The Baltimore Regional Partnership appreciates the opportunity to comment today on the Draft 2001-2005 Transportation Improvement Program (TIP) for the Baltimore Region. As you know, the Partnership is a collaborative effort among five civic, environmental, and anti-sprawl organizations to improve land use and transportation planning, environmental quality, and consideration of equity impacts in the Baltimore region.

We have many specific comments on individual projects in the draft 2001-2005 TIP, but we also have three broader comments. Within the short-term perspective of the TIP, we believe these three areas offer special opportunities for achieving lasting solutions to the problems in the Baltimore region associated with transportation and related land use decisions.

1. Transportation Management Activities: Projects such as ridesharing programs and congestion management systems should be expanded to include the full range of available transportation demand management tools and Transportation Control Measures, including parking management, land use measures, and the Commuter Choice program. In fact, Michael Replogle of Environmental Defense and Dan Pontious of the Partnership have urged the Transportation Steering Committee (TSC) to devote significant resources, on the order of $5 million, to aggressively promote federal and state Commuter Choice tax incentives to employers throughout the region. In addition, a March 28, 2000 letter to the TSC from Michael Replogle, Dru Schmidt-Perkins of 1000 Friends of Maryland, and Lee Epstein of the Chesapeake Bay Foundation outlines specific reasonably available transportation control measures (RATCMs) that we believe the TSC is required under the Clean Air Act to consider as part of its transportation programs. We again urge you to consider these measures thoroughly as part of the 2001-2005 TIP process.

2. Planning Studies: The many planning studies contained in the TIP provide perfect opportunities to look "beyond the pavement" into community and land use issues, which often hold the key to identifying sustainable solutions to transportation problems. As was evident recently in the experience with the new Arundel Mills Mall, local land use decisions can have a profound affect on regional transportation problems and projects. Similarly, regional transportation decisions can have a dramatic affect on local land use opportunities and market incentives for various land use decisions. The scope of the planning studies in this draft TIP should be expanded to cover these broader issues.

3. Bridge Projects: - Many of the bridge and bridge deck reconstruction projects in the program provide opportunities to improve bicycle and pedestrian connections. Often, these bridges are the critical links in the pedestrian and bicycle networks, just as they are for cars. Moreover, these bridges often span river valleys that are the focus of bike and pedestrian movement systems. All bridge projects should include an explicit and careful examination of bike and pedestrian needs.

Baltimore City:

#12-9603-04 - Traffic Signal Computer Replacement

Traffic signal pre-emption capability for transit vehicles should be explicitly included in the scope, description and justification for this project.

#12-9807-04 - Traffic Signal Detectors Installation

We are confused by this item, since funding is not shown. We also urge caution in proceeding with this project, since signal actuation by vehicle detectors can work against the coordination of signals in an interconnected system and thus may actually hinder overall traffic flow.

#12-9403-41 - US 40 Terminus Modification

We believe this project holds significant potential for transit-oriented development, especially considering its location adjacent to a MARC Commuter Rail Station and near a significant amount of vacant and under-utilized land. Unfortunately, the old design for this project was not sympathetic to existing and potential development, and the overall project has been repeatedly delayed to beyond the outer years of the capital program. We urge reconsideration of the design of the project and its acceleration in the TIP if a new mixed-use, transit-oriented design compatible with the surrounding area and community can be assembled.

#12-9902-13 - Frederick Avenue Bridge Over Gwynns Falls Greenway

Plans for this bridge replacement should be coordinated with the Gwynns Falls Greenway.

#12-0001-13 - Harford Road Bridge Over Herring Run

A bikeway runs underneath this bridge. As part of this project, extensions of the bikeway to Lake Montebello, Morgan State University and other locations should be investigated.

#12-9215-13 - Monroe Street Viaduct Over the B&O Railroad

We are not clear to which bridge this project refers. It is our understanding that the B&O Railroad no longer exists. The TIP should specify if this is the bridge over the CSX Mainline or over the Mount Clare siding which terminates at the B&O Railroad Museum.

#12-9213-13 Potee Street Bridge Over the Patapsco River

Bikeway and pedestrian improvements should be incorporated into this project.

#16-0001-04 - Advanced Traffic Management

See Baltimore City #12-9603-04 and #12-9807-04.

#70-0003-59 - Maglev System Study

This project is a study. The stated justification is for Maglev itself, not for the study. The study must determine if Maglev is justified.

#40-0003-09 - Greyhound Terminal at Penn Station

While we believe this is a worthy project overall, we do not believe it is an appropriate use of CMAQ funds. Since the terminal is being moved from an area of very high local transit accessibility, we do not see the congestion mitigation or air quality benefits accruing to the move. Other funds should be found for this project, and CMAQ funds should be used for projects with much more demonstrable air quality benefits.

#40-0001-06 - Light Rail Double Tracking

We are glad to see that MTA has compressed this project to five years, but in our December 14, 1999 comments on the 2000-2004 TIP, we offered a way to fund its compression into four years. We urge the continued acceleration of this much needed measure.

#40-0015-64 - Bus System Preservation and Improvements

We believe this item is far too broadly defined. We urge the TSC and MTA to designate funds for specific transit facilities, with an emphasis on user amenities at specific transit hubs.

