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Exhibit 1

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This paper presents an analysis demonstrating that a major widening of MD 32 between MD 108 and I-70 is unnecessary and inappropriate. The Build Alternatives proposed in the MD 32 Draft Environmental Impact Statement fail to adequately address the safety and traffic operation needs of the highway and fail to address the local community’s and region’s transportation needs. SHA’s MD 32 Safety Action Plan, released to the public March 18, 1999, proposes a number of promising options for directly addressing the safety needs of the highway. This paper will analyze both the proposals put forth in the MD 32 DEIS and the SHA Safety Action Plan. As the two DEIS build alternatives are found to be inadequate, recommendations for creating a Safety Action Alternative based on SHA’s Safety Action Plan are presented.

A major widening of MD 32 from MD 108 to I-70 is unnecessary from a transportation perspective for the following reasons:

1. Traffic Assignment: Travel on MD 32 is largely interchangeable with travel on MD 100. Having two parallel freeway corridors between I-70 and I-97 only 4 to 5 miles apart is excessive and wasteful.

2. Traffic Volumes and Capacity: If capacity enhancement is a legitimate goal, this can be accomplished without dualization and construction of an excessive number of interchanges. Roadway capacity can be increased to approximately 30,000 vehicles per day by eliminating the left-turn conflicts and thus the need for traffic signals, and without widening the roadway to four lanes. This should be sufficient to accommodate SHA's very high traffic projections under the 2020 "no build" scenario, at a Level of Service "D" during peak periods.

3. Safety: There are many better and easier ways to improve safety on MD 32 than widening to a four lane freeway. The current safety problem is due to the difficult transition from freeway to arterial north of MD 108. If the MD 32 freeway was extended northward to I-70, the unsafe transition zone would simply be shifted northward to the segment between MD 99 and MD 26, which would be much worse.

4. Access: The construction of six or seven new full interchanges to make local access to MD 32 easier would further increase traffic and encourage new development, beyond the effect of the highway itself. To the greatest possible extent, local access should be by way of local roads.

Each of these issues is elaborated as follows:

The travel forecast for the MD 32 corridor conducted by the Baltimore Metropolitan Council for the most recent update of the Regional Long Range Transportation Plan yields quite a different result from the forecast of the State Highway Administration for the Draft Environmental Impact Statement. The BMC projects that the existing two lane roadway will be sufficient for the 2020 horizon year, and will operate without congestion. SHA, on the other hand, asserts that this section of MD 32 is congested now and will only get worse by 2020. This discrepancy between the two forecasts points out the inexactness of long range travel modeling.

BMC's model incorporated the entire region, including the Washington DC metro area east of the Potomac River. SHA used a technique that offered more network detail for the areas near MD 32, and less detail as the model got further away. SHA also engaged in the luxury of looking at the model results and making mathematical adjustments to account for professional judgment.

Two specific differences between the methodologies are identified below.

BMC used older and lower baseline traffic counts. Traffic on the study section of MD 32 increased greatly as soon as the freeway section was completed through the MD 108 interchange, and the BMC baseline results do not specifically account for this, although both models treated this highway improvement as part of the "existing and committed" baseline network. The SHA baseline counts are from 1997, more recent than the BMC counts, and after the MD 32 freeway extension through the MD 108 interchange was completed. On the other hand, both studies took place prior to the completion of MD 100 north to US 29. It is very likely that the current 1999 volume on MD 32 is actually lower than the 1997 SHA count, with some traffic having shifted back to MD 100.

Secondly, the BMC model, by considering the entire region at a relatively uniform level of detail, is likely to assign more traffic to MD 100 than the SHA model, in both the baseline and 2020 horizon years.

Traffic assignment is generally considered to be the least accurate and most sensitive component of the traffic forecast modeling chain. However, it is also the least critical from a policy standpoint. Specific traffic route assignments have little or no impact on the most critical regional travel forecast measurements, including total trips, modal split, vehicle miles of travel, and overall congestion. The most important result is that the traffic actually does get assigned somewhere in the network.

