In order to pay for the $910 million total
20-year cost for these projects, we propose deleting from the Plan several
expensive, counter-productive highway projects, including the proposed
expansion of MD 32 from Clarksville in Howard County to Eldersburg in
Carroll County ($207 million), the proposed Westminster outer-bypass ($200
million), and the proposed HOV-2 lanes on I-95 both north and south of
I-695 ($209 million). Deletion of these three projects would generate $616
million savings. Further savings can be realized by pruning other
sprawl-inducing highway projects from the Plan. (See item 4, below.)
Our very preliminary estimate is that
implementation of High Occupancy Toll lanes on all major freeways in the
Baltimore region by 2010 could generate added net revenues of $100-200
million a year that could support improved transit, better road
maintenance, and enhanced information and congestion reduction services as
well as reductions in general tax support (property or sales taxes) that
now subsidize transportation. These net cumulative revenues from High
Occupancy Toll lanes by 2020 could amount to $2 billion.
Presented below are the three major
projects we recommend for deletion from the Plan, followed by a brief
discussion of 10 other sprawl-inducing projects that should be
reconsidered.
1. MD 32 from Clarksville, Howard
County, Cost: $207 million
to Eldersburg, Carroll County
The two lane section of MD 32 is slated
for upgrade from two to four lanes for 16.9 miles from MD 108 at
Clarksville in Howard County to MD 26 at Eldersburg in Carroll County.
This project should be dropped because it violates the principles of Smart
Growth and will induce added sprawl and traffic growth.
MD 32 has been upgraded through a series
of improvements which have resulted in a major expressway corridor from
Clarksville (beyond Columbia to the west) to Annapolis. Essentially, MD 32
serves as an outer beltway for both the Baltimore and Washington suburbs.
Motorists have discovered that it now takes less time to get from
Clarksville to Annapolis in rush hour than it does to either Baltimore or
(especially) Washington.
North of Clarksville, MD 32 traverses
Howard County's agricultural district. It remains a two lane roadway, but
access is well controlled, and travel speeds of 60 miles per hour or more
are typical. This has made the area beyond Clarksville to the north and
west in Howard County a favorite location for sprawl. New $300,000 to
$500,000 houses on large lots are not uncommon. Development is now
extending even further westward along the 1-70 corridor toward Cooksville,
Lisbon and Mount Airy. It is also extending northward toward Sykesville
and Eldersburg in Carroll County. These areas used to be regarded as too
remote from Baltimore to be candidates for significant urban sprawl.
However, they are not too far from Columbia, Fort Meade and Laurel, all
growing employment centers in Howard County. The proposed expansion of MD
32 would accelerate development of bedroom communities in Carroll County
for people working in Howard County who cannot afford the high cost of
housing in the latter.
The BMC/TSC analysis shows no congestion
in this corridor through the year 2020, with or without the proposed
projects. This is perhaps due to
the fact that the road already has excellent access control, as well as
extensive widening beyond the basic two lane section at the major
intersections at MD 144, I-70 and MD 26. The very low density of
development in Howard County's agricultural district is probably also a
factor.
The congestion effects of the sprawl
development along the MD 32 corridor will likely emerge instead at more
remote locations, most notably on I-70 and US 29. It is difficult to see
how some of these problems can be solved except by managing traffic and
growth patterns and expanding travel options in Howard County. I-70
already has three lanes in each direction between US 29 and I-695 (the
Baltimore Beltway). No widening is proposed, because the I-695 interchange
is considered a permanent bottleneck that restricts any capacity increase.
2. The Westminster Bypass Cost:
$200 million
The Plan calls for construction of a new
four lane road, 6.89 miles long -- the Westminster "outer"
bypass. This project should also be dropped because it violates the
principles of Smart Growth and will induce added sprawl and traffic
growth.
Westminster is the geographic center,
county seat, largest community and "heart" of Carroll County,
and consists of a very old and attractive traditional town center,
surrounded by newer developments and sprawl. Almost every major road in
the entire county leads to Westminster. It has a unique opportunity to
take advantage of its small scale traditional core and its large scale
growth opportunities at the same time.
Surrounding Westminster to the east and
north is a four lane divided bypass highway (MD 140) which has attracted
much highway-oriented strip development. This development and the lack of
access control on MD 140 have resulted in congestion. Recently,
significant development has begun to leap beyond the MD 140 corridor into
the outer countryside.
There are three projects in the
"preferred alternative" of the long range plan to alleviate this
congestion. A widening of MD 140 from its existing four to six lanes to
eight lanes, the construction of a new four lane outer bypass beyond the
existing MD 140 bypass, and a widening of MD 97 for 2.73 miles beyond the
bypasses to the northwest toward Union Mills and Gettysburg.
Efforts to maintain the vitality of the
old core of Westminster have had some success, emphasizing its inherent
historic charm. The existing MD 140 bypass is close enough to the town
center so that each can feed off each other's strengths. The bypass
provides welcome traffic relief to the town's main street as well as
"back door" access, while the highway-oriented businesses retain
some of the identity of old Westminster rather than appearing to be
"placeless." There has also been a steady upgrade in the quality
of businesses along MD 140, with marginal uses being steadily replaced by
more prosperous ones.
