Mr. Jeff Trulick
U.S. Army Corps of Engineers, Baltimore District
P.O. Box 1715
Baltimore, Maryland 21203-1715
Fax: 410-962-4698

Dear Mr. Trulick:

Please accept the following comments on the development called "Arundel Mills," proposed by the Mills Corporation of Arlington, Virginia (Application number 98-60874-10).

The Baltimore Regional Partnership ("the Partnership") requests that the entirety of the proposed actions, including parcel development and local, State and federal roadway improvements be assessed together, rather than segmented into pieces. The segmentation of environmental assessments of federal actions is prohibited by law.

The potential benefits and environmental, economic and social costs of the project have not been adequately assessed. The Partnership believes it is premature to make decisions sanctioning some of the environmental impacts required by the development proposal without a full assessment of cumulative effects of reasonable foreseeable future actions.

By definition ("super regional mall") and by design, at build-out this project will represent one of the largest single development projects in the history of the region.

The public perception of the permitting process is split into: cynicism – "this is a done deal, behind closed doors"; or naivete – government agencies scrutinize the whole project before allowing construction to commence. Neither of these perceptions are accurate: the U.S. Army Corps of Engineers can use its authority to cause the cumulative effects of the project in its entirety to receive the scrutiny it warrants.

The Baltimore Regional Partnership is composed of the Citizens Planning and Housing Association, Baltimore Urban League, 1000 Friends of Maryland, Environmental Defense Fund, and the Chesapeake Bay Foundation. Collectively, these organizations represent tens-of-thousands of citizens of the region which would be impacted by this development.

Sincerely,

Hank Goldstein, Executive Director

Appendixes: 2 pages

If built, the Mills project would add at least 75,000,000 vehicle-miles-traveled to the region per year, based on the developer’s projected target market and projected customer visits.

There is a shortage of "entry-level" workers in Anne Arundel County. Arundel Mills would have to draw its workers from long distances, ensuring that traffic and, and most likely congestion, increases. Neither the developer nor Anne Arundel County government have plans to provide transit to the proposal site.

The developer calls Arundel Mills a "super regional mall." This designation refers to how far away customers will be drawn from. "Super regional" widens the net out to about fifty miles in every direction, ensuring that traffic, and most likely congestion, would increase.

The proponents of the project assume a financial windfall for Anne Arundel County. According to sources in the County Executive’s office, most of the taxes generated for the County by the mall would be dedicated to pay for the bond that the County issues in order to build roads for the mall.

The U.S economy is currently experiencing a historically high rate of consumer spending. Consumer spending is the metric for determining supportable retail space – any downward fluctuation will increase the devastation of supportable retail space in the region. This would result in more consumers driving further distances to shop at Arundel Mills, and more abandoned retail space in the region.

Neither the Anne Arundel County Council, nor the Executive’s Office have performed a cost/benefit analysis to determine economic impacts of directing investments in infrastructure to other projects.

The bond issue for this project limits the County’s future borrowing capacity for other worthy projects and investments in infrastructure.

The projected benefits of the project include future phases – office space and residential components – not only the shopping mall. Yet, the permitting process evaluates traffic and congestion one phase at a time. The advertised benefits are greater than the analyzed costs.

If the mall is built, surrounding jurisdictions will experience tremendous negative impacts – loss of retail sales and gains in traffic and congestion – yet they have no voice in the permitting processes.

Except for assessment of the future value of real property, inputs to the analysis of projected income to the County, projected increase in VMT, trip generation, employment, and "spin-off" development have been supplied solely by the developer. No independent analysis of costs and benefits have been performed on any facet of the proposed project.