The Baltimore Regional Partnership, composed of Citizens Planning and Housing Association, Baltimore Urban League, Chesapeake Bay Foundation, Environmental Defense Fund, and 1000 Friends of Maryland, offers the comments below on the Draft Transportation Improvement Program for Fiscal Years 2000 - 2004.

The short range program is our immediate window of opportunity to make transportation responsive to the needs of the region. While we cannot afford to wait for the "long range" to forge regional progress and cooperation, the region needs a consistent long range vision so that we can measure our short range progress. On this basis, the best aspect of the Draft TIP is its emphasis on maintaining and improving the existing infrastructure.

It is particularly gratifying to see that a listing of projects within the "areawide" designations is provided for the first time. It would be extremely helpful to have some of the same basic information regarding these projects, such as the county location and the cost, as is presented for the regular listings. Also, it is somewhat disconcerting to see some of the STP and IM "safety" projects described as widenings. Assurance should be provided that these will not increase capacity, which would require individual listing for environmental review and conformity status, and possibly inclusion in the Long Range Plan.

In addition to the comments above, we have concerns about the following specific aspects of the draft TIP.

1) The Baltimore Regional Partnership is dismayed that not a single member of the Transportation Steering Committee attended the first public hearing on the Draft Transportation Improvement Program. In light of the Joint Certification Report of the FTA and FHWA calling for greater public involvement outreach by the TSC, it is inexcusable that not a single member of the TSC participated in the public participation forum. Moreover, we take issue with the certification provided on page 2 that "the MPO has adopted a public involvement process that fulfills the requirements and intent of public participation and outreach as defined in the Intermodal Surface Transportation Efficiency Act." As the TSC well knows, the Federal Transit Administration and Federal Highway Administration in their Second Joint Certification Review, found that "the role of the public in the TSC process is inconsistent with the requirements for public involvement as per ISTEA..." As no TSC response to the required quality improvements of the Joint Review Team Report has yet been approved, we find it difficult to understand how the TSC can make this claim of certification. Even if the certification language is just a placeholder until the TSC approves a response to the required quality improvements, the public involvement process during the development of the TIP will still not have been in compliance. We request that sufficient notice be inserted to the TIP that the TSC has been found to be out of compliance with the intent of federal law and regulation under ISTEA.

2) The inclusion of projects in the TIP that were not included in the Baltimore Regional Transportation is wholly unacceptable. Specifically, the inclusion in the TIP of the Arundel Mills Boulevard and MD 295 interchange and the Baltimore Beltway widening between I-97 and MD 100 subverts the regional planning process completed less than one year ago. These projects raise serious questions about the function of MD 100 and the Baltimore-Washington Parkway as they relate to regional travel patterns and land use planning. We urge that Arundel Mills Boulevard and MD 295 interchange, and the Beltway widening between I-97 and MD 100 be deleted from the TIP until a substantive discussion is held on the regional context of these projects.

3) We urge the rejection of the proposed widening of the Hickory Bypass. Widening the Bypass to four lanes would simply make it a purveyor of new sprawl development to the northern and eastern portions of Harford County. The Bypass widening, coupled with other major road in the area projects, appears to serve the purpose of avoiding investment in established communities in order to conduct more growth to rural areas outside the Bel Air Priority Funding Area (PFA) and the County's Development Envelope.

In sum, the TIP, despite its dry, often obscure and cryptic format, does focus attention on the disarray of the regional planning process. The region does not have a clear vision. We do not yet know how our transit system should function in a regional context, or how our highway system should function to serve legitimate travel needs rather than sprawl development pressures. The region's short range transportation planning process appears to be an ongoing one, with constant adjustments and second thoughts. The region's long range planning process appears to be a periodic series of unrelated vision statements. This should be reversed. The long range planning process should be a constant ongoing quest for regional vision, while the short range process should strive for a single clear annual expression of the region's priorities to attain that vision.