The challenge for Westminster is to
enhance its locational advantage by replacing the car dealer lots and
convenience stores in key locations with more productive employment and
tax revenue intensive uses. This can be accomplished without causing
serious congestion by emphasizing mixed-use development and traffic and
demand management improvements (including access management) on MD 140, by
creating incentives for attracting new development into the adjacent town
center, and by strengthening land use controls in the surrounding
countryside.
The proposed Westminster bypass creates
the following problems:
Congestion.
On paper, building the proposed roadways would solve traffic congestion
problems, but the traffic operational problems would be formidable. At the
south end of the proposed projects, at Reese Road, the proposed eight lane
MD 140 and four lane bypass (total of 12 lanes) would have to achieve a
transition back into the existing four lane section of MD 140 toward
Baltimore. In practice, this would cause serious congestion.
The planned upgrade of existing MD 140 in
Westminster, for which start-up construction funds have already been
committed, reinforced by demand management can take care of future
congestion problems. (MD SHA projects only two failed intersections on
this segment of MD 140 by 2015 and that is without instituting more
effective demand management.)
Impact on established communities.
A new outer bypass would draw new commercial
and residential development away from both the historic town center and
the existing bypass. The current trend of upgrading the businesses along
the bypass would be curtailed.
Pressure on resource lands. The
proposed bypass is outside Carroll County's designated growth area for
priority funding under the state's "Smart Growth" law and its
construction would intensify development pressure on farmland north and
west of Westminster. Thus far, MD SHA's analysis of alternatives for
improving MD 140 and the proposed Westminster bypass has focused on the
proposed bypass's primary impacts, that is, impacts of highway
construction. This limited analysis reveals that the proposed bypass
traverses a mine-field of sensitive resources -- historic and ecological
(wetlands and bog turtle habitat) in addition to farmland. But the
proposed bypass's secondary impacts are far more threatening than its
primary ones.
In its Atlas of Agricultural Land
Preservation in Maryland, the Maryland Office of Planning reports that
all of Carroll County's farm land is under "significant development
pressure," the county's agricultural zoning is only "moderately
protective," sizable development areas permeate its agricultural
areas, many of its easements are surrounded by land that shows significant
development pressure, and " the northern tier of Baltimore and
Carroll counties... forms a large contiguous area of farm land, even
though much of northern Carroll shows significant development
pressure." (pp. 17 and 18)
1990 commute patterns show that half the
people commuting to jobs outside Carroll County were going to jobs in
Baltimore County and Baltimore City (Baltimore County --39.2%; Baltimore
City -- 18.9%) along MD 140 and I-795. Commute time, not distance, is the
controlling limit on how far away people are willing to live from where
they work. Expedited access around Westminster will invite people looking
for middle-income housing to drive further, going around the City of
Westminster and putting pressure on resource lands in northern Carroll
County. Limited access along the proposed bypass can control strip
commercial development but will not diminish pressure to subdivide
resource lands.
3. I-95 HOV-2 expansion north and
south of I-695. Cost: $209 million
The Plan calls for widening I-95 north and
south of the Baltimore Beltway. These projects would spur further growth
in traffic while missing strategic opportunities for inter-city travel
demand management. They should be dropped from the Plan and replaced with
multi-modal corridor studies that consider a broad array of options for
more efficient use and management of travel in this economically vital
corridor. These corridor studies should be accomplished through extensive
coordination with the Metropolitan Washington Council of Governments,
Wilmington’s Metropolitan Planning Organization and the Delaware Valley
Regional Planning Commission, the North Jersey and New York Metropolitan
Planning Organizations, and their member agencies, plus Amtrak, freight
carriers, and stakeholders in the air traffic industry.
The proposed I-95 HOV expansion north of
I-695 in Baltimore and Harford counties appears to be an re-enactment of a
High Occupancy Vehicle (HOV) expansion several years ago when this same
section of 1-95 was widened from 6 to 8 lanes. That project was planned
and built in the name of providing new HOV lanes, and its completion was
accompanied by "HOV Future" signs over the left lane of the
roadway. Those signs were later removed. It can be presumed that the
present proposal for a further "HOV" expansion on I-95, both
north and south of I-695, may serve the same ultimate objective of
widening I-95 for single-occupant vehicles. If two more lanes were
added for HOVs, the existing eight lanes would all essentially be
allocated for single occupancy vehicles - a total peak hour capacity of
over 8000 single occupant vehicles in each direction.
Expanding I-95 for HOV is the wrong
approach. Widening 1-95 with HOV lanes would spur additional long-distance
passenger and freight travel by modes that are the least efficient and
most polluting in a corridor that is a severe ozone non-attainment area,
spurring further growth in Vehicle-Miles Traveled and sprawl. This would
delay timely attainment of the National Ambient Air Quality Standards and
hence increase the threat to public health posed by growing motor vehicle
use in the Baltimore region.
The I-95 corridor already offers
multimodal options unsurpassed in most other parts of America. I-95,
itself, should not be widened without first undertaking investments in
these alternative transportation facilities and before managing travel
demand in the corridor.
