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1000 Friends of Maryland
1209 North Calvert Street, Baltimore, MD 21202

Comments on Howard County General Plan 2000 Draft
May 10, 2000

1000 Friends of Maryland appreciates the opportunity to comment on the Howard County Plan 2000 draft. 1000 Friends of Maryland is a statewide nonprofit organization that works to preserve our natural resources, maintain and revitalize our existing communities, protect historic resources, and assure efficient and effective transportation choices for all citizens.

I.  Transportation

                   A. Regional Road Capacity Expansion

The plan includes recommendations to increase capacity on regional roads in order to accommodate through traffic and reduce through traffic on local roads.

Empirical evidence from throughout the country and in Maryland proves that expansions of highway capacity induce demand for travel by making it easier for people and businesses to move further from developed areas, resulting in even more congestion on wider roads. On I-270, for example, "The highway administration reported that the 1997 volume at Route 28 in Rockville was 193,000 vehicles a day – 2,000 more than the 2010 projection. The volume at Interstate 370/Sam Eig Highway in Gaithersburg was 171,000 vehicles a day – 10,000 more than was forecast." (Washington Post, 1/4/99) Similarly, seven months after the opening of Route 100, there was a proposal to widen this road.

Outlook 2020, the Baltimore Region Transportation Plan, also proves that road expansions will not alleviate congestion—congestion is expected to occur on many regional corridors despite significant investment in highways, transit and other transportation programs. An expensive proposition, capacity expansion will only increase Howard County’s economic responsibility for maintenance and safety patrols on roads primarily used for through traffic (up to 82% of traffic on regional roads in Howard County is through traffic).

The Howard County General Plan should state that Howard County will work to implement, either locally or regionally through the Transportation Steering Committee, all reasonably available Transportation Control Measures before expanding regional road capacity on I-70, I-95, US 29 and MD 32. Examples of such measures are listed below, but they include land use and transit strategies, taking full advantage of state and federal "Commuter Choice" tax incentives, value pricing of highways, and upgrading ridesharing programs.

Highway investments should focus on safety improvements, as identified as a
priority in the "Rural West," (page 3-10 & 3-11). We recommend the County
focus on safety improvements that incorporate traffic calming measures, and
fully include bicycle and pedestrian safety, over capacity expansions on MD
32.

B. Transportation Control Measures

The region needs to invest in solutions that minimize demand for traffic. The counties have dominion over some of the most potent solutions—land use strategies, and they also have significant influence in strategies adopted by regional planning bodies such as the Transportation Steering Committee. Howard County can best address congestion by:

increasing the concentration and mix of land uses in population centers;
increasing land preservation in rural areas;
working at the regional level to promote complementary land policies in other jurisdictions;
working at the regional level, through the Transportation Steering Committee and National Capital Region Transportation Planning Board, to develop a multi-modal transportation plan that is truly integrated with land use;
working at the regional and local levels to implement a comprehensive transportation demand management program that includes taking full advantage of state and federal "Commuter Choice" tax incentives and "value pricing" on highways; (Consideration of highway value pricing strategies could be coordinated with an MDOT study on the subject currently underway.)
removing proposals to add HOV lanes; and
strengthening ridesharing by joining WashCOG’s Commuter Connections.

Although the plan does touch on the connection between land use and transportation, it should strengthen the connection and recommendations. For example, it should be made clear that a transit system is less effective (and less likely to be funded) if it serves low-density areas.

C. Through Traffic on Local Roads

The plan concludes that the best way to prevent through traffic from using local roads is to expand regional highway capacity (p. 3-10). Capacity expansion, as noted above, ultimately increases demand for the expanded roads, and there is no proof that expensive highway expansions will keep through traffic off of local roads. Traffic calming, which the county refers to as a secondary strategy, does reduce the ability of automobiles to speed through neighborhoods and thus creates a very definite disincentive for use of neighborhood roads by through traffic, while also providing environmental, pedestrian, bicycle, aesthetic, and safety benefits.

The county also needs to stop believing that it has no control over through traffic (p. 4-20). By revising local land use regulations in Howard County and working with other jurisdictions to revise their land use regulations to ensure more compact, transit-friendly development and land conservation, Howard County can reduce through traffic.

D. Transit Funding

The county uses an excise tax on commercial development (p. 4-19) to help pay for road construction but only recommends exploring new sources of funding for transit. The county should commit to using some, if not all, of the excise tax for alternative modes of transportation, including bicycle and pedestrian facilities.

The county should consider connecting via light rail to Baltimore City. Light rail, coordinated with transit-oriented development, can help to address congestion, affordable housing, and economic development issues.

We support Howard County’s commitment to funding for and expansion of the Howard Area Transit System (HATS).

II. Economic Development

The plan notes that Howard County has entered into a Memorandum of Understanding with surrounding jurisdictions (counties and municipalities) to encourage information sharing about infrastructure needs (page 2-6). Howard County should push, through the Transportation Steering Committee, for jurisdictions to share information about economic development and related land use plans. Such cooperation will help begin to address economic development at the regional level. Competition between counties for retail development results in vacant stores and blighted conditions in commercial centers. Arundel Mills Mall is a prime example of a development with regional economic implications. Neighboring jurisdictions, including Howard County, will have to brace themselves for a cycle of disinvestment and revitalization in response to the new super-regional center. The jurisdictions of the region need to devise a regional economic development strategy that prevents jurisdictions from undercutting one another and instead focuses on helping the region to compete in the global economy.