From a regional standpoint, there is little difference between an assignment of traffic to either MD 100 or MD 32. The two corridors are generally only four to five miles apart. The overall difference in the distance traveled for trips assigned to the two is quite negligible. The distance between the interchange of MD 32 and I-97 and the interchange of MD 32 and I-70 is approximately 29 miles via MD 32 and 31 miles via MD 100. This extremely negligible difference is due to the fact that MD 32 has two long "S" curves, one near MD 170 in Odenton and one near Burnt Woods Road just south of MD 144. In contrast, MD 100 is relatively straight. Since the maximum distance advantage of MD 32 over MD 100 is only two miles, the number of trips which a computer model will assign to MD 32 could be quite sensitive to other seemingly minor differences detected in the model.

In real terms, the lack of a significant mileage difference is even more notable. This major upgrade to MD 32 is justified by SHA as an important link between the Eastern Shore and Western Maryland. Such trips are upward of a hundred miles, so a two mile difference is even less significant. Most of the higher density urban and suburban areas are closer to MD 100 than MD 32, so MD 100 will be that much more attractive than MD 32. The only instances where MD 32 will be substantially more attractive is for very short trips in the immediate vicinity of MD 32, where the two mile difference will be significant.

This also helps explain the large difference between SHA's traffic projections for the "build" and "no build" conditions. The large proposed capacity increase would make MD 32 much more attractive to through traffic from a wide surrounding area. Thus there can be no fixed, absolute projection of future traffic demand on MD 32.

The much more optimistic BMC model result, which predicts a generally congestion free condition on MD 32 north of MD 108 through the year 2020 without any widening, may not be more accurate than the more pessimistic prediction by SHA. However, the BMC result demonstrates that a less overbuilt and less congested future is feasible, and that the additional traffic projected by SHA may be a self-fulfilling prophesy. From the standpoint of planning for a roadway network that considers the needs and fulfills the policies of the entire region, rather than simply examining the MD 32 corridor in isolation, the more optimistic results of the BMC model runs may be considered more useful.

Traffic volumes and projections in the DEIS are expressed in terms of Average Daily Traffic. However, capacity is not a function of traffic conditions throughout an entire day. Obviously, the traffic volume during off-peak periods will be lower than that during peak periods, and therefore below capacity. It is therefore the standard practice in traffic planning to express capacity in terms of the peak hour. The "daily capacity", if such a term is to have any relevance at all, must be calculated by taking the peak hour capacity and dividing it by the percentage of daily traffic that occurs the peak hour.

Similarly, Level of Service is also a term that has no intrinsic meaning when applied over an entire 24 hour day. Obviously, the Level of Service will be "A" in the middle of the night under all scenarios. Level of Service assessments should therefore be understood to be applicable to maximum volume conditions only. As such, the State Highway Administration has calculated the current percentage of daily traffic which is present at the peak hour as 9.52%. Thus, "daily capacity" is calculated by taking the peak hour capacity and dividing by 0.0952.

SHA does not provide an estimation of the existing peak hour capacity in the DEIS, which would have to incorporate an analysis of left-turn conflicts and traffic signal timing allocations. However, the easiest and most direct way to increase the capacity of MD 32 would be to eliminate the left-turn conflicts and thus the need for traffic signals. This would increase the capacity to approximately 1800 vehicles per hour per lane, calculated at Level of Service "D", which is a somewhat but not fully congested condition where traffic moves at an average speed of about 40 miles-per-hour. This approach would achieve essentially the same Level of Service as the higher impact dualization build Alternatives I and II. Level of service in design year 2020 for Alternatives I and II in the DEIS is "C/D."

To calculate daily capacity, this maximum 1800 vehicle per hour volume in the peak direction must be combined with the concurrent volume in the opposite non-peak direction. SHA estimates this volume for the year 2020 "no build" scenario as 940 vehicles per hour. The total peak hour capacity would therefore be 2740 vehicles per hour, and the "daily capacity" would be 28,800 vehicles. (1800+940)/0.0952 = 28,800.

At the current distribution of traffic over a 24 hour period, therefore, the capacity of MD 32 can be increased to 28,800 vehicles per day without widening to four lanes, by eliminating the left-turn conflicts and traffic signals. This is based on the current 9.52% of daily traffic at the peak hour.

