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.
For Immediate Release:
April 9, 2021
Stewart Schwartz, CSG, 703-599-6437, email@example.com
Eliza Cava, ANS, 202-503-9141, firstname.lastname@example.org
Kyle Hart, NPCA, 202-400-1193, email@example.com
Josh Tulkin, Sierra Club Maryland Chapter, firstname.lastname@example.org, 650-722-3171 Douglas Stewart, Sierra Club Virginia Chapter, 703-407-2790, email@example.com
Environmental Advocates Release “Best Smart Growth Plan” for American Legion Bridge and Capital Beltway
Sustainable, Equitable, and Effective
Today, in advance of pending decisions in Virginia and Maryland, leading environmental organizations released a “Best Smart Growth Plan” for the American Legion Bridge and Capital Beltway. The document reviews the current situation and summarizes the consensus recommendations of the groups.
Citing the rush by Governor Hogan and Governor Northam to a pre-ordained conclusion to widen the bridge and the Beltway, including Hogan’s push for a premature development contract with TransUrban and his YouTube video trumpeting the Maryland toll lanes, the groups are calling for an immediate pause in the projects and offering a comprehensive land use, transit and demand management solution that will be more sustainable, equitable, and effective.
“Governor Hogan has not kept faith with his public promises to complete a solid environmental study of impacts and alternatives before moving forward with private toll lanes,” said Eliza Cava, Director of Conservation, Audubon Naturalist Society. “He has instead pressed forward with a proposal that ranks as highway robbery — not just high tolls, but the theft of national and local parks, historic sites, community peace, wildlife, and a sustainable planet.”
Meanwhile, the powerful TransUrban corporation, a major donor to politicians on both sides of the river, has been sending out expensive mailers to thousands of Northern Virginia households as part of their lobbying push for the lucrative private toll lanes deal.
The Fairfax County Board will be meeting on April 13 to discuss their position on 495Next and the Virginia Commonwealth Transportation Board will act on the proposal at their April 21 meeting. The Maryland Board of Public Works is scheduled to meet in May to approve the pre-development contract for 495/270, even though the environmental studies are not yet complete.
“We are calling for a pause on the interconnected Maryland and Virginia toll lane projects, and are setting forth a sustainable, equitable and effective alternative that should be studied and ultimately adopted,” said Douglas Stewart, Transportation and Smart Growth Co-Chair of the Sierra Club Virginia Chapter. “This project should not move forward without plans for high capacity transit and robust, dedicated transit funding from both Maryland and Virginia, in order to reduce congestion and help jurisdictions meet their goals to reduce greenhouse gas emissions.”
“We decry the conclusions-first approach of Virginia and Maryland and the way the state’s Public-Private Transportation Acts undermine fair and objective alternatives analysis,” said Stewart Schwartz, Executive Director of the Coalition for Smarter Growth. “Our groups offer here, and have offered before, a comprehensive, integrated land use (transit-oriented development), transit, and demand management alternative, but both states have refused to consider such an alternative.”
“The DMV needs more green space, not less. Governor Hogan’s proposed toll lanes could bulldoze valuable national parkland and damage delicate ecosystems just to make room for more fumes, noise, and cars. This proposal threatens local communities of color and a historic African-American church cemetery. This is not a solution to traffic congestion in the area; it’s another problem,” said Kyle Hart, National Parks Conservation Association.
“We have the time and must take the time to build the best bridge for people and wildlife. This is a decision that will affect our environment and climate for the next hundred years.” said Cava.
“Our plan would improve transportation and reduce traffic, while directly addressing the racial and socio-economic inequity that continues to mark our region. Investing in transit-oriented development, particularly in the underinvested east side of the region would reduce long commutes for residents and also create jobs and generate revenue for schools and fund other community benefits, unlike Gov. Hogan’s toll lane proposal,” said Josh Tulkin, Director, Sierra Club Maryland Chapter.
