[ Home ] [ Up ] [ About the Partnership ] [ Reports ] [ Local Advocacy ] [ News ] [ Resources ] [ Archives ] [ Job Openings ]

September 28, 2001

J. Craig Forrest
Baltimore Regional Transportation Board
2700 Lighthouse Point East
Baltimore, MD 21224

Dear Mr. Forrest:

We appreciate the opportunity to comment on the Final Draft 2002-2006 Transportation Improvement Program (TIP) for the Baltimore region and the Final Draft 2001 Baltimore Regional Transportation Plan (BRTP). As you know, the Baltimore Regional Partnership is a coalition of civic and environmental groups working to curb sprawl, enhance equity, and improve overall quality of life in the Baltimore region. We were strongly critical of the 1998 BRTP because of what we believe to be its impacts on those crucial concerns.

In general, we see a modest step forward in the Final Draft 2001 Baltimore Regional Transportation Plan, compared to the current 1998 plan. The plan includes a significant increase for transportation demand management (TDM) funding, it includes a new equity analysis, and two counties have removed three unwise highway widenings. Still, we believe the Board can readily move further in this TIP and Plan. The following are our highest priorities:

1. Flexible federal funding in the TIP should be reprogrammed to bring TDM benefits to the region much sooner than 2007.

2. The BRTP equity analysis should be enhanced to include midterm horizon years, likely showing the need to advance transit initiatives in the plan.

3. An additional $1.6 billion of highway widening funds in the TIP and BRTP should be reprogrammed for better uses or guided by a demand management strategy—

a. Harford County has already deleted two road widenings from the BRTP, freeing $129 million that should be dedicated to TDM.

b. $900 million of taxpayer funds slated for additional capacity on I-695 and I-95 south of Baltimore should not be spent until corridor studies are undertaken that develop demand management strategies for those arterials.

c. More than $600 million slated in the BRTP for highway expansions outside PFAs or right up to the edge of PFAs should be reprogrammed to TDM or transit in growth areas.

The following are the elements that we believe represent improvements in the Final Draft 2001 BRTP over the 1998 plan:

Regardless of their individual merit, the road widening and construction projects below use types of federal funds that the U.S. Congress has specifically said can be used for other needs. We believe these projects show there is adequate funding available in the TIP to advance some of the TDM initiatives included in the BRTP. They show that, even when the U.S. Dept. of Transportation offers flexibility, the Baltimore region is prioritizing road widenings and new construction over certain near-term demand management strategies, such as more aggressive marketing of Maryland’s Commuter Choice tax incentives.

We urge the BRTB to devote the funds noted below to innovative TDM efforts, such as promotion of Commuter Choice employer incentives. If the highway widenings below are higher priority than others in the TIP, then these projects should be financed with highway funds, and other projects should be modified or delayed to make flexible funds available for TDM.

In November 2000, the Transportation Opportunities Committee issued its final report to the Baltimore Regional Transportation Board. In highlighting the importance of the Baltimore Beltway to the region, the report stated, "With this in mind, the TOC recommends a strategic plan be developed for the Baltimore Beltway which explores High Occupancy Vehicle (HOV) lanes, High Occupancy Toll (HOT) lanes and other efficiency techniques that maximize the capacity of this regional asset. In addition, the TOC recommends the initiation of similar major corridor studies for I-95, I-83, and I-795." (Emphasis in original.)

Despite this recommendation, however, the Final Draft 2001 BRTP and TIP spend over $900 million in taxpayer funds to widen I-95 south of Baltimore and I-695 with no clear strategy for managing demand. The plan simply envisions widening the highways and adding HOV lanes. When modeled as an option as part of the I-95 Master Plan Study, HOV lanes performed extremely poorly in managing demand. Furthermore, HOV lanes have often proven problematic in practice.

The lack of a clear strategy for the Baltimore Beltway is even worse than it appears from a quick look at the projects in the table below. A closer look reveals that the proposed 29 miles of HOV lanes on I-695 are remarkably inexpensive compared to the much shorter widenings that precede it chronologically. In response to questions from the Baltimore Regional Partnership, the Maryland Department of Transportation has revealed that this is because the costs of the earlier projects include laying the pavement for the HOV lanes. This means that, not only are we planning to construct HOV lanes on the Beltway in the year 2020 with no real strategic plan, but we are planning to lay the pavement much earlier. In some sections of the Beltway, the pavement for HOV lanes scheduled for operation in 2020 has already been laid.

We urge the BRTB to reprogram a portion of these funds shown below for an immediate comprehensive study of the Beltway, including a vigorous exploration of the various options for managing demand on the facility for the coming 20-30 years.

Not only do the TIP projects below show that the BRTB plans to spend more than $100 million to widen the Beltway over the coming six years, five of the six projects below are funded by National Highway System funds, which can be used to enhance transit service in the corridor as well. The intended flexibility of the funds shown below is another indicator of the appropriateness of conducting a comprehensive study of the needs of the Baltimore Beltway in the immediate future.

The table below details funding programmed in the first draft BRTP that should now be available to enhance TDM efforts in the Final Draft. We urge particular consideration be given to Harford County’s TDM efforts, since that jurisdiction’s key decision to pursue a different path in the plan has resulted in the availability of these funds.

The nearly $500 million in highway widening projects outside PFAs listed below shows additional opportunities in the BRTP to reprogram funds for additional transit projects, such as the Metro extension to Bayview, and TDM programs.

While technically located within PFAs, each of the road widenings below extends to the edge of a PFA. With the exception of the MD 32 project, it is clear that these widenings are designed to facilitate traffic originating from development outside the PFA. The MD 32 project would only function in combination with the Howard County widenings outside that county’s PFA. All of the widenings below have the potential to create safety problems at the point where the newly widened 4-lane highway returns to 2 lanes. This would lead to new calls to widen the roads outside the PFA, such as the current calls to widen MD 32 in Howard County past MD 108. (See table above.)

In closing this set of comments, we want to acknowledge and praise the decision of the members of the BRTB to launch the current Vision 2030 process. As you know, we are active participants in that process and are even devoting funds to expand its scope. We understand that one of the goals of that process is to imbue the next Regional Transportation Plan with a more comprehensive regional context and vision. As active participants, we support that process and have high hopes for its results.

Still, we believe there are shorter-term steps the BRTB can take to improve this current Final Draft Plan and TIP. By taking advantage of flexible federal funding to advance innovative TDM programs to the near term, the BRTB can bring travel benefits to the region’s citizens in the immediate future. By developing strategic plans for our region’s most important highway assets, the BRTB can show the region’s citizens that we are not just trying to build our way out of traffic congestion. And by reprogramming BRTP funds currently slated road widenings to serve growth in rural areas, the BRTB can show the region that it is serious about using our transportation infrastructure to improve quality of life in existing communites and to curb rural sprawl.

These steps are essential if the region's transportation plan and program is to contribute to timely attainment of the National Ambient Air Quality Standards as required under the Clean Air Act. The Baltimore region remains a severe ozone non-attainment area and will face large challenges in reducing ozone precursor emissions, especially nitrogen oxides and particulates sufficiently to attain healthful air quality. Resources must be shifted now – not at some future time – from projects that increase traffic and pollution to projects that reduce traffic and pollution. What is at stake is not just sound transportation policy that expands travel choices, but the health of tens of thousands of people in the region who
today suffer adverse health impacts from Baltimore's degraded air quality.

Again, we appreciate the opportunity to comment on the Final Draft BRTP and TIP. We would welcome the opportunity to talk about potential changes to these documents. Please contact us with any questions.

Sincerely,

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