SHA projects the peak hour percentage on the roadway to actually increase to over 11% for the 2000 no-build scenario, and remain at 10.25% for the 2020 no build scenario. This is inconsistent with usual trends, which generally result in a reduction in the peak hour percentage as traffic volumes increase. It would be more likely that the current 9.52% peak hour percentage would go down over time, perhaps stabilizing around 9%, which would increase the maximum daily capacity to over 30,000 vehicles.

This reduction should be further abetted by the availability of alternative roadways to increase motorists' flexibility in choosing routes, most notably the 1998 opening of MD 100 to US 29. Instead, SHA has projected a huge increase in traffic on MD 32 of over 18% (5.8% per year compounded) between 1997 and 2000 for the "no build" scenario. This is even greater than SHA's projected increase over the longer term, which is still a large 38% over the twenty year period from 2000 to 2020. New traffic counts on MD 32 should be taken which reflect the completion of MD 100, to determine if SHA's large projected traffic increase since 1997 has indeed occurred.

In conclusion, the capacity of MD 32 can be increased to approximately 30,000 vehicles per day by eliminating the left-turn conflicts and thus the need for traffic signals, and without widening the roadway to four lanes. This should be sufficient to accommodate SHA's very high traffic projections under the 2020 "no build" scenario, at a Level of Service "D" during peak periods.

In the early and mid 1990's, MD 32 between MD 108 and I-70 was a fairly safe roadway. In the three years from 1991 to 1993, there were only 132 accidents, well below the statewide average in terms of per million vehicle miles. From 1995 to 1997, this had increased to 161 accidents or 113 per million vehicle miles, which was still below the statewide average rate. However, in less than two years from 1997 and part of 1998, there were six fatalities, compared to only four from 1991 to 1993, and none in 1995 or 1996.

The turning point was the completion of the MD 32 expressway south of MD 108 in 1996. Motorists now think of the entire roadway as a freeway, and drive it as if it was a freeway, despite the fact that it is simply a well designed two lane highway north of MD 108. Motorist high expectations have attracted them to MD 32, and has led them to drive faster and less carefully than they should.

Converting MD 32 to a freeway from MD 108 to I-70 might reduce the accident rate in this area, but likely lead to the same problem of motorist expectations, if not worse, north of the I-70 expressway terminus. Whereas the current transition area north of MD 108 has full access control for about five miles, MD 32 has a high volume full four-legged intersection with MD 99 less than one mile north of I-70. If the intersection of MD 32 and MD 99 becomes the first at-grade intersection on MD 32 beyond the freeway, there will be major safety problems.

Eventually, the Regional Long Range Transportation Plan calls for the full dualization of MD 32 and widening to four lanes northward to MD 26 (Liberty Road) in Eldersburg in Carroll County. Once MD 32 is converted to an expressway south of I-70, it will attract more traffic north of I-70 as well, creating congestion and safety problems which will add to the pressure to extend the widening to the north. This will further contribute to the continuous ongoing cycle of roadway capacity increases leading to traffic increases, which creates pressure for further capacity increases.

The problem of increased attractiveness to traffic will reach its peak at the intersection of MD 32 and MD 26 in Eldersburg. At this intersection, there is no long range plan for significant widening, and no place to widen even if it was deemed desirable. The widening of MD 32 will be aimed point blank at a permanent bottleneck for which there is no solution, except to disperse the traffic onto local roads and streets throughout the Eldersburg community.

This is already evident in plans to improve country roads in Carroll County such as Obrecht Road, and to connect currently low volume suburban streets such as MacBeth Way and Piney Ridge Parkway. These so-called "improvements" will have a severe impact on the quality of life for nearby residents. MacBeth Way is now a quiet dead-end street that carries virtually no traffic. It will become a favorite short cut for many motorists who wants to avoid the worsening bottleneck at the intersection of MD 32 and MD 26. The solution to the safety problem on MD 32 is not to escalate use of the road by building an expressway. The solution is to identify and solve the safety problems directly.

If head-on collisions or left-turn movements are identified as a significant problem, a median can be constructed without widening the roadway to four lanes. The State Highway Administration already has experience with the construction of a two lane median divided roadway - MD 90 in Worcester County on the Eastern Shore. If passing needs to be accommodated, turnouts can be provided for slow moving vehicles at safe locations. However, most passing is not safe and should not be encouraged. This is hardly ever an issue of roadway capacity; maximum capacity is provided when speeds are as low as 30 miles per hour.

