Tag: 495/270

CSG Comments to VDOT/VDRPT on 495 Southside Express Lanes NEPA Study

The Coalition for Smarter Growth appreciates the efforts of the Virginia Department of Transportation
(VDOT) and the Virginia Department of Rail and Public Transportation (VDRPT) to improve mobility
within the I-495 corridor between Springfield and Maryland. However, to truly address the needs of the
study area communities on either side of the Woodrow Wilson bridge and the metropolitan region,
VDOT will need to take a broader and more holistic approach consistent with the National
Environmental Policy Act (NEPA).

Letter re: 495/270 Toll Lanes in Montgomery County Economic Development Strategic Plan

Montgomery County Council
100 Maryland Ave. 6th Floor
Rockville, MD 20850
March 17, 2022

Dear Councilmember:

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. 

Sincerely,

350 Montgomery County
Audubon Naturalist Society
Baltimore Transit Equity Coalition
Bike Maryland
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
Corazón Latino
DoTheMostGood
DontWiden270.org
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

Comments on the I-495 and I-270 Managed Lanes Study Supplemental Draft Environmental Impact Statement

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.

Take Action: Will Maryland’s Board of Public Works vote to expand highways during a climate crisis?

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:

  1. 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.
  2. 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.
  3. Testify or submit written comments as soon as possible:
    1. Submit written testimony to email.bpw@maryland.gov, mdcomptroller@marylandtaxes.gov, and Treasurer@treasurer.state.md.us
    2. You can testify in-person at the Treasurer’s Office in Annapolis or virtually. Send request to email.bpw@maryland.gov 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.

RELEASE: Transportation Planning Board Re-Vote on Governor Hogan’s Toll Lanes

COALITION FOR SMARTER GROWTH

PRESS RELEASE

For Immediate Release

July 21, 2021

Contact

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).

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CSG Testimony: TPB Vote on Capital Beltway/I-270 & Long-Range Transportation Plan

CSG Testimony: TPB Vote on Capital Beltway/I-270 & Long-Range Transportation Plan

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.

Thank you,

Stewart Schwartz
Executive Director

RELEASE CORRECTED: Removal of 495/270 Toll Lanes from Regional Plan

RELEASE CORRECTED: Removal of 495/270 Toll Lanes from Regional Plan

PRESS RELEASE – CORRECTED (to identify the correct motion maker)

For Immediate Release
June 16, 2021

Contact:
Stewart Schwartz, Executive Director, 703-599-6437

Concern about Climate Change Leads to Historic Vote at the Region’s Transportation Planning Board

Vote removes 495/270 toll lanes from the long-range plan, requires next plan to meet climate goals

Today, in the latest of several significant debates at the Transportation Planning Board, the regional body of local and state officials charged with creating a regional long-range transportation plan Visualize 2045, the body voted to remove the I-495/I-270 toll lanes from the draft plan and to require the development of a climate-friendly plan by 2024.

Gary Ehrenrich, representing Montgomery County Executive Marc Elrich made the motion to remove the I-495/I-270 toll lane project from the plan and it passed 16 to 12 with 6 abstentions. Mayor Bridget Newton of Rockville and other Maryland leaders spoke firmly about the reasons for removing the project, with the vote attracting near universal support from local Maryland jurisdictions as well as support from DC and some Virginia jurisdictions. This was followed by a vote on the draft 2022 long-range transportation plan – now minus the toll lane project, and with provisions advanced by Montgomery County Councilmember Evan Glass to commit the TPB to create a new plan by 2024 that significantly reduces greenhouse gas emissions. The TPB voted 26 to 4 with 4 abstentions on the measure.

“The unifying theme in today’s vote was the overwhelming concern of elected officials about climate change. It motivated the vote to remove the toll lane project and to do more to reduce greenhouse gas emissions from our region’s transportation sector,” said Stewart Schwartz, Executive Director of the Coalition for Smarter Growth.

