternatives

Two things can be true at the same time – declining driving demand today because of telecommuting and possibly online shopping, but also induced driving generated by the presence of a new highway. What we now know from study after study—including examples in our own region—is that the temporary relief from traffic seemingly offered by new road capacity is eaten up within years as more people decide to take more car trips because it has become more convenient to drive. Expanded highways also drive development to more auto-dependent areas, further increasing traffic volumes.

This is a phenomenon called induced demand, and it eventually leads you right back to the traffic problem you started with—but with even more driving overall. See CSG’s summary of the research here. We saw after the state of Maryland spent $200 million to expand I-270 from 8 to 12 lanes, traffic gridlock returned in just 8 years (featured in a 1999 Washington Post article and confirmed by a Transportation Planning Board analysis).

M83 would cause significant environmental damage – to the watershed, stream valleys, and the climate

M-83 would not result in long-term, sustainable improvements to travel times and traffic congestion. It is, however, highly likely that building M-83 would result in increased carbon emissions from increased vehicle miles traveled, as the county’s own modeling predicts. And it is a certainty that M-83 would cause damage to the sensitive ecosystems it cuts through, including watersheds that feed into our regional drinking water supply.

As with the now well-documented phenomenon of induced demand, the connections between human and environmental health were perhaps not fully appreciated by decisionmakers at the time M-83 was originally planned. Now, we know better, and we need to act accordingly.

Our region is just exiting its longest-ever recorded period with no precipitation. We cannot take the health of the ecosystems that feed into our drinking water supply for granted. Likewise, we now know that the many byproducts of traveling by car, from auto emissions to microplastic particles produced by our tires, do not have a neutral impact on our health or on our environment. Rather, they cause negative health impacts like increased rates of asthma for those living near roadways, and contribute to the already-disastrous and mounting effects of climate change.

MD-355 Bus Rapid Transit is a better alternative for more Upcounty transportation options – and already underway

There is a path forward to relieving transportation challenges in the Upcounty without generating long-term negative environmental and health effects. The solution to Upcounty transportation challenges lies in high-quality, high-capacity new transit connections, safer and more comfortable options to get around by walking and biking, and targeted intersection and street grid improvements to improve accessibility. These solutions provide a sustainable long-term framework for relieving traffic by offering more and better choices for how people get around.

Planning Board progress on these transportation alternatives is well underway. Bus rapid transit, or BRT, on MD-355 will provide a high-capacity, high-frequency bus line with service between Bethesda and Clarksburg. The County Department of Transportation is planning to begin construction on the central segment of MD-355 bus rapid transit next year—the first of three segments—and is seeking to contract a progressive design-build firm not just for this segment but to eventually build all segments of MD-355 BRT. This reflects our county’s commitment to reduce delays and quickly and efficiently deliver long-promised BRT on this corridor.

The County’s own 2017 supplemental report on M-83 found that when it excluded the proposed M-83 highway from its analysis, and focused instead on bus rapid transit on Route 355, along with improvements to existing intersections and roads, BRT-based scenarios excelled in reducing driving, producing the lowest number of vehicle miles traveled in private vehicles, highest percentage of people traveling by transit and shortest rush hour travel times on Route 355, among other key metrics.

CSG has been and will continue to be a strong advocate not only for this BRT project, but more broadly for better bus service, transit-oriented development, safe streets for all users, and in particular, safer and more comfortable options for walking and biking Upcounty.

We urge the Planning Board to move decisively forward in this direction, and no longer keep alive in our county’s plans an unbuilt and environmentally damaging highway proposal that distracts from better transportation options already underway. The time is now to remove M-83 from our county’s Master Plan of Highways and Transitways.

Thank you for your time.

Sincerely,

Carrie Kisicki
Montgomery County Advocacy Manager

Photo: TAME