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.