Tag: 495/270

Best Smart Growth Plan for ALB & Beltway

Posted on by Emily Maurer
Best-Smart-Growth-Plan-for-ALB-Beltway-FinalDownload

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

Posted on by Emily Maurer

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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495/270 Update | July 2020

Posted on by Emily Maurer
Photo credit: urbandispute, Flickr

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:

1. Sign up for a virtual or in-person public hearing.

2. Tell Maryland to extend the comment period to 120 days.

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.

RELEASE: Advocates Alarmed at 18,000 Page Environmental Impact Statement on Gov. Hogan’s I-495 and I-270 Widening Plan

Posted on by Emily Maurer

July 10, 2020

FOR IMMEDIATE RELEASE

Friday, July 10th, 2020

CONTACT:

Lindsey Mendelson, Maryland Sierra Club
lindsey.mendelson@mdsierra.org | (240) 706-7901

Jeanne Braha, Rock Creek Conservancy
jbraha@rockcreekconservancy.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. 

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495/270 P3 DEIS Comment Extension Letter

Posted on by Emily Maurer
2020-07-01-RCC-Request-for-Extension-of-Comment-Period-on-495-270-Expansion-DEIS-CleanDownload

June 30, 2020 

Dear Ms. Mar and Ms. Choplin, 

We are writing on behalf of the undersigned organizations to request an extension of the public comment period. The proposed I-495 & I-270 Public-Private Partnership (P3) Program (Project) is likely to have significant impacts on water quality, air quality, and managed by the Maryland National Capital Planning Commission, and downstream on Rock Creek Park. 

The Maryland Department of Transportation – State Highway Administration (MDOT SHA) and the Federal Highway Administration (Agencies) have indicated they will soon make available for public comment the Draft Environmental Impact Statement (DEIS) for the proposed Project. This DEIS will describe the proposed action’s impacts on the environment as well as the impacts of alternatives and plans to mitigate the impacts. The document also will describe the environmental analysis conducted on the impacts of construction and operation of the new roadway. It is critical that the public have an adequate opportunity to meaningfully review the DEIS and submit comments to ensure that the Agencies’ analysis is complete and fairly considers all the options for the Project. 

We believe that allowing sufficient time for a well-considered review and thorough comments on the DEIS will lead to better evaluations, a more efficient process, and solutions that protect environmental resources, including Rock Creek. Due to the evolving situation with COVID-19, it is even more imperative that the public be given sufficient time to submit comments on the DEIS. Over the last few months, several of the undersigned organizations have submitted Freedom of Information Act and Maryland Public Information Act requests to the Agencies, the 

timely fulfillment of which would have assisted our reviews of the DEIS. These requests were denied, ignored, or delayed. 

The Project is one of the largest of its type ever proposed, expected to cost billions of dollars, and have significant environmental impacts. We expect the DEIS and its dozens of appendices and corresponding data to be thousands of pages. In regular times, for a proposed action such as this, the Agencies should reach an agreement to provide a longer time period and if not, the lead agency should easily find good cause to provide an extended comment period beyond 60 days from publication in the federal register. See 23 U.S.C. § 139(g)(2)(A); 42 U.S.C. § 4370m–4(d). Not doing so would not allow for meaningful public review and comment. 

These are not normal times. The emergency COVID-19 pandemic, and corresponding mandatory and voluntary restrictions, necessitate a longer public comment period. Like your agencies and other interested parties, our groups are working remotely while dealing with other responsibilities, generally without the use of office equipment such as printers for large files. Communications within our organizations, with members, and with others in the public that are interested in participating in the process are also delayed. The public’s ability to review and comment on the DEIS is currently hampered and requires more time than normal. Both of your agencies have recognized the difficulties caused by the pandemic. Both agencies have delayed providing electronic records in response to our public records requests (beyond statutory deadlines) based on asserted difficulties caused to the Agencies by the pandemic.1 It would be arbitrary for the Agencies to now deny the pandemic does not present good cause for a longer comment period. 

We appreciate the Agencies’ commitment that the public comment period will extend beyond the minimum-required 45 days and that the Agencies desire to allow full participation by the public and interested stakeholders. Forty-five days, or anything close to that, is clearly not sufficient. The undersigned organizations therefore request that the Agencies provide at least 120 days for public comment on the DEIS. This amount of time is necessary with increased uncertainty over the ability to re-open safely in a way that will allow the public to view documents in a timely manner. This time frame is also consistent with other Environmental Impact Statement comment periods such as the Washington Union Station Expansion Project and the Farmington Resource Management Plan. 