III.  Land Preservation

The plan does not sufficiently address the need to preserve land in Western Howard County. Based on current zoning, western Howard County can still accommodate over 5,000 additional homes and land can be developed at approximately one unit for every 4.25 acres. Despite the reasonable progress of Howard County’s rural clustering program, the program does not help to conserve contiguous open space sufficient to sustain environmental habitat or agricultural activities.

The only possibility for preserving rural resource lands (e.g. blocks of productive agricultural and forest lands) in western Howard County is to create a transfer of development rights system that downzones the West to 1du/20 acres. Public input could help define receiving areas for the development that ideally would be defined growth areas around older towns and corridors.

Zoning that permits 1 unit per 20 acres would better protect the environment, enable agricultural activities, and reduce demands on infrastructure and services in western Howard County.

Downzoning of the West is also important from a water quality protection perspective. A Maryland Office of Planning study showed that current build out trends in the West will spread degradation of Patuxent River subwatersheds. The same study showed that redirecting growth to the East will contribute to protecting most rural subwatersheds in the West (see: Smart Growth Options for Maryland's Tributary Strategies" Maryland Office of Planning, 1998).

  1. Environmental Protection

The plan recommends that the county "Coordinate with the Maryland Department of the Environment to ensure implementation of any future amendments to septic system regulations to promote nitrogen removal." The county should commit to working with MDE and the Office of Planning to refine, pass, and implement statewide legislation that requires nitrogen removal technology on all new septic systems in sensitive areas.

In the section on Working With Nature, there is a recommendation to "Prepare comprehensive watershed management plans for each of the major watersheds in the county to guide efforts to protect restore and improve the county’s water resources." The county should commit to change zoning in order to implement comprehensive watershed management plans.

V. Balanced and Phased Growth
    1. Fiscal Impact Scenarios
      2.

      The plan should provide more detail regarding the fiscal impact scenarios, including assumptions and factors contributing to revenues and costs. In addition, the county should analyze a series of scenarios that alter the character and location of growth, not just rate of growth.

      Base in-fill capacity on creating more compact, walkable communities that can be served by transit. Reduce parking requirements, and reconfigure parking lots, to save land, improve walkability and use an as incentive to developers.

    2. Affordable Housing
    1. The plan makes a good connection between affordable housing, economic development, and jobs access. However, the county should strive to incorporate affordable housing into new developments, in addition to maintaining affordable housing in older communities (p. 4-6). Given future needs for more diverse housing types and a limited supply of housing, including homeownership opportunities, much more aggressive action is needed. We recommend implementation of a program similar to the Montgomery County's Moderately Priced Dwelling Unit Program. Such a program should be applied to all new development, not just that occurring in the MXD District.
    2. Howard County discourages concentration of poverty by allowing multi-family communities with 20% subsidized housing to refuse to take additional Section 8 housing certificates. However, Howard County does need to ensure that the people holding the rejected Section 8 certificates have somewhere to turn.
    3. The plan recommends that the county establish a Live Near Your Work program similar to the State’s program in order to help lower-income individuals purchase homes near their employment. Howard County should also participate in the state’s program (p. 4-5).

3. Economic Development

The plan appropriately recommends intensification of economic development near transit nodes and services. Howard County should incorporate a residential component into this recommendation. (See section VI-1)

4. Sewer and Water

The plan recommends deferring shifts in sewer and water priority status for developments until they have received Adequate Public Facilities Ordinance (APFO) approval, instead of the current procedure, which allows properties to receive priority status based on submittal of a sketch plan for a development. The proposed change in procedure provides for a more systematic way of expanding sewer and water.

                   5. Transportation

Refer to section I of these comments.

  1. Community Conservation and Enhancement
    1. Mixed-Use

The plan recommends revising the zoning to encourage mixed use developments on US 1 and 40 and in existing communities. Older commercial corridors and some existing communities are appropriate locations for new mixed-use development based on their access to different modes of transportation and, in some cases, their existing mix of uses. The county should include the community as it drafts changes to the zoning code, however, to develop recommendations that reflect community needs and concerns, such as adequate provision of open space. The county should help communities to work proactively to achieve in-fill development that best serves their needs.

We urge the county to consider zoning changes to better use underdeveloped land to create new housing opportunities and pedestrian-friendly environments. The revitalization areas of Route 1 and Route 40 are a good opportunity to implement land use that supports pedestrian, bicycle, and transit activity.

2. Public Space

Public space is a critical component of health communities, both new and old, and the plan emphasizes this issue well.

                   3. Through Traffic and Traffic Calming

      See Section I

                   4. Corridor Revitalization

We support the proposal to revitalize Route 1 and Route 40 and recommend that the revitalization focus on targeted locations along the corridors. The location and design of new developments should maximize transportation alternatives and provide quality open space and a range of housing options. Moreover, the uses proposed for revitalization areas should be screened to ensure that they enhance the existing community rather than simply add new development to older areas of the county.

  1. Regionalism

The plan appropriately acknowledges of the importance of regional land use, transportation, environmental protection, solid waste management, and the farm economy. Discussion of regionalism should also highlight regional approaches to economic development. See comments on Economic Development (Section II).

The plan should also include specific action items to undertake with each of the jurisdictions in the Baltimore and Washington regions.

For further information, please contact Kristen Forsyth at kforsyth@friendsofmd.org or 410-385-2910.

 

 

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