A number of outer Virginia jurisdictions thought it was too late to change the current draft plan which will move forward into air quality modeling and adoption in the spring of 2022, but they ultimately also joined Maryland and DC in voting to begin work to adopt another more climate-friendly plan by 2024. “We wish the TPB would have acted this cycle to fundamentally reform the current plan because we have no time to waste,” said Schwartz. “Nevertheless, they made an important commitment today to adopt a more climate-friendly plan by 2024.”

  • The scientific consensus is that we must slash our emissions by 2030. The Biden Administration and our regional Council of Governments have each set a goal of cutting CO2 emissions 50% below 2005 levels by 2030.
  • Transportation is this region’s and the nation’s largest source of CO2 emissions.
  • Recent studies show that electric vehicles will not be enough, therefore the region will need to use transit-oriented development, transit, and demand reduction solutions to reduce vehicle miles traveled and associated emissions.
  • The Council of Governments’ recent Voices of the Region Survey found that 84% of the region’s residents want elected officials to prioritize climate change in transportation plans.
  • Public comment on Visualize 2045 has overwhelmingly supported a plan that addresses climate change.

“Removal of the I-495/I270 project from the draft plan means it will not be included in the federally mandated air quality conformity modeling, a huge roadblock for the controversial project,” said Schwartz. “I believe the many flaws in the Hogan Administration’s approach to the project including failure to analyze more sustainable and less destructive alternatives, failure to hear the public outcry or account for the strong opposition of nearly every local jurisdiction, and rush to commit the state to a long-term contract before finishing all of the environmental impact studies, contributed to the resounding rejection of the project today at the TPB.”

“There may also be implications for Virginia’s 495Next HOT lane extension contract with Transurban but that would have to be confirmed with VDOT,” said Schwartz. “Many of us had urged Virginia not to rush into that deal because of the controversy in Maryland and the similar failure in Virginia to consider alternative approaches. We want to see solutions for the American Legion Bridge and 495, and the best solutions lie in addressing the east-west jobs/housing imbalance, focusing jobs and housing near transit, and in the growth in telecommuting.”

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RELEASE: Best Smart Growth Plan for ALB & Beltway

Press Release 

For Immediate Release: 

April 9, 2021 

Contact:  

Stewart Schwartz, CSG, 703-599-6437, stewart@smartergrowth.net 

Eliza Cava, ANS, 202-503-9141, eliza.cava@anshome.org 

Kyle Hart, NPCA, 202-400-1193, khart@npca.org 

Josh Tulkin, Sierra Club Maryland Chapter, josh.tulkin@mdsierra.org, 650-722-3171 Douglas Stewart, Sierra Club Virginia Chapter, 703-407-2790, douglasbstewart@gmail.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.  

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Best Smart Growth Plan for ALB & Beltway

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

Introduction:

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:

  1. 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.
  2. The 2003-2004 VDOT/TPB origin-destination study showed similar results.
  3. 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:

  1. 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.
  2. 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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:

  1. We support appropriate investment at the American Legion Bridge crossing.
  2. We oppose any efforts to revive proposals for an upriver bridge.
  3. 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.
  4. 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.
  5. We request evaluation and adoption of a land use, transit, and demand management alternative to include:
    1. 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.
    2. 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.
    3. Demand management tools:  parking pricing, employer transit benefits and parking cashout, telecommuting, and (potentially) pricing existing lanes rather than expansion with priced lanes.
    4. Inclusion of well-designed bicycle and pedestrian connections to and across a rehabilitated or new American Legion Bridge.
    5. We seek clear environmental justice considerations to be brought into the highway expansion planning.
  6. 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:
    1. Include bike/pedestrian connections.
    2. Provide significant funding for transit operating and capital needs to ensure frequent, high-capacity transit.
    3. Incorporate a bridge design that supports Metrorail.
    4. 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.
    5. 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.

RELEASE: CSG Joint Comments on Proposed Expansion of I-495/I-270

November 9, 2020

FOR IMMEDIATE RELEASE

Monday, November 9, 2020

Contact:
Lindsey Mendelson, Maryland Sierra Club, lindsey.mendelson@mdsierra.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 

Background: 

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.

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