We look forward to your affirmative response to this request. 

Respectfully submitted, 

As an example, despite previously agreeing to provide non-exempt responsive records to one of our February 18 requests by April 30, MDOT SHA then requested that we “extend the 10-day period for providing a time and cost estimate, as well as the 30-day period for responding to your request, until 10 days after the date that [Maryland’s] state of emergency is lifted.” MDOT SHA stated: “Complying with the statutory timeframes of your PIA request at this time is not feasible given the state of emergency and recognized health risk that the coronavirus poses to all Marylanders, including State employees responsible for identifying, retrieving, and reviewing documents and responding to your request.” We still have not received any responsive records. 

Signed by, 

Jeanne Braha, Executive Director, Rock Creek Conservancy Josh Tulkin, Director, Sierra Club, Maryland Chapter 

On behalf of the following organizations: 

350 Montgomery County 

Audubon Naturalist Society – Woodend, Chevy Chase, MD 

Baltimore Tree Trust 

Beaverdam Creek Watershed Watch Group 

Cedar Lane Unitarian Universalist Church Environmental Justice Ministry 

Central Maryland Transportation Alliance 

Chesapeake Bay Foundation 

Chesapeake Physicians for Social Responsibility 

Citizens Against Beltway Expansion [CABE] 

Cleanwater Linganore Inc 

Climate Parents of Prince George’s County 

Coalition for Smarter Growth 

Conservation Montgomery 

DontWiden270.org 

DoTheMostGood Montgomery County 

Forest Glen Citizens Association 

Friends of Sligo Creek 

Greenbelt Advocates for Environmental and Social Justice 

Greenbelt Climate Action Network 

Indian Spring Citizens Association 

Indivisible Howard County 

League of Women Voters of Maryland 

Maryland Campaign for Environmental Human Rights 

Maryland Legislative Coalition 

National Parks Conservation Association 

Neighbors of the Northwest Branch 

North Hills of Sligo Creek Civic Association (NHSCCA) 

Our Revolution Maryland 

Parkwood 

Preservation Maryland 

Prince George’s County (MD) Peace & Justice Coalition 

Rapid Shift 

Regents Square Condominium (Rockville) 

Rock Creek Conservancy 

Rogue Tulips Consulting & Association Management 

Sierra Club, Maryland Chapter 

Takoma Park Mobilization 

The Ocean Foundation 

University Park Community Solar LLC 

Washington Area Bicyclist Association 

Wicomici Environmental Trust, Ltd. 

West Montgomery County Citizens Association (WMCCA) 

Woodside Forest Civic Association 

cc: Linda Strozyk DeVuono, Office of the Attorney General, LDeVuono@mdot.maryland.gov 

CSG testimony opposing I-270/495 expansion

Posted on by Emily Maurer

January 8, 2020

Maryland Board of Public Works

Maryland State House

100 State Circle

Annapolis, MD 21401

Maryland Department of Transportation Item 23-GM (Oppose) 

Testimony for January 8, 2020 

Jane Lyons, Maryland Advocacy Manager 

Governor Hogan and Board members, thank you for the opportunity to speak today. I am here on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. I am also a founding member of the Maryland Advocates for Sustainable Transportation coalition, which includes over 20 organizations and continues to grow. 

Financial and process concerns: 

The multi-billion dollar, decades-long decision being made today is being rushed. It is premature and lacks adequate environmental, alternatives, and financial analyses. You have begun with the conclusion – to build private toll lanes – rather than with an objective analysis of alternatives. Critical information has not been shared with the public and other local, state, and federal agencies. This is not how any state should be making multi-billion dollar decisions. 

This project has significant financial uncertainty and risks. Prior to advancing this project and prior to solicitation, you must share the proposed financial terms and risks, including the state’s responsibility to compensate developers and lenders. Prior to taking action, you must request truly independent financial and traffic analyses. The public deserves to know how much they are expected to pay, both in tolls and potentially in taxes. 