A cooperative I-95 corridor study should
evaluate: (1) the potential for take-a-lane (and combinations of
add-a-lane and take-a-lane) High Occupancy Toll (HOT) and other toll
incentives that vary by time of day and that include high-speed automated
electronic toll collection (replacing fixed toll collection facilities)
throughout the corridor; (2) improved MARC and Amtrak services, including
150+ mph high speed rail in the Washington - Baltimore - Wilmington
-Philadelphia - New York City corridor; (3) increased investment in
intermodal truck-rail-sea freight facilities in the corridor; (4) tolls
that vary by time-of-day for heavy trucks on 1-95; and (4) improved
pedestrian, bicycle, bus, and shuttle access to rail stations and transit
centers in the 1-95 corridor. This analysis should not assume fixed
external travel demand at the boundaries of the Baltimore metropolitan
region, but recognize that changes to the level of service and cost of
competing long-distance travel modes in this corridor will affect travel
demand entering and exiting the Baltimore region on 1-95, as well as
affecting intraregional travel. This study should consider the potential
land use impacts of alternative transportation investment and management
strategies.
The New York Thruway Authority in July
1997 instituted time-of-day tolls on the Tappan Zee Bridge for trucks.
Early results suggest that these time-of-day tolls are having a
significant positive effect on truck traffic patterns in the corridor.
Pennsylvania and New Jersey plan time-of-day truck toll innovations as
well. This innovation should be extended into the Baltimore portion of the
1-95 corridor. Analysis of high-speed rail in the Northeast corridor by
various analysts in recent years suggests that improvements in Amtrak
service could reduce long-distance traffic on 1-95 as well as reducing
greenhouse gas and air pollution emissions and airport congestion by
reducing growth in short- to mid-range distance air traffic demand in the
northeast corridor. The experience of I-15 in San Diego and SR-91 in
Orange County, Ca, suggest that High Occupancy Toll lanes could provide an
important means of managing traffic congestion in the I-95 corridor while
generating revenues that might be used effectively to improve public
transportation options. High speed electronic toll collection techniques
combining EZ-Pass/FasToll technology with license plate imaging for those
without electronic toll tags, as successfully demonstrated on the E-407
expressway outside Toronto could readily be applied to I-95 in the
Baltimore region.
4. Other
Sprawl-Inducing Projects in the Plan
US 1 Belair Bypass - MD 147 to US 1 $25,488,000
(Harford) The current two-lane bypass has
excellent access control and does a very good job of diverting through
traffic from the town of Belair. Widening the bypass to four lanes would
simply allow it to be a purveyor of sprawl to the northern and eastern
portions of Harford County.
MD 2: Virginia Avenue to MD 214 $20,456,000
(Anne Arundel) This roadway just south of
Annapolis is the gateway to Southern Maryland, and to the sprawl which
would follow any widening.
MD 97: MD 140 to MD 496 $12,367,000
(Carroll) This roadway is the gateway to
northwestern Carroll County and the path of sprawl development north of
Westminster.
MD 145 Paper Mill Road relocated: MD 145
to MD 45 $ 9,764,000
(Baltimore County) This is essentially an
eastward extension of Shawan Road from Hunt Valley
to the Loch Raven Reservoir area, to
accommodate further sprawl to the east in the vicinity of
Phoenix and Jacksonville.
US 29: South of MD 175 to Montgomery
County $99,185,000
(Howard) This section of US 29 already has
more through-capacity than the Montgomery County portion of the corridor
ever will, unless the Inter-County Connector is built. In that case, this
project will serve to make Howard County a bedroom community for the
Rockville-Gaithersburg Corridor.
MD 26: MD 32 to MD 97 $19,022,000
(Carroll) This is a widening of Liberty
Road ever farther out into western Carroll County and is a blatant
sprawl-maker.
MD 152: MD 147 to APG-Edgewood area $37,945,000
(Harford) The parallel MD 24 corridor has
been the one designated for growth in Harford County, but congestion in
that corridor has led to this proposal as a type of bypass route. However,
MD 152 has already been widened at the critical capacity-constrained
locations (1-95, US I and MD 147) so further widening would add little to
the capacity of the corridor, but would do much to promote
capacity-robbing sprawl. The southern end of this project between 1-95 and
Aberdeen Proving Ground may be an exception, where further widening may be
compatible with smart growth.
1-695 (HOV-2): 1-95 to 1-95 (north side) $93,061,000
(Baltimore County) This HOV project widens
the Beltway from 8 to 10 lanes, while there is a separate project entry to
widen most of the Beltway from 6 to 8 lanes, without HOV consideration.
This departs from standard planning procedures. The conventional rationale
is that HOV designation cannot take place until (a) new lanes are added,
and (b) congestion then rises to a certain threshold level that justifies
the HOV lanes. In this case, the planners are stating that we have to wait
even longer for (c) widening to provide even more new lanes, and (d) still
more congestion to again attain the required congestion level. In other
words, two cycles of widening followed by congestion instead of just one.
A much more direct alternative would simply be to implement the HOV lanes
now, skip the two widening cycles, and save a few hundred million dollars.