Another safety problem identified as significant is collisions with animals. More and better fencing along the right-of-way is the solution. For rear-end, turning and angle accidents, better access control is the answer. This is discussed in the section below.

Enforcement of traffic laws is always an important factor. A perfect road design cannot guard against all motorist abuses. MD 32 as it currently exists is a competently designed road that meets all reasonable safety standards. Enforcement of traffic laws will always be necessary to ensure that motorists do not drive beyond the limitations of any roadway.

Access control is an important element in improving safety and capacity on MD 32 without widening the roadway. However, interchanges built in conjunction with access control simply open the surrounding land to more traffic-generating sprawl development which will use up the capacity increase, leaving congestion as bad as it was before the "improvements" were made.

Local traffic should rely most on local roads. If MD 32 is construed as the "front door" for much of western Howard County, increased traffic volumes and accelerated development will follow. Modifications to local roads in this area which will enable them to better serve the local residents should be identified. The State's proposal to connect Pfefferkorn, Burntwoods and Ten Oaks Roads appears to be a promising example of this. Currently, Pfefferkorn and Burnt Woods Road are potential spillover roads for through traffic on MD 32 that wishes to gain access to MD 97 and MD 144. Connecting these roads together, while severing their connection to MD 32, would allow them to serve local traffic rather than through traffic. Their traffic loads would be proportionate to the needs of the local users.

The DEIS refers to "right-of-way problems" associated with several proposed interchange configurations involving these roads. If the MD 32 widening and ramps connected to an overpass were eliminated from the plan, there would be much more extra room within the existing right-of-way to avoid any problems. Connections to MD 32, if they are desired at all, could be limited to inexpensive and inconspicuous right turn ramps to and from the roadway, without an overpass.

If one interchange is desired along this segment of MD 32, Triadelphia Road would be the best location because it has an existing overpass. Again, right-of-way problems are cited, but the elimination of the MD 32 widening would allow the ramps to be placed within the existing right-of-way. Alternatively, the ramps could be located at some distance from the existing bridge, which would still allow the bridge to connect local destinations on either side of the highway.

The other location where an interchange might make some sense is Rosemary Lane, since this would also create local access on both sides of the highway. Better still, right lane access could be provided to and from northbound Rosemary Lane, while southbound access is provided to Ten Oaks Road. Both would provide connections to each other via the existing Triadelphia Road overpass.

Perhaps the proposed interchange which is least justifiable is the one at Dayton Shop, which mostly serves only the dead end State Highway Administration property. Does this facility really justify a costly interchange? If State employees can't be trained to use alternative routes, who can?

Another alternative to interchanges is a concept called "dispersed movement intersections". This new concept is currently being planned in Howard County at the intersection of MD 175 and Dobbin Road in east Columbia. It allows at-grade intersections to carry almost as much traffic as a full interchange, without costly and disruptive overpasses, by dispersing turning movements in a manner that effectively eliminates conflicts between them. While traffic signals are generally installed at several locations within the intersection, none operate with more than two phases.

In conclusion, the interchanges don't really help a roadway to function any better. It is the elimination of existing driveway and intersection access, particularly left-turns, which improve the capacity and safety of the roadway, whether extra lanes are added or not. Two lane roadways can carry tremendous volumes of traffic when such conflicts are eliminated.

The Draft Environmental Impact Statement for MD 32, despite its phone book size, does not present a true range of alternatives for meeting the challenges created by traffic and development pressures. The report also fails to present traffic data in a useful form. Peak hour traffic data, particularly turning movements, is necessary to accurately assess the relationship between traffic volumes and capacity. It is hoped that the preceding discussion will begin to fill the need for investigation of a wider range of suitable alternatives.

Proper implementation of many of the elements of the Safety Action (dated March 18, 1999) for MD 32 from MD 108 to I-70, in combination with additional recommendations below, should solve the safety problems that have been caused by the transition from the new expressway south of MD 108. Successful implementation of these measures will make the proposed two lane widening, six to seven interchanges and construction of service roads for MD 32 unnecessary. An expanded analysis should be conducted on a safety action alternative, excluding the proposed widening to four lanes and excessive six to seven interchanges proposed under the current "build" scenarios in the Draft Environmental Impact Statement.

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