Environmental and traffic mitigation concerns: 

We are also concerned about environmental impacts and traffic mitigation. We appreciate the attention given to the American Legion Bridge. However, private toll lanes may not be the answer. To date, MDOT has failed to study a true, comprehensive transit, demand management, and transit-oriented land use alternative to expanding I-495 and I-270, and in the case of the American Legion Bridge, Maryland and Virginia should study Purple Line and Metrorail options. 

Maryland has 26 Metro stations, many of which are not being used to their full potential. Incentivizing residential and commercial development at Maryland’s Metro, Purple Line, and certain MARC stations would do more to reduce driving, long-distance commuting, and traffic than further widening highways. Because of induced demand, newly widened highways in metropolitan areas fill up again in as few as five years, but transit-oriented development provides long-term traffic mitigation. 

Furthermore, the retained alternatives are in direct opposition to state climate and economic development goals. Your focus on moving cars in the west side of the region and your failure to study a transit-oriented development solution leaves Prince George’s, eastern Montgomery, and Baltimore behind. Investing in TOD and jobs in the Prince George’s to Baltimore transit corridors would not only do more to address traffic, it would provide critically needed, more balanced, economic development. Amazon’s HQ2 selection makes clear the high value modern employers place on access to high quality public transit. 

To this, the scope of any transit improvements offered to counties in the P3 agreement needs to be clarified before today’s approval. A single BRT line is not enough to offset the harm of adding miles of new highway lanes. 

For these reasons, we urge the Board to delay further action and steps towards a P3 agreement, and ultimately adopt a more effective and sustainable transit-oriented approach. At a minimum, this project requires a comprehensive alternatives and impact analysis, clarification of the state’s financial obligations, independent financial and traffic analyses, and a better deal for transit. 

Thank you for your time.

RELEASE: CSG and partners launch a pro-transit coalition to counter Maryland’s I-495/I-270 widening

RELEASE: CSG and partners launch a pro-transit coalition to counter Maryland’s I-495/I-270 widening

Posted on by Jane Lyons
Press-ReleaseDownload

FOR IMMEDIATE RELEASE

Friday, January 3, 2020

CONTACT:

Jane Lyons, Coalition for Smarter Growth

jane@smartergrowth.net | (202) 675-0016

Lindsey Mendelson, Maryland Sierra Club

lindsey.mendelson@mdsierra.org | (240) 706-7901

Maryland Advocates React to Hogan-Franchot Agreement and 

Launch Coalition to Change Direction of State Transportation Policy

MARYLAND — Following today’s announcement of an agreement between Governor Hogan and Comptroller Franchot and in advance of Wednesday’s Board of Public Works vote, 18 non-profit and community advocacy organizations launched a new coalition to change the direction of state transportation policy. The groups share a concern for protecting the environment and communities, and more effectively addressing the state’s transportation problems — through transit, transit-oriented development, and demand management strategies. 

Formation of Maryland Advocates for Sustainable Transportation (MAST) follows public outcry against Governor Hogan’s and former Secretary Rahn’s ill-conceived and harmful plans to expand the Capital Beltway and I-270. The outcry prompted a delay in the December Board of Public Works vote to approve a hastily revised Public-Private Partnership (P3) proposal for the highways. A premature vote is now scheduled for January 8th. 

The coalition is calling on the Governor and incoming secretary to reverse course on the administration’s misguided highway expansion plan and to steer the state toward better solutions. MAST members sent a letter to Administrator Slater calling on him to change MDOT’s approach to transportation policy if he is confirmed by the Maryland Senate.

Reliable, transit and land use focused solutions — MAST supports transportation solutions that effectively address the climate crisis and our transportation problems, rather than exacerbate them. These integrated solutions include expanding reliable transit, bicycle, and pedestrian infrastructure; using transportation demand management; encouraging more transit-oriented land use with affordable housing; and a maintenance-first approach to road and bridge infrastructure. This approach will allow Maryland to grow without increasing driving, traffic, and greenhouse gas emissions.

MAST will support a bill to increase capital investment in the Maryland Transit Administration, which has a deferred maintenance backlog of $1.5 billion and is facing funding cuts by MDOT, and another bill that addresses the weaknesses in the state’s P3 law.