“WMATA’s Connect Greater Washington study showed that building out transit-oriented development would reduce driving and traffic on the Beltway, while increasing transit ridership and converting WMATA’s rail operating subsidy to a surplus.” said Schwartz. “We are calling on all of our elected officials to support a pause, and analysis and adoption of our more sustainable, equitable and effective alternative,” concluded Schwartz.
The “Best Smart Growth Plan” can be found here.
Best Smart Growth Plan for the American Legion Bridge and Capital Beltway
This is a 100-Year Decision – Let’s Take Time to Create the Most Sustainable, Equitable, and Effective Solution
As our metro area continues to grow, we must address the transportation issues at the American Legion Bridge and the Capital Beltway. Contrary to road booster’s hopes, however, an upper Potomac Bridge is not the answer, as demonstrated by previous studies. Further, while Maryland and Virginia are right to be focused on improving the American Legion Bridge and the Capital Beltway corridor, they have been rushing to implement a pre-ordained conclusion as to the best approach,and the resulting proposal–adding four toll lanes with massive connecting (double) interchange ramps and doubling the size of the American Legion Bridge — will harm adjacent communities and the environment. The two states have so far refused to study a comprehensive, integrated land use (transit-oriented development), transit, and demand management alternative, and they have failed to develop a sustainable, equitable, and effective solution.
As leading conservation organizations, we have come together to bring clarity to the issues at stake, and to make the case once again for a more sustainable, equitable, and effective approach. This is a multi-billion dollar, 100-year + decision, and we face a climate emergency, so officials must take a second look.
Why an upriver Potomac River bridge crossing is not the answer:
- The VDOT 2015 Potomac River Crossings Study showed that less than 4% of trips that currently use the American Legion Bridge might benefit from a potential upriver bridge.
- The 2003-2004 VDOT/TPB origin-destination study showed similar results.
- A 2001 proposal for an upriver bridge prompted outcry on both sides of the river because of impact on neighborhoods, environmental and historic resources, prompting cancellation of the study.
Why the American Legion Bridge crossing should be addressed:
- The VDOT 2015 Potomac River Crossing Study showed that the American Legion Bridge is the most important crossing in need of investment outside of the Rosslyn Metro tunnel crossing into DC.
- Reportedly due to age, the American Legion Bridge needs significant rehabilitation or replacement by 15 years from now.
Why there should be analysis of a comprehensive, sustainable and equitable land use, transit, and demand management alternative to the public-private toll lane proposal:
- There is time to conduct a thoughtful analysis of alternatives since MDOT has confirmed that we have 15 years before the bridge structure needs replacement.
- Virginia and Maryland have used a conclusions-first focus on high-occupancy (HOT) toll lanes via public-private partnerships, without full alternatives analysis or completion of all environmental studies. In Maryland, a series of very limited, isolated transit alternatives were assessed, but not a comprehensive, integrated land use (transit-oriented development), transit, demand management alternative.
- There are environmental and historic resources that must be considered at the American Legion Bridge crossing including the Potomac River, and National Park sites at Plummer’s Island research center, the C&O Canal, Potomac Heritage Trail, and GW Memorial Parkway.
- With just 10 years to dramatically reduce the emissions that cause climate change, highway expansion is exactly the wrong way to go, as studies show that metropolitan regions must significantly reduce vehicle miles traveled in addition to achieving a dramatic increase in electric vehicle use by 2030.
- The significant increase in telecommuting expected post-pandemic by those who work in offices will lead to a significant drop in peak hour demand for road space.
- A strategy of buildout of transit-oriented development at our Metro, Purple Line and Bus Rapid Transit corridors, especially on the east side of the region, would be more equitable and would reduce vehicle miles traveled and greenhouse gas emissions compared to high-priced private high-occupancy toll lanes.
- The increase in flooding and stormwater runoff from highway expansion — adding more pavement, even treated to current standards, will degrade the water quality in the Chesapeake Bay watershed, preventing the region from meeting its water pollution reductions by 2025, as required by the Chesapeake Bay Total Maximum Daily Load.
Summary of our Alternative for the American Legion Bridge and Capital Beltway:
- We support appropriate investment at the American Legion Bridge crossing.
