Ms. Pamela S. Stephenson
Federal Highway Administration
The Rotunda- Suite 220
711 West 40th Street
Baltimore, Maryland 21211

Re: Project Number HO756B11 (Maryland Route 32 From MD 108 to I-70)

Dear Ms. Stephenson:

In accordance with the National Environmental Policy Act (NEPA) and Section 309 of Clean Air Act, EPA has reviewed the subject Draft Environmental Impact Statement (DEIS) concerning the proposal to widen MD32 in Howard County, Maryland. The proposed project would expand the existing two lane highway to a four lane controlled access divided expressway. Based on our review of the DEIS, we have assigned a rating if EC-2 (Environmental Concerns and Insufficient Information) due to the potential impacts to aquatic resources. A copy of EPA’s ranking system is enclosed for your reference.

Based on information received from the Chesapeake Bay Foundation, we understand that the Maryland Department of Transportation is concerned that this project may be inconsistent with Maryland Executive Order 01.01.1998.04 on Smart Growth and Neighborhood Conservation Policy. The EPA is concerned that the proposed project may promote development in open lands outside the designated Priority Funding Areas (PFAs). As you know, Maryland’s Smart Growth Areas Act of 1997 is intended to direct development to existing towns, neighborhoods, and business areas by directing State infrastructure improvements to these places. We are concerned that the approval of this project as it is currently described in the DEIS could be counter to the Maryland Transportation Plan of serving designated growth areas and reinforcing locally defined limits on development outside designated growth areas. We are primarily concerned with the secondary and cumulative impacts associated with the increased access provided by the proposed project, including induced development and other land use issues.

EPA believes the a reevaluation of upgrade alternatives is warranted due to the concerns of the Maryland Department of Transportation and the Chesapeake Bay Foundation. We suggest that you investigate a number of the following improvements, including the addition of a center left turn lane, intersection improvements, access controls, and other minor roadway improvements. We believe that the enhancement of the existing highway may meet the project’s purpose and need while considerably reducing impacts. In particular, the improvements to the existing highway would help to minimize impacts to palustrine forested wetlands, shrub/scrub wetlands, emergent wetlands and watershed quality.

Thank you for the opportunity to comment on this proposed project. We look forward to working with you to resolve our concerns. If you have any questions regarding our comments please feel free to contact me at (215) 814-2726.

Sincerely,

Denise M. Rigney
Transportation Program Manager