Flaws in the I-495 and I-270 proposal: MAST joins with state legislators and local elected officials and planners who have identified significant shortcomings in MDOT’s toll lanes proposal, including:

  • Faulty P3 process and lack of transparency — MDOT’s P3 process for I-495 and I-270 has been flawed from the outset, including being rushed ahead of the environmental review process and the lack of objective alternatives analysis. MAST calls on MDOT to release their financial analyses, toll projections, and traffic modeling for independent review.
  • Failure to account for induced demand and increased air pollution — Research and experience shows that adding highway capacity inevitably leads to more vehicles on the road and more pollution from those vehicles, with expanded highways filling-up in as few as five years. MDOT’s study fails to consider an integrated transit-oriented development, transit, and demand management alternative.
  • Financial risks — The early Virginia experience shows that poorly structured P3 deals carry heavy financial risks, with taxpayers shouldering the bill when tolls cannot cover the costs of the project as planned or other problems occur.
  • Environmental harm — The highway expansion proposal would take valued park land, streams, and rivers in a number of locations; exacerbate stormwater runoff; require the loss of a number of homes; and directly affect 1,000 or more private properties.

“It is unlawful to proceed in securing implementation partnerships and contracts without completion and consideration of Environmental Impact Studies and related mitigation,” said Audubon Naturalist Society Executive Director Lisa Alexander.

“Transit and walkable, transit-oriented development are not only more effective in reducing vehicle trips, they attract jobs and residents. Marriott’s move to Bethesda Metro and Amazon’s move to Crystal City/Pentagon City are a testament to the value of transit-oriented development,” said Stewart Schwartz, Executive Director, Coalition for Smarter Growth.

“Maryland has committed to reducing greenhouse gas emissions, yet toll lanes will fuel more long-distance commuting, which increases driving, emissions, air pollution, water pollution, and traffic,” said Nancy Soreng, League of Women Voters of Maryland.

“Sustainable transportation solutions also spur more economic development and increase opportunities for socioeconomic mobility,” said Kimberly Brandt, Director of Smart Growth Maryland.

“The state must work together with local jurisdictions to find transportation solutions that are good for local residents, good for the environment, and good for Maryland taxpayers” said Brian Ditzler, Chair of Maryland Sierra Club.

Presently, 18 organizations have signed MAST’s principles statement. Follow the coalition by visiting MAST on Facebook and Twitter. A MAST website is now in development.

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Maryland Advocates for Sustainable Transportation (MAST) is a coalition of 18 non-profit and community advocacy organizations pushing for more sustainable alternatives to highway expansion. Signers of the coalition’s principles statement include: 350 Montgomery County, Audubon Naturalist Society, Baltimore Transit Equity Coalition, Bike Maryland, Central Maryland Transportation Alliance, Coalition for Smarter Growth, Corazón Latino, Friends of Sligo Creek, Greater Farmland Civic Association, Greater Greater Washington, Interfaith Power & Light (DC.MD.NoVA), League of Women Voters of Maryland, Maryland Sierra Club, National Parks Conservation Association, Neighbors of the Northwest Branch, Rails to Trails Conservancy, Smart Growth Maryland, and Washington Area Bicyclist Association.

ACTION: Tell Maryland to delay the I-495/I-270 widening project until after environmental reviews!

ACTION: Tell Maryland to delay the I-495/I-270 widening project until after environmental reviews!

Posted on by Jane Lyons

As you’ve probably heard, the Maryland Department of Transportation (MDOT) plans to expand the Capital Beltway (I-495) and I-270 by adding toll lanes, and now wants to accelerate the project by passing amendments through the Maryland Board of Public Works.

Email Maryland’s Board of Public Works members today!

We don’t think this project should more forward until there has been a comprehensive alternatives and impact analysis under the National Envrionmental Policy Act (NEPA). Rushing the highway expansions and failing to complete the environmental review process first creates significant environmental, legal, and financial risks.

As the Virginia experience has shown, the 12-lane highways that result from adding four 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. Maryland has committed to reducing greenhouse gas emissions, yet toll lanes will increase driving and emissions.

Image: urbandispute, Flickr

Letter to Governor Hogan opposing I-270/495 expansion

Posted on by Emily Maurer

December 3, 2019

The Honorable Larry Hogan

State of Maryland

Governor

100 State Circle

Annapolis, MD 21401 

Re: Capital Beltway and I-270 

Dear Governor Hogan: 

We are writing to share our strong and continuing concerns with your proposals for the Capital Beltway and I-270. We urge you to delay further action at the Board of Public Works and any steps toward a public-private partnership, until you conduct a comprehensive alternatives and impact analysis under the National Environmental Policy Act (NEPA). 

