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COMMENTS OF THE BALTIMORE REGIONAL PARTNERSHIP 
ON THE FINAL DRAFT OF THE BALTIMORE REGION
2001-2005 TRANSPORTATION IMPROVEMENT PROGRAM,
AMENDMENTS TO THE 1998 PLAN,
AND CONFORMITY DETERMINATION

September 18, 2000

The Baltimore Regional Partnership appreciates the opportunity to comment today on the Final Draft 2001-2005 Transportation Improvement Program (TIP) for the Baltimore Region, the amendments to the 1998 Baltimore Regional Transportation Plan, and the Conformity Determination. 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 also appreciate the Baltimore Regional Transportation Board’s detailed response to our April 26 comments on the initial draft TIP. The comments below are our reply comments to your response. As in our initial comments, we have three general emphases.

We are heartened by your response to our April 26 comments on this subject, both in the general section and in individual projects. We hope this is an area where the BRTB and MDOT are incorporating important new thinking that prioritizes pedestrian and bicycle mobility, and that this work can help inform the regional Vision 2030 process. We are concerned, however, that these ideals be incorporated into the actual projects as they are realized on the ground, and we look forward to working with you in that effort.

2. Lack of Effective Planning Process:

In contrast to our comment above, we believe that the TIP and Plan amendments overall show the relatively haphazard nature of transportation infrastructure development in the Baltimore region. This is a problem we hope can be dramatically improved through the proposed Vision 2030 process. Currently no real vision for the region serves as a framework for the projects in the Baltimore Regional Transportation Plan (BRTP) and the TIP. As a result, congestion continues to mount, as reflected in the 1998 BRTP, and yet the Baltimore Regional Transportation Board has no real strategy to address it except to expand road and highway capacity on a spot basis. Thus the Guilford Road Improvements and the expansion of the MD 174 Bridge over I-97 appear in the current TIP even though, before now, they were not envisioned for the next 20 years.

Your response to our April 26 comments on "Planning Studies" is something of a case in point. We are certainly glad that MDOT is including analysis of secondary and cumulative effects of transportation projects in its planning studies, but many of the stated "justifications" for the planning studies in this TIP make them sound exactly like construction projects. There is no sense that any important information about the usefulness of the project will emerge from the study, and thus the study appears to be prejudged.

In addition to withholding judgment on planning studies, we believe that the BRTB must look at the transportation problems facing this region from a much larger perspective – delving into community and land use issues, as we said in our April 26 comments – before the best solutions will become apparent. Even a well-executed SCEA process will only describe the effects of particular project alternatives. It does not help MDOT or the BRTB pick a problem's best solution that may have so far escaped their attention.

Largely because of the problems in the BRTB's planning mentioned above, the priorities reflected in this TIP are sadly misplaced. We at the Baltimore Regional Partnership have been calling for more aggressive use of travel demand measures since the 1998 long-range plan was under consideration. This spring we made a renewed effort to urge the Baltimore metropolitan planning organization (MPO) to promote an aggressive, region-wide use of the new Commuter Choice tax credits. In March, when Environmental Defense's Michael Replogle and the Partnership's Dan Pontious sat down with the MPO's leaders, we were told that including significantly boosted funding for marketing Commuter Choice would not be possible in the delayed 2000 TIP, but that we should work with you in crafting a program for the 2001 TIP. That meeting, and our May letter with detailed suggestions, resulted in no new programs or discussions with respect to the 2001 TIP. Now we are told that, aside from the Commuter Choice program within the Maryland Department of Transportation, we must wait for the 2002 TIP to see any progress.

At the same time those common sense and relatively inexpensive measures are being delayed, however, the Guilford Road widenings and widening of the MD 174 interchange with I-97 appear in the TIP out of no previous planning documents, and the I-695 widening from MD 144 to I-95 is advanced into the TIP. The BRTB is needlessly delaying potentially effective transportation control measures, while it advances road widenings in no context other than local spot congestion problems.

The Emissions Mitigation Strategies Subcommittee, cited in your reply comments as a forum for action on transportation control measures, was announced in January and yet will not have its first meeting until October. Similarly, despite clear recommendations on public participation measures from a 1999 subcommittee on recertification, the Baltimore MPO decided in January to initiate yet another internal process to develop a public involvement plan. A workgroup designed to address that plan just had its second meeting today. We believe the delay in both these actions reflects the BRTB's seriously misplaced priorities. We certainly hope that the Vision 2030 process will provide a better context for both transportation decision-making and public participation than is in evidence in this TIP.

