The Citizens Planning and Housing Association is a 58 year-old non-profit citizen action organization whose members are dedicated to improving the quality of life for people who live in the Baltimore region. Recognizing that so many of the quality of life issues addressed by CPHA were not only city-oriented, but in fact, regionally-oriented, we endeavored four years ago to create a Committee on the Region. One of the major projects of the Committee has been a joint project to inform and advocate for citizen participation in regional land use, transportation, and air quality decisions. Our partners in this project are the Chesapeake Bay Foundation, Environmental Defense Fund, 1000 Friends of Maryland, and the Baltimore Urban League. We come before you this evening as one of many organizations, including those noted above, with serious reservations about the scope of the Draft Environmental Impact Statement for Maryland Route 32 from Maryland Route 108 to Interstate 70 in Howard County. Our major concerns are as follows:

The boundaries of the DEIS Secondary and Cumulative Effects Area are incomplete because they do not encompass the rapidly growing communities along MD 32 in Carroll County. In particular, Sykesville and Eldersburg will bear the greatest effects from this project as growth in traffic and pressure for development is accelerated by the lure of reduced travel times to employment destinations. In turn, the air quality in the Baltimore region will likely worsen with more single-occupant vehicles and more vehicle miles traveled. The DEIS makes no mention of these effects, nor their relationship to Baltimore’s status as a "non-attainment area."

Moreover, the DEIS notes MD 32 as a "critical commuter link" but fails to explain why SHA believes this to be so. The DEIS fails to identify origins and destinations of these commuter trips or how they might be served by the existing highway network, specifically, MD 100.

CPHA worked very hard with other organizations, and the Governor, for the passage of Maryland’s Smart Growth Act. We find the proposed "safety improvement" action to be a clear violation of both the spirit and intent of Smart Growth. It is inconsistent with Smart Growth to assert that expanded highway capacity serving largely single-occupant vehicles is needed because it will avoid more populated areas (Baltimore and Washington, DC). Expanding highway capacity to serve rural areas and newly developing areas (outside of the Priority Funding Area) far from existing job centers in the Washington, DC and Baltimore areas is contrary to the goals of Smart Growth. The proposed action runs counter to reinvesting in established communities, the efficient use of existing infrastructure, and discouraging increases in single-occupant vehicle use and vehicle miles traveled in the corridor.

Furthermore, the Maryland Office of Planning has identified all of Howard County’s farm land as threatened by development pressure and most of the farmland Carroll County. This threat will only be exacerbated by capacity improvements to MD 32, further undermining the intent of Smart Growth as well as local efforts to preserve farm land and forest land.

The DEIS fails to consider regional social, economic, and fiscal effects from the proposed action.

Many of the problems facing communities in the region are a function of larger policies and trends beyond their jurisdictional boundaries and control; solving such problems will require region-wide action to redirect those policies and trends. The proposed expansion of MD 32 is just such an action. It heavily affects existing communities not only in Howard County but in Anne Arundel and Carroll Counties as well. The DEIS considers far too narrow a scope of likely effects within its section on environmental justice as described below.

Howard County employs a policy of de facto fiscal zoning in the western part of the County. We suggest that the expansion of Route 32 will reinforce this policy. As Myron Orfield, Director of the American Land Institute’s Metropolitan Area Program, reported to CPHA last year in Baltimore Metropolitics

The dynamic of fiscal zoning creates three sets of mutually reinforcing relationships. First, the residentially exclusive suburbs with low tax rates continue to attract more and more business, the presence of which continually lowers the overall tax rate. Because of low social needs, these [suburbs] can provide a few high-quality local services. Another reinforcing relationship includes those [suburbs] with increasing social needs that lead to both declining consumer demographics and increased taxes. Both of these factors are large negatives in terms of business location and retention. The third relationship concerns the developing suburbs that lose the battle of fiscal zoning. Because they have not yet attracted business or executive housing, these communities must pay for their schools, police, parks, curbs, and sewers, with fewer resources. To keep taxes from exploding, they are forced to build the lower-valued homes and multi-family units rejected by the wealthier suburbs. These decisions, in the long-run, catch-up with working class suburbs and they become the declining suburbs of tomorrow.

One need not look far from the proposed Route 32 expansion to see areas where the disinvestment described by Orfield is already occurring. The areas of Fort Meade, Savage, and Guilford, are typical of this pattern. Along the parallel corridor of Route 100, one can look to Glen Burnie, Linthicum/Ferndale, Elkridge, and even parts of Ellicott City and Columbia are seeing the deleterious effects of greater transportation access to areas farther away from our established communities. We contend that West Columbia and Clarksville are likely to suffer these same effects as a result of the proposed action. This cycle can not be allowed to occur, and ought to be examined by the DEIS.