As we have noted before, MDOT failed to study an integrated transit-oriented development (TOD), transit and demand management alternative to your proposed toll lanes. This is important because your proposal will increase, not decrease driving demand, whereas a transit- oriented development approach that includes buildout of development at Prince George’s 15 Metro stations, Montgomery’s 13 stations, and selected MARC stations will reduce vehicle trips and vehicle miles traveled while providing the competitive placemaking environment so much in demand by people and corporations today. Transit components of this alternative include the Purple Line, Metro capacity expansion, MARC expansion, and bus rapid transit (BRT) networks. The Council of Governments recently determined that TOD, BRT, and Metro all performed best in improving the performance of our highways. 

If the Amazon decision to locate in Arlington near two Metro stations tells us anything, it’s that transit-oriented development (TOD) is our future. In fact, the WMATA Connect Greater Washington study shows that build-out of the DC region’s Metro stations would so shift travel modes and trip patterns that we would avoid having to add 1000 lane miles of new roads and thousands of parking spaces. At the same time, Metro would go from needing public operating subsidies to annual operating surpluses because the trains would be full in both directions and all day due to the amount of development at the suburban stations. 

Your proposed toll lanes will fail because of induced demand: the new capacity created by the toll lanes, especially through diversion from the general-purpose lanes, will not last. The general-purpose lanes will fill up again as people decide to live farther away from work to take advantage of the initial time savings or decide to switch to driving from other modes or to drive more often. At the same time, vehicles seeking to reach the new capacity will add to traffic on all connecting roads. Additionally, toll lanes have termini, and the congestion which occurs at these termini, where multiple new lanes merge into the regular lanes, is regularly substantial; the congestion is merely moved “down the line” by some miles. By fueling more long-distance living and commuting, toll lanes add to vehicle miles traveled, greenhouse gas emissions, air pollution, water pollution, and traffic. Last, but not least, they raise serious equity concerns. 

As the Virginia experience has shown, the 12-lane highways that result from adding four toll lanes to the Beltway and other highways are a massive, generational alteration of our landscape and come at high cost to homes and neighborhoods, people and health, and the environment. You have committed to reducing greenhouse gas emissions in Maryland, yet the toll lanes will increase driving and emissions. In contrast, the comprehensive TOD, transit and demand management alternative will reduce vehicle trips, vehicle miles traveled and greenhouse gas emissions. 

We have been extremely concerned about the process that has been applied to the toll highway proposals, as have the Comptroller and Treasurer, members of the legislature, the local community and local elected officials, and the Maryland National Capital Park and Planning Commission. The failure to complete the NEPA process including full alternatives and impacts analysis, creates significant risks for the project, both legal and financial. 

The Comptroller promised the project would not be approved by the Board until the EIS is complete. Your proposed timeline assumes an agreement will happen in February of 2021 even though the NEPA process from the upper portion of I-270 has still not begun. Moreover, the Department of Legislative Services recommended that the P3 statute be amended to prohibit the submission of a pre-solicitation report prior to the availability of an environmental impact statement which has not yet been released. 

The Maryland National Capital Park and Planning Commission (M-NCPPC) has twice decided unanimously not to concur with the alternatives for the project. To this date–the public and M- NCPCC still don’t have origin-and-destination data, stormwater management impacts, financial assumptions, toll rates and other critical information that is important for this solicitation proposal to be approved. 

For all of the reasons we outline in this letter, we once again urge you to delay further action at the Board of Public Works and any steps toward a public-private partnership, until you conduct a comprehensive alternatives and impact analysis under the National Environmental Policy Act (NEPA), and to ultimately adopt the more effective and sustainable transit-oriented approach that we have outlined here. 

Sincerely, 

Denisse Guitarra | Maryland Conservation Advocate | Audubon Naturalist Society 

Brian O’Malley | President & CEO | Central Maryland Transportation Alliance 

Stewart Schwartz | Executive Director | Coalition for Smarter Growth 

Ed Rich | President | Greater Farmland Civic Association 

Lois Hybl and Richard Willson | Co-Presidents | League of Women Voters of Maryland 

Pamela Goddard | Senior Program Director, Mid-Atlantic Region | National Parks Conservation Association 

Josh Tulkin | Director | Sierra Club, Maryland Chapter 

Kimberly Golden Brandt | Director | Smart Growth Maryland