This corridor would be an ideal candidate for early consideration of HOT
lanes in the Baltimore region, which might be introduced using currently
programmed or in-process lane expansions.
MD 543: I-95 to MD 136 $
8,127,000
(Harford) The best place to concentrate
growth is in the immediate vicinity of an expressway interchange or
transit station. The infrastructure at 1-95's newest interchange at MD 543
in Abingdon has already been constructed to do just that. This project
would simply allow for the dissipation of that growth northward away from
the MD 543 interchange.
Marriottsville Road: MD 99 to MD 144 $11,370,000
(Howard) This roadway straddles 1-70, and
currently has a half diamond interchange. The missing ramps are also
proposed. This project would expand the reach of the interchange well
beyond the immediate area.
THE PLANNING PROCESS
These comments address the planning
process conducted by the Transportation Steering Committee, as described
by the TSC in Outlook 2020 and as we experienced it over the last year.
1. Guiding Principles
The Plan summarizes the role of its
guiding principles as follows: "The Plan envisions a twenty first
century transportation system that meets the region's needs, moving people
and goods in an efficient manner. Toward these ends, the Plan is founded
on four guiding principles..." Each of these is addressed below.
Principle #1:"Linking
transportation to managing growth. This means giving priority to
transportation projects and programs planned by local jurisdictions for
existing and designated growth areas. Projects and actions should support
redevelopment and new growth through congestion and access management,
while retaining community character and respecting the planned pattern of
development."
As noted in our critique of project
selection, we conclude that many of the Plan's proposed highway projects
will encourage sprawl, with its usual harmful effects of converting
resource lands to development, sapping established communities of
vitality, and increasing vehicle-miles traveled. Accordingly, we are not
able to perceive, on balance, how the Plan forges a constructive link
between transportation and growth management.
With respect to this linkage the Plan
explains, "This means giving priority to transportation projects and
programs planned by local jurisdictions for existing and designated growth
areas." Each local jurisdiction designates its growth areas with
little or no attention to impacts on neighboring jurisdictions or on
regional patterns of development. Connecting each locally designated
growth area with every other one in the region would result in a maze of
criss-crossing potential rights-of-way that, if developed for highways or
transit, would have a negative impact on most, if not all, locally
designated agricultural districts in the region, sensitive ecological
resources, historic sites, and many established communities. Of course,
the Plan does not propose to use each of these potential rights-of-way,
yet it provides no clarification of how, if at all, the TSC applied this
guideline to project selection.
The Plan's vague expression of deference
to local plans contrasts with the 1995 recommendations of the TSC's own
Land use Subcommittee. The subcommittee concluded that the lack of
coordination among local jurisdictions and between transportation and land
use planning and the absence of a unifying vision are major problems for
the region. It made the following recommendations to local governments,
the BMC, and the TSC for addressing them:
The local jurisdictions should work
together to support regional coordination of land use and
transportation planning and, in particular, in the development of a
regional vision. The historic practice of developing independent
visions for the benefit of the individual jurisdiction, at the
possible expense of the Region as a whole, must be replaced with an
outlook based on the goals of ISTEA, CAAA, and the Maryland Planning
Act. (p. 51)
.... The involvement of the Local
Planning Directors in a continual land use coordination effort is a
key to the success of a regional vision. The role of land use planning
should be elevated to "full partner" with transportation
planning in the TSC mission and work program...(p.54)
Principle #2:
"Improving life in our communities. This means giving priority to
transportation projects that reduce air pollution. Projects should
contribute to the environmental and aesthetic quality of communities
in both their scale and design."
"Improving life in our
communities" is a laudable goal. But it is so broad and potentially
all encompassing that the TSC's interpretation of what it means becomes
all-important. The TSC's emphasis on air quality is good as a starting
point, but the Plan's heavy emphasis on building expanded highway capacity
for single-occupant vehicles and its lack of attention to demand
management raise questions about how this specific concern was used to
guide development of the Plan.
The Plan should say something that
acknowledges the immediate impacts on specific communities that
transportation projects may have. These are suggested by the following
passage from the newsletter of the Harford Road Partnership in northeast
Baltimore:
Harford Road was once our main street.
Over time, the road was widened to accommodate more cars at greater
speeds. The effect was less pedestrian activity, the loss of local
markets, and less visibility for the small businesses that remained.
Once the street served as a unifying element, knitting the
neighborhoods together and creating a community. (Spring 1997)
As the TSC's Citizens Advisory Committee
has commented, "...the Plan says virtually nothing about how the plan
will affect the quality of life. In its 1995 report on Growth Management
and Transportation, BMC (Land use Subcommittee) included a delightful
excerpt from the Portland, Maine Transportation Plan explaining the
tremendous degree to which transportation can shape our daily lives. But
nothing of this sort is applied to the current recommendations. All of the
projects are presented in a cold and abstract manner ..." that
obscures their pervasive influence on our quality of life.
Principle #3:
"Increasing transportation choices. This means giving priority to
projects that increase the variety of options for making a trip,
including bringing public transportation to more citizens and
businesses, additional highway routes as appropriate, facilitating
bicycling and walking, and fostering trip-elimination options such as
telecommuting.