In the meantime, we again urge you to include more ambitious Transportation Control Measures (TCMs) in this TIP. Two readily available possibilities would be: 1) an aggressive campaign, with at least $5 million funding and active participation by local governments, to promote the use of Commuter Choice tax incentives in the region; and 2) formalization of a "Digital Harbor" employment and land use plan as a TCM both in the 2001-2005 TIP and the Baltimore region's State Implementation Plan. On the latter point, new employers are achieving surprisingly high walk-to-work mode shares for their employees, a tremendous "smart growth" advance that should be reflected in the region's transportation plans and BMC modeling and replicated where possible.

Baltimore City:

#12-9603-04 - Traffic Signal Computer Replacement

We appreciate your positive response to our comment on this item and your inclusion of light rail signal preemption in the Final Draft TIP. Our comment referred to all transit vehicles, however, and we urge the purchase of computer equipment that will aid bus signal preemption as well.

#12-9807-04 - Traffic Signal Detectors Installation

We appreciate the addition of funding amounts for this item. We believe our overall point may have been misunderstood, however, even if it is only a small one. We are only concerned that in many residential neighborhoods traffic signal patterns should be coordinated as much as possible to promote a moderate traffic speed, and that vehicle actuation can sometimes result in uncoordinated lights and excessive speed. Overall, we are concerned that poor traffic light timing in Baltimore City promotes excessive vehicle speed along various routes, hindering quality of life along many residential streets.

#12-9403-41 - US 40 Terminus Modification

We appreciate the response to our comments and wish to work with the BRTB, MTA, and Baltimore City to help promote appropriate development around the West Baltimore MARC station. Such an effort should improve pedestrian and transit access to the station as well as boost ridership.

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

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

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

We appreciate your response on these items. We are glad these projects are being coordinated in order to facilitate bicycle and pedestrian access and interconnectivity. We look forward to seeing them implemented in a bicycle- and pedestrian-friendly way.

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

Your response on this item was not particularly helpful, but we were able to see from the Final Draft TIP that this is the bridge over the CSX mainline. Perhaps the "traditional name" for this rail line in BRTB documents should be updated.

Howard County:

#16-0001-04 - Advanced Traffic Management

We appreciate your response to our comments. If signal priority is currently used in Howard County for emergency vehicles, perhaps it should be considered in the future for transit vehicles as well.

Mass Transit Administration:

#70-0003-59 - Maglev System Study

Here we disagree with your response. If the item to be funded is a study, the justification should be for the study. Otherwise you appear to prejudge the study itself. We propose that the second sentence of the justification be rewritten to say, "The study in this TIP further examines a potential Maglev project with respect to passenger carrying capacity, potential rights of way, travel times, job creation, and economic development in both Baltimore and Washington. It also analyzes the potential impact of Maglev on overall travel in the Baltimore-Washington corridor."

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

We see that air quality benefits have been claimed for this project in the Conformity Determination, but we do not see any assumptions or justification for this claim. The new terminal may have very high local transit accessibility, but the old terminal had even better MTA bus system accessibility and was also accessible to Metro subway, MARC commuter rail, and light rail by foot. We continue to urge the use of non-CMAQ funds for this project and to use the roughly $5 million in federal CMAQ funds currently slated for this project to bolster MDOT's Commuter Choice promotion project.

#40-0001-06 - Light Rail Double Tracking

We appreciate your reply to our comments on this subject, and we are sympathetic to the need to minimize disruptions to service during double-tracking. We do believe this should be a lesson, though, for thinking out any new rail transit lines in the future.

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

We appreciate your clarification of the components of this item, but our main concern remains. Your answer highlights the fact that MTA has only limited plans at this point to upgrade our transit system around a series of transit hubs with attractive user amenities.

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

Regardless of the merits of this particular project, we are concerned that in March it was not envisioned for the next 20 years, and now it will be completed in 2004 and will consume $11 million dollars that will not go to promote Commuter Choice or any other transportation control measure. Moving up expensive, piecemeal capacity expansions like this one while continually delaying substantial efforts to reduce traffic at its source epitomizes the transportation planning problems in this region.

