Baltimore Regional Partnership
1000 Friends of Maryland * Baltimore Urban League * Chesapeake Bay Foundation
Citizens’ Planning and Housing Association * Environmental Defense

March 28, 2000

Mr. J. Craig Forrest, Chairman
Transportation Steering Committee
601 North Howard Street
Baltimore, MD 21201

Re: General Comments for March 28 Transportation Steering Committee Meeting

Dear Mr. Forrest and Members of the Transportation Steering Committee,

Thank you for the opportunity to present general comments to you today on behalf of the Baltimore Regional Partnership. As you know, the Baltimore Regional Partnership is an alliance of five civic, environmental, and anti-sprawl groups who work to protect public health and improve the quality of life in the Baltimore region through promoting effective and equitable transportation and land use policies.

We appreciate the importance the Transportation Steering Committee has attached to issues such as composition and voting process at the TSC by appointing a Bylaws Subcommittee. Since we are now aware of the importance of the bylaws and 1992 memorandum of understanding in shaping the composition and voting members of the TSC, I have been attending the subcommittee meetings on behalf of the Partnership, and the subcommittee’s members have graciously welcomed my participation.

It is our strong contention that these documents must clearly delineate the active participation in the TSC of public officials from around the region. In fact, in the subcommittee’s review of Metropolitan Planning Organization (MPO) governing documents from around the country, active participation from elected officials was a clear common thread through them all. We also believe that weighted voting is an important issue that we are glad to see is on track to be considered by the subcommittee. The Citizens Planning and Housing Association (CPHA) has more extensive comments on that subject this morning.

The TSC is clearly faced with significant air pollution and traffic congestion problems in the Baltimore region over the next several years. While we believe the emissions control measures inserted into the Transportation Improvement Plan (TIP) and long range plan are still clearly inadequate, we do appreciate the TSC’s effort to include them.

Some of our concerns regarding transportation and emissions control measures relate to the TSC’s plans for consideration of the upcoming TIP. As today’s letter from Environmental Defense and other Partnership member organizations discusses in more detail, we are extremely concerned that the TSC is proceeding in a "business as usual" manner regarding the 2001-2005 TIP. Despite claims by the TSC that it is eager to embrace additional pollution and congestion mitigation measures, the upcoming TIP is scheduled for an April 26 public hearing. No first meeting of the much-discussed Mitigation Subcommittee has been scheduled, and no substantial discussion of additional mitigation measures, such as more effective promotion of Commuter Choice tax incentives, has been scheduled so as to include it in the TIP presented to the public. We strongly urge the TSC to delay the April public meeting until these measures can be discussed much more fully and incorporated into the plan that is presented to the public.

Our other concerns relate to the TSC’s response to our January comments on air quality conformity in the 2000-2004 TIP and long range plan. In our January 21 comments, we enumerated four specific concerns with the methodology used to calculate the benefits of the College 33 bus pass program and the telecommuting program. In a January 28 TSC worksession, Harvey Bloom announced that the TSC would responded to our concerns in "Attachment 1" to their reply letter. When we received Attachment 1, we found that it included a description of the two programs, but it did not address or even mention our specific comments. In a March 7 meeting, Maryland Department of Transportation (MDOT) and Baltimore Metropolitan Council (BMC) staff were able to explain their response more clearly, although we ended the meeting agreeing to disagree on the merits of the issues. Regardless of whether we can be persuaded of the TSC’s ultimate position, we hope that in the future the TSC will at least reference our comments in any reply.

We are extremely concerned about the delay in the BMC staff timeline for putting together an effective public involvement plan for the TSC. Last year’s Subcommittee on Certification made very specific recommendations for improving public involvement in TSC decision making, and yet the TSC has referred the bulk of those recommendations either to the Bylaws Subcommittee or to a staff plan that the BMC transportation director does not intend to complete until the fall. It is my understanding that even the Equity Subcommittee is currently considering some of these recommendations once again in the context of equity issues in the region. We in the Partnership are becoming concerned about a frustrating tendency in the TSC to shunt unwanted reforms from one subcommittee to another, or to a long-term staff report, while business continues as usual.

As we have mentioned in previous comments, we are encouraged that the TSC is poised to embark on a significant regional visioning process and we would like to contribute substantially to that process. We believe our perspective and resources on transportation and land use issues would be valuable in the development of a regional vision which effectively integrates transportation and land use planning. Such a vision should lead to a region with cleaner air, less traffic congestion, a more robust economy, and a higher overall quality of life than is contained in the TSC’s current 20-year plan. Furthermore, such a plan could be effective not only for the region as a whole, but for each individual jurisdiction in the region.

Unfortunately, we are concerned about our ability to participate effectively in the regional visioning process and about potential significant delays in its preparation. Initially we had heard that the TSC would like to launch this process by June or July. Now, however, we are concerned that we may not even be able to participate until July, when TSC planning for the visioning process would already be outlined, but not yet truly underway. We fear that this could lead to the worst of both worlds: a process already designed without our input, but which could still be delayed for months while other preparations are underway.

Despite our frustrations with the items listed above, we do hope to work closely with the TSC over the months ahead. If you have any questions or comments, feel free to contact me at (410) 385-2910 or danp@friendsofmd.org.

Sincerely,

Dan Pontious
Director

Cc: John D. Porcari, Secretary, Maryland Department of Transportation
Jane T. Nishida, Secretary, Maryland Department of the Environment
Nelson J. Castellanos, Division Administrator, Federal Highway Administration
Sheldon A. Kinbar, Regional Administrator, Federal Transit Administration
Bradley Campbell, Region III Administrator, Environmental Protection Agency