The Plan's proposed allocation of
resources and project selection are heavily weighted towards expansion of
highway capacity and fixed transit services, while starving other
alternatives. Our proposed re-allocation of these funds reflects our view
of what the Plan could, and should, do to "increase the variety of
options for taking a trip" for people living in and visiting the
region.
Principle #4
:
Maintaining the current system. This means giving priority to
protecting the existing investment in our transportation system.
Projects such as resurfacing, safety improvements, bridge
rehabilitation and reconstruction, and new transit vehicles are
essential to this effort.
The Plan allocates 52% of its resources to
system preservation and 23% to operating cost, consistent with historic
levels of support for operation and maintenance. We agree with the Plan’s
emphasis on maintenance and strongly support the principle that we should
"fix it first", i.e., maintain the transportation system we have
before further expanding capacity.
In summary, we think the Plan's four
guiding principles are sound. However, with the exception of emphasis on
system maintenance, we do not see them reflected in the Plan's Preferred
Alternative. We see little evidence in the Plan that the TSC gave serious
consideration to congestion management, retention of community character,
respect for planned patterns of development, or increasing transportation
choices. As reflected in our discussions of the proposed expansion of MD
32, the Westminster bypass, and HOV expansion of I-95 and our
identification of 10 other sprawl-inducing highway projects, the Plan
seems first and foremost to embody the discredited notion that the
Baltimore region can build its way out of congestion and that highway
projects are to be evaluated in narrow terms of level of service and
safety. The TSC would have produced a better plan if it had taken more
seriously both its own guiding principles and the recommendations of its
Land Use Subcommittee.
2. Goals, Policies, and Strategies
In addition to the four guiding
principles, the Plan articulates five goals, 18 policies, and 53
strategies. Substantively, they cover a broad front and we have only one
additional policy to propose for inclusion. Under the goal of
"accessibility" Policy 2 directs enhancement of "mobility
options for the young, the elderly, the disabled, and the economically
disadvantaged through the Plan." We recommend that this policy be
expanded and strengthened to assure that equity is served by assigning
sufficient funding to projects that benefit "the young, the elderly,
the disabled, and the economically disadvantaged." We further
recommend that the Plan explicitly incorporate compliance with Title VI of
the Civil Rights Act as a goal and as a policy, and that it focuses
attention on the equity impacts of the regional transportation system. To
provide an example, the Plan should evaluate how the benefits and costs of
the Plan are distributed by income group, race, and sex with particular
focus on accessibility to jobs and other opportunities. Explicit emphasis
should be given to improving access of low income communities of color to
the region’s job opportunities.
Operationally and procedurally it is
difficult to understand how the TSC applies the Plan’s diverse goals,
policies, and strategies to project selection and resource allocation. The
specific projects we have criticized, above, all conflict blatantly with
several policies and goals articulated in the Plan, yet they survived the
TSC's screening process. Perhaps, the TSC found that each of these
projects is supported by one or more of the Plan's other goals or policies
and that this support outweighs their manifold conflicts. We have no way
of knowing. The process is inscrutable. All the Plan reports is, " Of
the 152 projects on the candidate list, 57 projects were assigned a high
policy-level rating and 27 were assigned a medium policy-level
rating." Without further clarification by the TSC we are left with
the impression that either the goals and policies were disregarded during
the project selection process or that the TSC can find within their midst
a basis for justifying any conceivable project proposed by a sponsor.
In spite of the request we made last
November in our comments on the first draft of the Plan, the revised draft
fails to disclose any information on the criteria or process that govern
elevation of projects from the Plan to the Transportation Improvement
Program.
In the sections on project prioritization
and policy evaluation, the Plan lumps all Transportation Demand Measures
together in a generic discussion of the "priorities (that) were used
to guide selection of TDM strategies to be included in the Plan."
(p.94) These priorities include: flexibility, coordination and cost
control. TDM Initiatives should have an additional explicit criteria:
that, together with the transportation investment and land use plan, they
allow the region to meet a travel demand reduction goal, such as reducing
per capita Vehicle-Miles Traveled by 10% by 2020. The potential for some
TDM strategies, such as High Occupancy Toll lanes and parking
management/pricing, to generate additional revenues should also be
evaluated and incorporated in fiscal constraint discussions of the plan.
In light of the low level to non-existent
funding allocated to these measures, a more complete explanation of how
TDM measures were evaluated and selected is needed. Specifically, we call
on the TSC to give a more complete explanation of the criteria and the
process by which demand management, market-incentives, urban design, and
projects based on intelligent transportation systems technology were
considered in developing the Preferred Alternative, and how these were
evaluated for their trade-offs or complementarity with capital investment
and land use strategies. The public is entitled to a basis for
understanding, for instance, why the Westminster bypass and expansion of
MD 32 are worth over $400 million, while only $122 million is ear-marked
for all Transportation Demand Management Strategies, MARC improvements,
intelligent transportation systems, and bicycle and pedestrian projects
for the next 20 years and no funding is provided for paratransit, reverse
commuting, access-to-jobs programs, promotion of new flexible transit
benefit programs that could give new incentives to commute alternatives,
or use of CMAQ funds to encourage traffic reduction through innovative
zoning or site design.