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

This is yet another study in this TIP where the justification prejudges the study. Regardless of the analysis of secondary and cumulative effects, we believe the study should explore what is the best option for addressing safety and capacity concerns, including potential land use measures. The justification should be reworded to state, "This study will analyze various measures, including measures other than highway expansion, for addressing safety and capacity concerns along this corridor."

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

This project also demonstrates ineffective transportation planning in the Baltimore region. Its anticipated year of operation is 2015, and yet the 1998 long-range plan anticipates an additional HOV lane to be constructed along this stretch of I-695 by 2020. Thus, years and years of separate and overlapping sets of beltway construction along this section between 2010 and 2020 seem to be envisioned, and the Baltimore beltway could become a morass of disparate construction and widenings for the next 20 years. Funding figures also do not seem to make sense, either. Engineering alone for this 5.67 mile widening is slated to cost over $7 million, while all costs for 29 miles of HOV lanes in 2020 are estimated to be $93 million. And lastly, the Final Draft TIP indicates the length of this segment to be 5.67 miles, but the accompanying map illustrates a much longer segment from I-70 west to I-95 northeast. We urge the BRTB to make clear exactly which sections of the beltway are being widened and when.

#63-0001-41 and #63-0111-41 - I-695 (Baltimore Beltway) South of MD 144 to I-95

Perhaps more than the project above, this project also demonstrates problems with Baltimore region transportation planning. This widening of I-695 is being advanced in the TIP and Plan, while consideration of aggressive transportation control measures is being delayed altogether. Funding figures here call others in the Plan into even greater question. We do not understand why this project is split into two identically-described items in the TIP, but when both are combined, this 3 mile widening of I-695 in one direction is slated to cost $54 million. This figure makes the $93 million cost for 29 miles of HOV lanes in both directions even less plausible.

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

We appreciate your response to our comments on this item.

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

Here, again, the "justification" language prejudges the study and it ignores the land use concerns we raised in our April 26 comments. The description and justification in the TIP also do not mention the trail connection in your reply comments. The justification should read, "This study will analyze options for best resolving conflicts on MD 145 between the existing MD 145 and Shawan Road. It will also weigh goals such as curbing sprawl, connections to the North Central Trail, ease of east/west travel in Baltimore County, and access to I-83, the Hunt Valley commercial area, and the Hunt Valley light rail stop."

#64-9902-41 - MD 140 - Westminster

We appreciate your response to our comments, and we would like to see any report prepared by the task force you mention. We would like to be part of a smart growth solution for Westminster.

#64-0101-41 - Liberty Road

We appreciate your response to our comments, and this is one justification in the TIP that does not prejudge the study it supports. We urge the BRTB to include potential land use measures to address capacity issues in this heavily sprawl-plagued corridor.

#64-0102-42 - MD 30 Hampstead Bypass

We appreciate your response on this item, and we remain concerned about the potential of this bypass to exacerbate sprawl around Hampstead.

#65-0102-42 - MD 159 Perryman Road

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

We are pleased to see that these study "justifications" do not strongly prejudge their studies, although in the MD 24 item the word "capacity" should be changed to "access." The descriptions of these two projects should be changed to reflect the more open nature of the justification language.

#63-9308-04 Areawide CHART Projects

Our contention that CHART does not necessarily provide air quality benefits is supported by the fact that no air quality benefit is claimed for the $57 million project in the Emission Reduction Strategies Tracking Table in Appendix J of the Conformity Determination. These programs should be financed with other funds, freeing over $41 million in federal CMAQ funds for true emissions reductions strategies.

#60-9505-04

#60-0103-09 - Areawide Congestion Management

We appreciate your response on these items, but we still believe that this topic would be an ideal heading under which to fund aggressive marketing of Commuter Choice tax incentives.

#80-9601-00 - ITS Early Deployment Study

We are confused by your response to our comments on these questions. First you seem to say that "smart card" technology placed low on a set of priorities because of certain criteria, and then you seem to say it placed low because MTA and the Maryland Transportation Authority would have to take the lead. Neither of these reasons is compelling to us for keeping it such a low priority when it has such potential for keeping travelers out of private cars in the first place.

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

We appreciate your response to our April 26 comments on this item, and we understand the limitations of ITS funds.

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

Baltimore Regional Partnership · 512 Orchard Street  · Baltimore, MD 21201-1947
 phone: (410) 523-8150  x249 · fax: (410) 523-4022