#61-0103-43 - MD 174 Bridge Over I-97

This project involves a major capacity increase to the I-97 interchange at Quarterfield Road, and is being treated as such in the environmental review process, with an FEIS being prepared for 2001. Despite this, however, it is not included in the Regional Transportation Plan. The project description implicitly argues that this is unnecessary because this project will make the roadway "compatible with the adjacent roadway sections." However, the adjacent widened roadway segments are also very short, and the overall MD 174 corridor consists of a mixture of two, four and five lane sections.

We believe this project should be submitted as a candidate for inclusion in the regional transportation plan, and that the TSC should examine the project from a comprehensive perspective to determine what improvements are necessary to support smart and effective growth in the surrounding area. We are concerned that the fact that this project is not included in the regional plan illustrates a lack of definitive regionally sensitive land use planning for the area. As mentioned above, it involves a major capacity increase to an I-97 interchange, and it is located near significant vacant and under-utilized land, which could be notably affected by the project. It is also directly adjacent to the interchange of two major expressways, I-97 and MD 100.

#61-0105-41 - MD 3 - US 50 to MD 32

This is a study. The project description and justification should be expanded to include larger land use and transportation issues, rather than merely safety and capacity.

#63-0108-41 - I-695 (Baltimore Beltway) - I-95 to I-70

There are two projects for this section of the Beltway in the regional transportation plan, this project - widening from 6 to 8 lanes with three funding sources - and a future widening from 8 to 10 lanes for High Occupancy Vehicles. The long range plan thus recognizes that the current project will not be sufficient to last twenty years. Aggressive transportation management measures should be considered now before either of these road widenings moves forward.

#63-0101-45 - I-695 (Baltimore Beltway) at MD 26

This project calls for a capacity increase. It should therefore not be granted "Programmatically Conforming" status, or a Categorical Exclusion from the environmental review process.

#63-0110-42 - MD 145 (Paper Mill Road)

This project should not be considered "Programmatically Conforming" because it is a brand new road that will certainly increase traffic. It is one of the biggest sprawl-makers in the capital program, providing a new direct highway connection between Shawan Road and the sensitive Loch Raven watershed area to the east and beyond. It should therefore not be excluded from the NEPA process. There is also a need for a bicycle connection in this corridor between the light rail line and the Northern Central Bikeway, which has not been fully addressed.

#64-9902-41 - MD 140 - Westminster

This scope of this project should be re-examined in light of the cancellation of the Westminster Bypass, which will increase the need and ability of Westminster to engage in smart growth-oriented planning and other activities. The cancellation of the Bypass should also make additional funds available to expand the project scope.

#64-0101-41 - Liberty Road

The scope of this study project should be widened to include smart growth land use issues and alternative transportation modes, and not simply capacity and safety.

#64-0102-42 - MD 30 Hampstead Bypass

While we believe the town of Hampstead is in need of traffic relief, the design and scope of this project should be re-examined in light of smart growth policies. SHA’s historic bypass projects have tended not to enhance the vitality of existing communities. Any traffic relief measure for Hampstead should be thoroughly studied for related impacts on land use and the local economy to avoid the economic drain and sprawling land use trends associated with many other bypasses. The Towson bypass in Baltimore County can perhaps be used as a model for a measure which relieves traffic pressure on York Road without draining the economic vitality of downtown Towson or providing a significant barrier to pedestrian and bicycle traffic in the area.

#65-0102-42 - MD 159 Perryman Road

#65-0101-41 - MD 24 Vietnam Veterans Memorial Highway

These studies should be defined to encompass smart growth objectives. The Perryman Road project in particular has great potential if it is defined to enhance community development and land use objectives.

#60-9308-04 Areawide CHART Projects

CMAQ is an inappropriate funding source for this project. In some instances, CHART operations result in increased vehicle emissions by increasing vehicle speeds and vehicle miles of travel through circuitous travel brought about by detours around congested areas.

#60-9505-04

#60-0103-09 - Areawide Congestion Management

This program should be spun off into a new account which focuses on Transportation Control Measures which address congestion and demand management issues, most notably parking management and Commuter Choice programs in key employment areas. We urge you to refer to the March 28, 2000 letter from Environmental Defense, 1000 Friends of Maryland, and the Chesapeake Bay Foundation for suggested measures to include.

#80-9601-00 - ITS Early Deployment Study

We are concerned that the BMC’s Intelligent Transportation Study has not been a balanced multi-modal effort thus far. It has emphasized traffic management and automobile traveler information at the expense of measures that could keep travelers off the region’s roads in the first place. The Mass Transit Administration, for example, has been developing electronic fare collection media "smart cards" in a separate process even though this technology must ultimately extend to electronic parking payments to be truly effective. "Smart cards" should also be integrated into the electronic toll collection system now being developed by the Maryland Transportation Authority and should be compatible (as we believe MDOT intends) with WMATA technology. BMC should restructure this program to give much greater priority to support for initiatives that truly integrate transit and automobile travel, such as "smart card" technology.

#80-0101-39 - Multi-Modal Traveler Information System

In addition to neglecting "smart card" technology, the regional ITS program has failed to provide funding for MTA’s Automatic Vehicle Locator system for transit vehicles. This is not only an essential component of a multi-modal traveler information system, but it is also crucial to the success of integrating the elements of MTA’s own system, including transit hubs and route consolidation. If the MTA does not have precise information of its vehicle locations, it cannot contribute accurate information to a multi-modal information system. As above, BMC’s ITS program should extend support to this vital MTA function.

Again, thank you for the opportunity to provide these comments. Feel free to contact Dan Pontious, Baltimore Regional Partnership director at (410) 385-2910 with any questions.