- We oppose any efforts to revive proposals for an upriver bridge.
- We urge all efforts to reduce vehicle miles traveled and single-occupant vehicle trips in order to reduce greenhouse gas emissions from surface transportation by at least 45% below 2005 levels by 2030, and 100% by 2050.
- We urge an immediate pause in pursuit of the 495Next HOV extension and American Legion Bridge/495/270 toll lane proposals and P3 contracting until evaluation of a comprehensive land use/transit/demand management alternative, and we urge adoption of a less destructive and more sustainable and equitable solution.
- We request evaluation and adoption of a land use, transit, and demand management alternative to include:
- Buildout of transit-oriented development at Metro stations, Purple Line stations, and BRT corridors. The WMATA Connect Greater Washington Study shows that TOD buildout – particularly in Prince George’s – would help correct the east-west jobs/housing imbalance, increasing transit trips, reducing vehicle miles traveled, and reducing demand on the Beltway in both Maryland and Virginia.
- Prioritization of a dedicated “Purple Line” transit connection across the river including Metrorail or light rail connecting between the Silver Line and Red Line and Maryland Purple Line, along with dedicated bus-only or bus-HOV3 lanes.
- Demand management tools: parking pricing, employer transit benefits and parking cashout, telecommuting, and (potentially) pricing existing lanes rather than expansion with priced lanes.
- Inclusion of well-designed bicycle and pedestrian connections to and across a rehabilitated or new American Legion Bridge.
- We seek clear environmental justice considerations to be brought into the highway expansion planning.
- Should officials proceed with the HOT proposal for the American Legion Bridge and connections at each end, AFTER full and objective consideration of our comprehensive alternative, then the project must:
- Include bike/pedestrian connections.
- Provide significant funding for transit operating and capital needs to ensure frequent, high-capacity transit.
- Incorporate a bridge design that supports Metrorail.
- Incorporate a bridge design that minimizes impacts to the sensitive natural and historic assets in the Potomac Gorge including water quality, forests, native species, National Park sites like Plummer’s Island, and historic assets. In contrast to the significant widening required by four HOT lanes (as much as 80 feet or more), other alternatives such as pricing existing lanes, converting existing lanes to bus-only or bus/HOV3-only lanes, and vertically separated rail could result in less impact.
- Furthermore, while we do not recommend private tolled HOT lanes, if new lanes are added, they should be added to the upriver side of the bridge so as not to require use of Plummers Island for the construction, and additional mitigation measures should also be taken to protect this historically important site of ongoing, long-term research.
November 9, 2020
FOR IMMEDIATE RELEASE
Monday, November 9, 2020
Lindsey Mendelson, Maryland Sierra Club, firstname.lastname@example.org, 240-706-7901
MARYLAND — Today, fifty groups came together to deliver one simple message: Governor Hogan’s plan to widen the I-495 and I-270 toll lanes is flawed, incomplete, legally vulnerable, and would fail to reduce congestion for the vast majority of drivers.
On behalf of the diverse coalition of groups, the Maryland Sierra Club and Rock Creek Conservancy released over 200 pages of technical and legal comments today, the final day of the 120-day public comment period for the project’s Draft Environmental Impact Statement (DEIS). According to the groups, “the state’s Draft Environmental Impact Statement violates the National Environmental Policy Act (NEPA), as well as other federal laws, and is a disservice to the public because it presents incomplete and inadequate analyses.”
The coalition comments are the result of work by Jill Grant & Associates, dozens of community experts, and three contracted consultants. They present a sophisticated legal analysis demonstrating a project that is not in the public interest, with countless unanswered questions, and would be extremely harmful for the environment and public health.
The comments include a new study by renowned traffic modeler Norm Marshall that shows expanding I-495 and I-270 will shift traffic into the peak hours and create or exacerbate bottlenecks at the ends of the toll lanes and on connecting roads. There would be no congestion improvements for the majority of drivers and no benefits for non-users of the toll lanes.
