December 14, 1999

C. A. Dutch Ruppersberger, Chairman
Transportation Steering Committee
601 North Howard Street
Baltimore, MD 21201-4585

RE: Recommendations for revising the 2000-2004 Transportation Improvement Program

Dear Chairman Ruppersberger:

We commend the decision by the TSC to revise the 2000-2004 Transportation Improvement Program (TIP). As you are aware, members of the Baltimore Regional Partnership, along with many citizens, have expressed serious concerns about the TIP, amendments to the Baltimore Regional Transportation Plan (BRTP) and the conformity determination. We offer our assistance to the TSC’s efforts to make appropriate changes to the TIP, BRTP and applicable so that the region can continue to enhance mobility without compromising communities, public health and the environment.

As the TIP is now appropriately being reevaluated, we request that you reconsider our comments submitted previously. In addition, the members of the Baltimore Regional Partnership would like to offer the following recommendations for revising the TIP so that it meets both federal Clean Air Act standards, and the needs of the region’s residents and visitors for greater transportation choices.

In short, we recommend that the TSC: (1) adopt a package of innovative and substantial transportation emissions reduction measures; (2) adopt measures to improve the planning process; and (3) reorder the TIP projects based on how these projects will help meet air quality goals, address the needs of citizens and businesses for more travel choices, and manage travel demand. Below, please find our detailed recommendations for achieving these objectives.

1. Transportation Emissions Reduction Measures
   

1. Aggressively Market Commuter Choice Inventive Programs

Allocate two million dollars per year for marketing campaigns aimed at Maryland employers and employees to foster maximum adoption and use of commuter choice incentive programs. Adopt objectives of: by 2002 offer ninety percent of workers in transit- and van pool-served areas the opportunity to purchase transit/van benefits with pre-tax dollars; fifty percent of employers paying for or discounting transit passes for their employees using the Maryland transit tax credit; twenty-five percent of employers offering added cash income in lieu of a parking space; further increase these rates by 2005.

All member agencies of BMC will offer all their employees the opportunity to purchase transit and van commute benefits using pre-tax dollars by 2001, with fifty percent of these employees offered some added cash income in lieu of a parking space by 2002.

2. Establish "Cash-for-clunkers" program to purchase older, more polluting vehicles and retire them from use to eliminate their emissions.
3. Establish "Cash-for-tune-up" program to help selected low-income motor vehicle owners repair motor vehicles to good tune where cost-effective.
4. Establish "Fee-bates" and other incentives to encourage early adoption of Super Ultra Low Emission Vehicles (SULEVs), such as new hybrid cars, by Maryland motorists when these come on the market in the coming year.
5. Fully mitigate the anticipated emissions associated with the Arundel Mills Mall Project

                    f. Consider site plan modifications for improved urban design to reduce traffic

g. Mills Corporation and its tenants agree to offer cash in lieu of free parking to all employees, and free transit passes for all employees.

 

1. Show that the new TIP/RTP amendment does not worsen pollution problems, and mitigate the pollution increases related to the proposed project additions to the TIP/RTP with TDM strategies.
2. Incorporate 1996 or 1999 motor vehicle fleet data in the next SIP update and conformity analysis, and update the motor vehicle fleet data assumptions annually.
3. Report to the public annually on how well the regional travel model is able to represent measured travel patterns and trends, suspected or known shortcomings in the analysis process used to forecast traffic and emissions, and efforts underway to address these shortcomings with more policy-sensitive analysis methods. This should include discussion of the means used to evaluate how and when people choose to travel and how these choices may be affected by changes in traffic congestion, travel cost, and the characteristics of travel options, including the walkability of neighborhoods. It should also include a discussion of how Smart Growth strategies and travel demand management strategies have been considered in the planning process.
4. Commit to an evaluation for the next TIP/RTP a transportation, land use, and TDM incentives scenario developed by the Baltimore Regional Partnership and other stakeholders, with appropriate modeling to reflect changes in pedestrian access, pricing sensitivity, and other factors.
5. Commit to improving public involvement and information on equity impacts of the next TIP/RTP.
6. Commit to a wide exploration of reform measures designed to integrate land use and transportation and air quality decision-making, and a full discussion with the public about such measures.