3. Development of a Regional Vision
We endorse the recommendations made by the
TSC's Land Use Subcommittee in 1995 concerning the importance of launching
a regional vision planning process:
The BMC should facilitate the
development of a regional vision which includes goals and objective
uses for land use, economic development, environmental protection and
transportation. The regional vision will set the framework for all
planning activity in the region, including the work of the TSC, and
which would potentially be incorporated in each jurisdiction's
comprehensive plan. (p.53)
****
As the entity charged with formulating
long-range transportation plans for the entire region, the TSC has
been entrusted with a significant public responsibility. To maintain
the public trust, it is incumbent upon the TSC to clearly demonstrate
how selected projects for the Long Range Plan qualify in terms of the
criteria established by ISTEA, the visions of the Maryland Planning
Act and the goals of the TSC, itself. These criteria go well beyond
congestion levels and should include consideration of environmental
and economic development impacts of not just each individual project
but also of the Long Range Plan as a whole. (p. 54)
As we stated in our comments on the draft
Plan last November, the Long Range Plan is the best opportunity for the
region's leaders to articulate a common vision for the region through a
succinct document and supporting information. Without developing a
regional vision that integrates economic development and land use and
transportation planning, the TSC risks committing the region to a Long
Range Plan that amounts to little more than a compilation of projects
without giving adequate consideration to the effects of projects in one
jurisdiction on neighboring localities or on the region as a whole.
The Plan reports that the TSC/BMC has not
attempted to create or stimulate creation of a regional vision.
... there was no attempt to develop a
broad vision for the region encompassing land use, transportation,
economic development, and other quality of life issues. (p.158)
***
"A regional approach to planning
for growth and development does not exist in the Baltimore region.
This is the second transportation plan that broaches the subject but
cannot address it adequately, and won't until local officials desire
it to be done. (p.158)
We also note that the draft 2020 Plan pays
no attention whatsoever to interactions with the Washington, DC,
metropolitan region. We urge TSC to add a section to the Plan that
explicitly considers how this Plan relates to the Plan of the Washington
region and how future planning efforts -- at technical, policy,
management, and political levels -- will better address the
interconnection of the Baltimore-Washington metropolitan area. As the
Washington Metropolitan Council of Governments prepares a new vision plan
over the next two years and TSC/BMC move forward with their own vision
plan, these regions should as much as possible develop coordinated efforts
to integrate their initiatives.
4. Implementation of the Land Use
Subcommittee's Recommendations
We have already made several references to
the 1995 report by the TSC's Land Use Subcommittee on "Growth
Management and Transportation." We attach great importance to this
report, including both its analysis of
alternative patterns of development (the "composite scenario")
and its recommendations to local governments, the BMC, and TSC for future
action, because it initiates discussion about what we consider to be some
of the most fundamental challenges confronting the region. These include
integration of transportation and land use planning and development of a
regional vision for reconciling the competing demands for economic
development, social equity, environmental quality and quality of life
throughout the region.
Although the subcommittee's report was
completed three years ago, the TSC appears to have done little, or
nothing, to build on its work or to implement its recommendations. The
Plan does not address any of the subcommittee's recommendations. It
discusses "Maryland's Smart Growth Initiative" in bland,
descriptive terms but does not indicate any influence this initiative will
have, or should have, on transportation planning in the Baltimore region.
Under "Future Challenges,"
without referencing the subcommittee report or any of its specific
recommendations, the Plan commits to working with local governments in the
future on regional planning and visioning and to "develop greater
understanding of the relationship between land use and transportation
investments as an input to future land use and transportation planning
decision-making."
Although this expression of commitment to
give more attention to the land use-transportation connection in the
future is welcome, it is also an indictment of the BMC/TSC for having
neglected it since 1995.
We are now concerned that without a
commitment of resources and a more specific work plan, this vague
commitment will not lead to timely progress in addressing these important
issues. The BMC’s Unified Planning Work Program commits only $45,000
next year for these purposes. This is grossly insufficient for carrying
out a meaningful vision-planning or land use/transportation coordination
effort.
Technical Analysis of 2020 Plan
Alternatives and TDM Strategies
We appreciate that the TSC included some
evaluation of 2020 alternatives in the draft Plan. We note the TSC’s
conclusions that, "Generally, these comparisons show very little
change from one alternative to another since no real changes to land use
are made," (p. 104) and that "the proper selection of travel
demand measures can make a difference in the efficiency of the overall
transportation system." (p. 104). TSC also notes that "the
transit ridership projection shows very little change among alternatives…a
very high congestion level or a large increase in highway travel time is
necessary for measurable increases in transit ridership to occur."
Each of these statements has a basis in fact but needs to be fleshed out
with a fuller statement of the range of assumptions tested and the
limitations on the analysis methods used by TSC staff.