Meanwhile, the DEIS presents an incomplete and unclear estimate of capital costs and revenues and ignores significant financial costs the project would impose on Maryland communities. These costs include a direct subsidy to a private developer, costs of relocation of utilities, decreases in property values, and public-private partnership (P3) financial risks.
The comments describe the DEIS’s failure to adequately assess impacts to parkland, air and water quality, adjacent and environmental justice communities, and historic and cultural resources. The report also describes how the Maryland Department of Transportation refused to provide key information to the public–denying, delaying or charging the Sierra Club and other groups $300,000 for public information requests that would have shed more light on this project.
“Our analysis shows that Governor Hogan’s highway boondoggle will not solve congestion; instead, it will be a disaster for our climate and health and cause further harm to communities already impacted by environmental injustices. We must invest in equitable solutions that actually increase mobility and connectivity across the region. We are grateful for the groundswell of partner and community support in this major effort and thank everyone who has voiced their concerns about this flawed and harmful project.” –Josh Tulkin, Director, Maryland Sierra Club
“Rock Creek is a primary driver of quality of life in our region – for people and for our ecosystems. The state’s study offers few details for a plan to permanently remove land from the Rock Creek stream valley parks and make up for impacts to water quality with changes many miles away. Their plan strips local residents of quality of life benefits in favor of short-lived travel time benefits for drivers and at a great cost to the taxpayers of Maryland and to downstream communities. The P3 calls for innovative techniques, yet the state’s proposal represents a complete failure of imagination.” –Jeanne Braha, Executive Director, Rock Creek Conservancy
“The draft environmental impact statement does not consider any real alternatives to highway expansion and consistently fails to take a hard look at the environmental and health impacts of the project, as required by the National Environmental Policy Act. Because of the extensive failings of the statement, along with the many harms to air quality, water quality, parklands, and historical and cultural resources that the expansion would cause, the Maryland Department of Transportation and the Federal Highway Administration should not move forward with the project.” –Ian Fisher, Jill Grant & Associates
“The proposed expansion of the I-495 Beltway and I-270 is the wrong path for Maryland’s transportation networks – instead of decreasing congestion, it would only increase traffic and pollution and damage our neighborhoods and our environment. It’s time for our state to work with local communities on developing stronger solutions to our transportation challenges that are more sustainable for our environment and work better for our residents.” –Patrick L. Wojahn, Mayor, City of College Park, Maryland
“This study represents a failure to protect people and the environment. It fails to show how wildlife and wild places will be hurt by water pollution, air pollution, and forest loss. It fails to account for climate change by considering an alternative that relies on public transit rather than more pavement and more cars. It fails to account for the people who will be harmed by more air pollution. Maryland is better than this. There are cheaper, longer-lasting, more equitable and sustainable solutions to traffic than adding more luxury lanes.” –Eliza Cava, Director of Conservation, Audubon Naturalist Society
“MDOT started with the conclusion: private toll lanes. But we know that the best path to lessen congestion and create a greener world is a comprehensive transit, land use, demand management solution. More highway lanes and more driving is the absolute wrong way to go during the climate crisis.” –Stewart Schwartz, Executive Director, Coalition for Smarter Growth
“The proposed Capital Beltway-widening project would adversely affect the National Register-eligible site of Morningstar Moses Cemetery/Hall in the historic African American community of Gibson Grove in Cabin John, MD. This site, consisting of a sensitive, extant burial ground containing an estimated 80 bodies and the foundation of the county’s only remaining Moses Hall, already suffered from racial injustice and adverse environmental impacts in the 1960s when the highway’s initial construction concretely separated it from Gibson Grove AME Zion Church, the community’s other lynchpin. The Friends of Moses Hall OPPOSES any planned highway construction that would further desecrate and damage the Morningstar Moses Cemetery/Hall, an important cultural and historic African American resource.” –Diane Baxter, Community Descendant, Friends of Moses Hall