Year            Current Fed         Current Match        Proposed Fed     Proposed Match

FY 2000      20,993,000        5,248,000                 20,993,000            5,248,000
FY 2001      20,000,000        5,000,000                 32,000,000            8,000,000
FY 2002      20,000,000        5,000,000                 32,000,000            8,000,000
FY 2003-4  40,000,000      10,000,000                 33,247,000            8,312,000
Future          17,247,000        4,312,000

Total          118,240,000      29,560,000               118,240,000          29,560,000

Year        Current Fed     Current Match      Proposed Fed      Proposed Match

FY 2000                                                      400,000                  100,000
FY 2001                                                      800,000                  200,000

Total                                                         1,200,000                  300,000

3. MTA Transit Bus Replacement (#40-9904-05) - CMAQ

Three Federal funding sources are used to finance bus replacements, two FTA categorical grant sources, Sections 5307 and 5309, and CMAQ funds, which can be used for a wide variety of projects to reduce emissions. In addition to bus replacement, the CMAQ funds are also used for the State CHART program which monitors traffic incidents on major roadways. Transit bus replacement, however, is a much more appropriate use of CMAQ funds than CHART, which could be funded under the National Highway System (NHS) funds, which is more directly related to highway operations. The relationship between highway incident management and emissions reductions is very indirect, and is predicated on the vague assumption that higher highway speeds will result in cleaner air. Not only is this categorically untrue for NOx emissions, it also ignores the relationship between highways and induced travel. Using CMAQ for bus replacement not only improves air quality directly by supplying newer and cleaner vehicles, it also results in a better, more reliable and more attractive transit system which will attract new riders. The following proposal diverts CMAQ funds from CHART to the MTA bus replacement program:

FY 2000     4,520,000      1,130,000             9,935,000          2,484,000
FY 2001     1,792,000         448,000             7,207,000          1,802,000
FY 2002     1,452,000         363,000             6,867,000          1,707,000
FY 2003-4  2,936,000        734,000            13,766,000          3,442,000

Although we are unable to estimate precise costs, we recommend acceleration of bus funding to (1) improve the bus replacement cycle to 80 buses a year, (2) use replacement buses that are the least polluting feasible technology that is operationally practical, to support timely attainment of Clean Air Act air quality standards and to address concerns related to exposure of community residents to air toxics from bus exhaust.

4. ITS Early Deployment Study (#00-9601-00)

The Intelligent Transportation Systems "Early Deployment Study" has been an ongoing attempt sponsored by BMC to integrate and develop ITS systems across the lines of jurisdictions and transportation modes. Unfortunately, the study has been very one-sided in favor of the automobile, declaring "incident management" on major roadways as the major priority. Meanwhile, the MTA has been working on ITS measures for transit virtually alone, mostly outside the ITS study structure, and without the benefit of the specific capital funding shown here.

Despite this, the MTA has made major progress in their ITS program, particularly the Automatic Vehicle Locator system and electronic user information kiosks. It is proposed that the MTA’s activities be fully integrated into the ITS Early Deployment Study, and that the priorities of the study be modified to achieve a balance between highways and transit

FY 2000     150,000            38,000                 (No Change)

5. Provide increased transit operating assistance:
   

1. Provide transit operating funds to implement MTA 6-Year Bus Plan over 3 years instead of 6.
2. Provide operating funds necessary to plan for and implement "Route Action Plans" on 5 major bus corridors in the region over the next 5 years. Route Action Plans provide a coordinated method of balancing the competing demands of the different uses of the routes. Application of traffic calming, transit improvements, pedestrian safety, and urban design techniques to these routes will serve to improve bus journey times and reliability, improve environmental conditions, and reduce congestion.
3. Implement downtown "fare-free" zone for MTA bus system.
4. Increase funding of locally-operated transit services by 25% over 3 years.
   

Thank you for consideration of our proposals, we look forward to working with you to meet the challenge of crafting a TIP that conforms with health-based federal air quality standards and provides better mobility for the diverse needs of our region’s residents and businesses.

Sincerely,