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COMMENTS OF THE BALTIMORE REGIONAL PARTNERSHIP REGARDING THE PROPOSED "ACTION PLAN" OF THE TSC/BMC IN RESPONSE TO THE SECOND JOINT CERTIFICATION REVIEW

 

May 18, 1999

Since 1996, Baltimore Regional Partnership has attempted to work constructively with the Baltimore Metropolitan Council and Transportation Steering Committee to see that a regional orientation be given to the transportation planning process. The Partnership is composed of the Baltimore Urban League, Chesapeake Bay Foundation, Citizens Planning and Housing Association, Environmental Defense Fund, and 1000 Friends of Maryland. Collectively, our organizations represent tens of thousands of citizens in the several jurisdictions represented on the Transportation Steering Committee and Baltimore Metropolitan Council. While the topic presently before the Transportation Steering Committee is a proposed "action plan" in response to the Second Joint Certification Review, it is important to review some of the recent history of the MPO process and the Partnership’s involvement therein. In particular, this background relates to the public participation processes employed (or not) by the Transportation Steering Committee and the lack of a truly regional process brought on by present composition of the Transportation Steering Committee.

The TSC continues its failure to involve the public...

The Partnership has been frustrated at every turn by the TSC’s lack of interest in reaching out to the public (and by the lack responsiveness to public participation when it is forthcoming). When the Transportation Steering Committee received the report of the Joint Certification Review Team, it formed a task force to develop the "action plan" presently before the TSC and BMC. The Baltimore Regional Partnership repeatedly requested to serve on this task force. Despite the Review Team’s required quality improvement of better public participation, the Partnership and other systems were denied access to meetings and documents of the task force. It is ironic that the TSC and BMC failed to involve the public in crafting the response to the federal report, despite the require quality improvement of enhanced public participation strategies.

Prior to the these issues being raised in the context of the recertification report, the Baltimore Regional Partnership and other organizations had repeatedly sought access to technical and policy information of the TSC, including agenda items such as drafts of the long-range plan, modeling data, etc. At best, information has been released slowly by the TSC. At worst, we have been unable to gain access to documents at all prior to a final vote by the TSC. What message does it send to the public when it can not gain access to the very documents being discussed at meetings of the Transportation Steering Committee?

On April 15, 1999, the TSC held a public hearing on the draft Transportation Improvement Program. The Baltimore Regional Partnership, TSC Citizens Advisory Committee, and other organizations were present to submit verbal and written testimony on the TIP. Yet, not a single member of the Transportation Steering Committee attended the public hearing. What message does it send to the public when the TSC does not even show up for its own hearings?

From the perspective of the Baltimore Regional Partnership, these and other actions indicate that the Baltimore Metropolitan Council and Transportation Steering Committee have no interest in involving the public in its process. This is further evidenced by the proposed "action plan" which makes no indication of a serious commitment to improving public participation in decisions made by the Transportation Steering Committee. Rather, the proposed "action plan" vests all of its public participation efforts in its Citizens Advisory Committee. Further, the briefing paper submitted to the BMC appears to blame the Citizens Advisory Committee for not being comprehensive in its approach. We submit that the TSC and BMC have given no role and no voice to the Citizens Advisory Committee and have made no concerted effort to improve the size or breadth of its membership. While we support the continuation of the CAC, and will continue to participate in the CAC, we believe that the TSC should engage in an aggressive outreach effort to involve more citizens, community organizations, business interests, and others in its decision-making process.

The TSC has failed in its role as a metropolitan planning organization...

We have further been frustrated by the lack of interest in setting a truly regional course to the important policy decisions made by the Transportation Steering Committee. The process used by the Transportation Steering Committee in developing the long-range plan has been nothing more than an exercise of stapling together local projects and submitting them to the federal government, terming them as a "regional plan." Despite repeated requests to the same, the Transportation Steering Committee never was able to explain to the public how projects were rated for technical and non-technical prioritization within the long-range planning process. The TSC even ignored its own subcommittee report on regional land use which provided a viable alternative to the sprawl caused by the preferred alternative selected for the Long-Range Transportation Plan. The result of the process termed "regional planning" is the development of a long-range transportation plan that will bring about more congestion and air than we have today in the Baltimore region – despite $16 billion dollars in transportation investments, including $4 billion in new capital improvements.

The issues are much more important than technical compliance with federal law...

The Baltimore Regional Partnership does not seek to make a solely procedural argument that the TSC is out of compliance with federal law and regulation as noted by the Joint Certification Review. The composition of the Transportation Steering Committee and its efforts to involve the public in the transportation planning process are much more important than technical compliance. Rather, developing a truly regional process for making transportation decisions will affect the region’s ability to succeed in the next century. As the Transportation Steering Committee is the only regionally constituted body, we must all work together to insure that this metropolitan planning organization is representative of the entire public interest. That cannot occur by vesting important policy decisions in low-level technocrats unable by their position within their respective institutional hierarchies to see the regional context of their decisions. Nor can it occur that a decisions made on a regional level be sustained without significant participation from the public at-large.

The proposed "action plan" makes no serious attempt to respond to the important issues raised by the Joint Certification Review. Rather, the proposed "action plan" is a mere "paper shuffle" designed to continue bypassing the regional planning process by maintaining the current membership of the Transportation Steering Committee. Bringing locally elected officials to the table of regional planning is an important step to securing the future of our region, and it is a step that is indeed required by federal law and regulation.

Given the lack of interest in public participation by the TSC and its task force, the Partnership engaged in its own process of reviewing the report, researching the practices of other metropolitan planning organizations, and developing recommendations not only to bring the TSC into compliance with federal law and regulation, but to develop a truly regional planning process.

Using materials available in the library of the Baltimore Metropolitan Council, interviews with officials of other MPOs, and research developed by the Association of Metropolitan Planning Organizations (of which the Baltimore TSC is a member), we submit the following recommendations for how the Baltimore MPO ought to be structured:

1. Elected officials, not their designated representatives should be

members of the Baltimore Metropolitan Planning Organization, and should make intermediate and final decisions on the many matters before the Baltimore MPO. The current membership of the Transportation Steering Committee is better suited to, and should take the role of, the current TSC Technical Committee.

 

2. The Baltimore MPO should employ weighted representation in order to achieve fair and balanced decision-making.

3. Among the voting membership of the reconstituted Baltimore MPO should be one or more members of the general public.

4. The Baltimore MPO should codify its policy regarding open meetings and access to information.

These recommendations represent the manner in which most metropolitan organizations conduct their business, not the "best practices" of select MPOs. Had the Transportation Steering Committee engaged in a peer exchange as recommended by and agreed to in the Joint Certification Review, perhaps the TSC and BMC would have learned quite a bit about the structure of other metropolitan planning organizations. Instead, the TSC action plan calls for a peer exchange in October 1999 – four months after the "action plan" is to be adopted. It is curious to note however, that the "peer exchange" as noted by the "action plan" is designed to gather input on issues of composition and public participation.

No serious commitment to reform...

In summary, the Baltimore Regional Partnership opposes the proposed action plan. The plan represents no serious commitment to reforming the regional planning process, nor does it meet the spirit or intent of the Joint Certification Review report. We again offer to work constructively with the Transportation Steering Committee, Baltimore Metropolitan Council, and the appropriate federal agencies to develop a plan that responds to the serious issues raised by the report.

 
 

 

Baltimore Regional Partnership · 512 Orchard Street  · Baltimore, MD 21201-1947
 phone: (410) 523-8150  x249 · fax: (410) 523-4022