“The Purple Line P3 is in disarray because, despite all of MDOT’s study and preparation, the private partner abandoned the project. The tollway DEIS fails to provide the detail or assurance that the $11 billion Beltway P3 proposal won’t collapse like the Purple Line, won’t cost taxpayers billions of un-budgeted dollars, and won’t force commuters to choose between bad-as-ever traffic and unaffordable $50 tolls.” –Brad German, Co-Chair, Citizens Against Beltway Expansion
“Every year, more than 20 million people visit the C&O Canal, Greenbelt, Rock Creek and four more national parks in the Capital region. If the Maryland Department of Transportation adopts this ill-advised plan, the air and water in these parks will be dirtier, and park visitors will lose access to valuable green space within park borders. MDOT must reject this proposal and embrace proven transit-friendly alternatives that address traffic congestion while protecting our national parks.” –Pam Goddard, Senior Program Director, Mid-Atlantic Region, National Parks Conservation Association
“North Hills of Sligo Creek Civic Association opposes efforts to move forward with the P3 project during the COVID-19 pandemic and believes that the cost of this project to our community and environment has not been thoroughly accounted for. We are also concerned that the DEIS fails to provide for any other transportation alternatives or options to take cars off the road. The negative environmental, economic and social impacts of expanding these highways will be borne by the adjacent neighborhoods.” –Eric Cathcart, President, North Hills of Sligo Creek Civic Association
Prior to the new information presented in these comments, recent headlines have broken news of the high tolls, the 21 utilities that would need to be involved, fundamentally flawed traffic modeling, and rebukes by the bi-county parks and planning commission and Montgomery County Council and Executive.
Last Friday, the Maryland Department of Transportation released an 18,000 page draft environmental impact statement (DEIS) on Governor Hogan’s plans to expand the Capital Beltway (I-495) and I-270 with private toll lanes. The study details the impacts on air, water, parks, noise levels, traffic, and more. The DEIS is available to read here.
More than 140 acres of public parks and historic sites, as well as 70 acres of wetlands and 1,400 acres of forest canopy, could be affected. We’ve said from the beginning that Governor Hogan began with the conclusion, and failed to consider a comprehensive transit, demand management, and land use option. Maryland has committed to reducing greenhouse gas emissions, yet toll lanes will fuel more long-distance living and commuting.
It’s overwhelming, but there’s still plenty that you can do to help. Here are three easy ways:
3. Sign up to be a community reviewer — no experience required!
At first, Governor Hogan claimed the project wouldn’t cost taxpayers a dime due to the public-private partnership (P3) structure. Now, the DEIS finally admits that the project could require a government subsidy up to $1 billion. Imagine if Maryland invested $1 billion in sustainable transit and transit-oriented development instead. That cost doesn’t even include the costs imposed directly on residents: water bills could nearly triple in Montgomery and Prince George’s Counties due to water and sewer relocation.
We’ll continue to keep you updated and work on this issue with our partners, including the Maryland Advocates for Sustainable Transportation (MAST) coalition. You can visit MAST’s website and follow us on Twitter and Facebook for the latest news.
July 10, 2020
FOR IMMEDIATE RELEASE
Friday, July 10th, 2020
Lindsey Mendelson, Maryland Sierra Club
email@example.com | (240) 706-7901
Jeanne Braha, Rock Creek Conservancy
firstname.lastname@example.org | (301)-312-1471
Advocates Alarmed at 18,000 Page Environmental Impact Statement on Gov. Hogan’s I-495 and I-270 Widening Plan
MARYLAND- Today, the Maryland Department of Transportation State Highway Administration (MDOT SHA) and the Federal Highway Administration (FHWA) released an 18,000 page Draft Environmental Impact Statement (DEIS) on Gov. Hogan’s plans to expand I-495 and I-270 with two private toll lanes in each direction. The DEIS outlines the impacts of the plan on the region’s air, water, parks, noise levels, traffic and other categories.
Residents and community organizations have just started to sift through the 90 pound document to assess the damage that the over $11 billion project could cause to Maryland’s environment, health, and economy, especially in the midst of a global pandemic and economic downturn. Advocates are concerned that the DEIS, despite its size, does not adequately examine key alternatives to the widening such as public transit and better land use planning nor effectively examine telecommuting’s role in reducing congestion.