First, the TSC continues to use a set of
travel models that assume that land use and many aspects of travel
behavior are not affected by changes in transportation capacity, pricing,
urban design, or investment mix. These models are very limited in their
capability to reasonably evaluate transit alternatives. TSC is in the
process of a major upgrade of their old mode choice models, but for the
time being, is using a very crude analysis method. Independent analysis
has shown that the assumptions for parking costs in this model are
seriously mis-specified for base and future periods by more than an order
of magnitude. This analysis tool is also not sensitive to changes in
pedestrian friendliness or urban design, and hence cannot be readily used
to evaluate the full range of alternatives being proposed by planning
process stakeholders. TSC is in the process of developing a new land
use-transportation interaction model, TRANUS, that promises to allow it to
more fully consider how changes in transportation capacity and cost affect
land use. Until TRANUS becomes operational, the TSC should put less
reliance on its inadequate modeling capability and rely more on the
informed judgment of its staff.
Second, TSC has not evaluated for this
Plan a composite scenario of alternative transit-oriented land use, with
changes in transit, demand management and pricing strategies, and
information systems. Such a scenario could be reasonably anticipated to
produce changes in regional VMT of 15% or more, with reductions in
regional Vehicle Hours of Travel of 20-25%, over the life of this 20 year
plan, based on the experience of Portland, Oregon (in the 2040
Framework Plan), and the Washington metropolitan region (in the Network
of Livable Communities study). Unless the public and elected officials
are given real choices that produce a range of outcomes against regional
goals, the long range planning process can be little more than an
elaborate project screening and stapling exercise.
Third, TDM and pricing strategies,
especially, need to be more fully considered in the planning process. TSC’s
evaluation of TDM strategies is simply inadequate. TSC should document
their analyses, the means they have considered to overcome barriers to
program implementation and acceptance, and provide funding for pilot
program developments in the region. TDM strategies should be adopted as
Transportation Control Measures in the State Implementation Plan to
accelerate the timely attainment of the National Ambient Air Quality
Standards.
The TSC’s discussion of TDM strategies
(p. 126-129) gives rise to the following questions:
What are the effects of doubling MARC
commuter rail service frequencies during peak periods? If this is
effective, why not accelerate this investment?
What is the effect of completing the
bicycle element of the long range plan? If this is effective, why not
complete this by 2005, rather than by 2015, given its very modest cost?
The cost of the bicycle element represents less than 4/10ths of one
percent of the projected $4.1 billion cost of the proposed system
expansion; this is less than the current share of trips in the region
that involve bicycles.
How was congestion pricing on existing
toll facilities and radial freeways evaluated? The Plan asserts these
strategies would have limited Single Occupant Vehicle trip and emission
reduction potential, while causing adverse impacts on diversion of
traffic to local roadways, economic development, and economic impacts on
lower income population groups. Yet there is no documentation of these
statements. The experience in southern California with High Occupancy
Toll lanes and in Norway and Toronto and Singapore and elsewhere with
congestion pricing would suggests quite the opposite of the TSC’s
assertions.
The TSC’s only parking pricing TDM
strategy assumed a $2 morning peak surcharge for parking in selected
centers, but rejected this for ‘adverse economic impacts,’ again
without evidence. Has the TSC considered how to design parking
management strategies and incentives that might reduce or eliminate
adverse economic impacts? Has TSC evaluated parking cash-out strategies,
that might give employees the option of taking cash or a transit pass in
lieu of a parking space at their workplace? Has TSC considered how to
strengthen the RCAP program for transit fare discounts, to use the new
federal laws facilitating employers offering tax-free transit pass
benefits, to offer benefits to smaller employers through transportation
management associations, and to promote community-based travel demand
management?
Other Non-capital Actions
Other non-capital actions need to be shown
with specific levels of funding in the Plan. We especially support
expanded funding commitments for developing improved travel analysis
tools, improving welfare-to-work programs, freight planning, public
outreach, congestion pricing studies, improving the Congestion Management
System to integrate demand management and pricing strategies, and
improving bicycle planning. These should be reflected in the financial
plan and should involve significantly greater funding than today.
PUBLIC PARTICIPATION
Public participation in developing
regional transportation plans is obstructed by several structural barriers
related to the role of the TSC. These structural barriers and their impact
on public participation are discussed immediately below. Following this we
address opportunities for public participation in the TSC process.
1. Structural Barriers
Absence of a forum for addressing regional
issues. This vacuum results from a
simple Catch-22. The TSC has a regional scope, but it represents itself as
not having power or authority to develop a regional vision, integrate land
use and transportation planning, or directly influence regional patterns
of development. According to the TSC that power resides with local
governments, which have general powers over planning and zoning.
However, local government officials do not
have a regional mandate. "They aren't elected for foreign
policy," as the columnist Neal Peirce puts it. Their parochialism is
reflected in the location of designated growth areas in one jurisdiction
next to an agricultural district in another, as seen along the border
between Howard and Carroll counties.
No forum exists for meaningful public
comment on regional issues such as adding projects to regional
transportation plans in one jurisdiction or taking them away from another,
or shifting funds from capital projects to transportation demand
management or to services such as reverse commuting or paratransit. No
forum exists for citizens of one local jurisdiction to make a meaningful
contribution to land use or transportation planning in a neighboring
jurisdiction even though the effects of local planning cross
jurisdictional boundaries.
The structure of the Baltimore
Metropolitan Council and the Transportation Steering Committee.