In the last two weeks, over 40 organizations and U.S. Senators Ben Cardin and Chris Van Hollen and Congressmen Anthony Brown and Jamie Raskin asked for the comment period to be at least 120 days to accommodate the public’s ability to comment during the pandemic and complete the approximately 600 hours it would take to read through the document completely. Despite this request, the public comment period remains at 90 days, which would not be enough time for a person reading 40 hours a week to get through all the pages of the document.
“The Draft Environmental Impact Statement weighs 90 pounds. That alone indicates that this project warrants intense scrutiny. We are concerned that this massive highway project will exacerbate harm to our health and environment. The Sierra Club and other organizations have been denied, delayed or charged $300,000 for public information requests that would have shed more light on this project. We need more time to comment on this controversial proposal.” –Josh Tulkin, Director, Maryland Sierra Club
“Experience shows that highway expansions increase, not decrease, driving demand. By fueling more long-distance living and commuting, toll lanes are a massive, generational alteration of our landscape and come at high cost to homes and neighborhoods, people and health, and the natural environment.” – Jane Lyons, Maryland Advocacy Manager of the Coalition for Smarter Growth
“The $11 billion I-495/I-270 expansion is too big and will affect too many lives over the next 50 years for Marylanders to accept an 18,000 page draft environmental impact statement that offers vague assurances that pollution and flood risk won’t increase and parks and communities will be protected. We urge MDOT to give the public the time it needs to review this draft statement and to release the secret traffic and revenue studies being used to justify this massive, high-risk project. Maryland cannot afford a repeat of the crisis plaguing the Purple Line, the Hogan administration’s first public-private partnership. –Brad German, Co-Chair, Citizens Against Beltway Expansion
“This proposed expansion threatens our national parks, including Greenbelt Park, C&O Canal, George Washington Memorial Parkway, Suitland Parkway, and Baltimore-Washington Parkway, without solving the region’s transportation needs. Should this proposal move forward, over 300 acres of local parkland – including valuable green space in an increasingly urban area — could be paved over. Instead of pursuing this new and costly highway expansion, the National Parks Conservation Association urges the Maryland Department of Transportation to examine the many alternatives available that will address our transit needs without sacrificing our parks.”-Pamela Goddard, Mid-Atlantic Senior Program Director, National Parks Conservation Association
Rock Creek is just one of the many special places that will be impacted by the proposed $11 billion expansion of I-495 and I-270. These impacts will extend far downstream, including into the creek through the nation’s first urban national park, Rock Creek Park. The public deserves a full range of alternatives for these sensitive waterways, habitat corridors, and public lands and time to fully consider them.-Jeanne Braha, Executive Director, Rock Creek Conservancy
“How precious is breathing? How important is it to preserve natural spaces and protect the health of residents of this region? We at the Audubon Naturalist Society want MDOT and the SHA to tell us, because the delivery of this 90-pound EIS for an $11 billion project with only 90 days to review it suggests that our health and well-being are not a top priority. Taxpayers deserve better.” –Denisse Guitarra, Maryland Conservation Advocate, Audubon Naturalist Society
“MDOT gave assurances that the public would have an opportunity in the DEIS process to actively participate in the consequential decisions related to the I-495 & I-270 project. However, in releasing an 18,000-page DEIS in the middle of a health and fiscal emergency, and then failing to provide adequate time for document review, MDOT shows disregard for public input. No one knows what post-pandemic commerce, employment, and traffic patterns will look like — the entire effort should be paused until the pandemic subsides.”-Linda Rosendorf, Don’t Widen 270.
Had the Governor and the Maryland Department of Transportation followed a process that allowed for sufficient constituent input and alternative proposals before announcing this massive, destructive plan, the citizens of Maryland would not be in the position of pointing out the obvious. The plan is deeply flawed and may very well cause more harm than good.- Cecilia Plante, Maryland Legislative Coalition.
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.
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.
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
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
Prince George’s County (MD) Peace & Justice Coalition
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