All of the County Executives and the Mayor of
Baltimore sit on the BMC. There is little question about whether the BMC
has power to conduct a regional vision planning process or to integrate
transportation and land use planning across local boundaries. But the BMC
is insulated from public comment on regional transportation/land use
issues. Public comment is supposed to be directed at the TSC, which does
not have power, and serves as a buffer between the public and the
decision-makers.
Parallel processes, one real, and the
other (mostly) imaginary. The real
process is not open to the public. It appears to center around the
Maryland Department of Transportation's separate negotiations with
officials in each local jurisdiction and their representative in the
Maryland General Assembly. These behind-the-scenes negotiations not only
shape the Long Range Plan for the Baltimore region but also control which
projects are elevated from the Long Range Plan to the Transportation
Improvement Program and which are included in MDOT's Capital
Transportation Plan. By the time county executives, who sit on the BMC,
sign-off on the package of deals that emerges from this process, it is
highly unlikely that their subordinates on the TSC will attempt to alter
them.
The public is invited to participate in
the TSC's public review process. We have accepted that invitation. But
stakeholders who have the strongest self-interest in transportation
planning -- highway engineers, construction companies, and freight haulers
and associations representing them -- generally do not participate in
these proceedings.
Summary perspective: In order for the
public to have a real opportunity to participate in regional
transportation planning, these structural impediments will have to be
diminished. As it is now, we feel as though we are participating in
ceremonial events and are not given an opportunity to participate in
significant planning or decision-making. We believe that the general lack
of participation in the TSC's proceedings, about which TSC members and
staff often complain, is caused in significant part by the lack of
substance and seriousness of the proceedings, themselves.
2. Recommendations for TSC/BMC Action
to Support Public Participation in Regional Planning
Inform public participation and the
decision-making process by continuing to upgrade the
BMC's technical analytic capability.
We appreciate the BMC's openness in providing
access to its model and data to our technical experts and the readiness of
its technical staff to consider our recommendations for improving its
system. We look forward to the possibility of working with the BMC staff
on upgrading the BMC’s analytic tools.
Develop user-friendly planning materials.
Competing visions of the region, such as
those implicit in the Preferred Alternative and the "composite
scenario" analyzed by the TSC's Land Use Subcommittee, should be
presented in a way the public can understand and in terms relevant to
quality-of-life issues. These vision statements should integrate land use
and transportation elements in order to portray potentially contrasting
patterns of development.
The color brochure, "Outlook 2020,
Crafting a Transportation Agenda for the Baltimore Region" published
by the BMC a few years ago is a good example of a user-friendly
presentation. Another example, noted above, is the excerpt from the
Portland, Maine Transportation Plan explaining the tremendous degree to
which transportation can shape our daily lives that was included in the
Land Use Subcommittee's 1995 report.
Be pro-active about attracting
stakeholders to participate in TSC proceedings, rather than passively
accept whoever shows up (the usual suspects). The
recent TSC-sponsored symposium for reviewing the Plan was unusual in that
it brought together representatives of several diverse constituencies. It
succeeded in doing so because the TSC invited specific stakeholders --
freight haulers, highway builders -- to participate in a structured event.
This pro-active approach should be expanded to reach more constituencies
in the future. In addition to identifying specific stakeholders with a
known high level of interest in transportation planning, the TSC should
develop a program for reaching out to constituencies that are not already
aware of the importance of regional transportation planning to their
communities. To do so effectively, the TSC needs user-friendly
informational material that explains the relevance of transportation
planning in quality of life terms, as recommended above, and it needs to
hold meetings in communities, themselves, rather than rely exclusively on
people from across the region attending events at the TSC offices.
Develop and fund a public participation
strategy with work plan, staff assignment and budget. Start
immediately. Do not wait for the last six months of a three year planning
cycle.
Support and fund a regional visioning
process. In the past, referring to
the present planning cycle, the public was forced into a reactive
position. It was presented with a project list, gussied up with a few
pages of text about guiding principles, policies, objectives, and
strategies, and asked to respond to the list in 45 days. ("Just tell
us what you want. What projects are you trying to knock out of the
Preferred Alternative?")
Other regions, including Seattle, Denver,
San Francisco, Vancouver, Toronto, Milwaukee, Salt Lake City, and Chicago
are involving the public in choices with alternative land
use/transportation visions and improved analytic models. We should have
this opportunity in Baltimore. A visioning process undertaken at the
beginning of the next planning cycle would provide the public an
opportunity to play a constructive role at the beginning of the process.
The BMC and TSC must work in tandem on
this. If the BMC throws its weight behind it, it will happen. Start
immediately after revision and final adoption of Outlook 2020. Use this as
a pro-active means for engaging public participation. Ask the big
questions: what kind of a region do you want and how can transportation
help achieve it? Don't let the process die but build on the regional
vision to guide and legitimize the next long range plan update.
We appreciate the opportunity to comment
on the revised draft Plan and look forward to working with the TSC and BMC
in the future.
Sincerely,
Mary Matheny
Citizens Planning and Housing Association
Lee Epstein
Chesapeake Bay Foundation
Michael Replogle
Environmental Defense Fund
