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The Draft Environmental Impact Study for the proposed MD32 Improvements was reviewed to determine if it adequately portrayed the expected land use impacts from the alternatives.

The study devoted little detailed attention to all of the land use implications from the widening of MD32, particularly since the impacted study area excludes the adjoining Carroll County growth area of Freedom/Sykesville. This represents a serious flaw in an Impact Study for a highway project designed to accommodate much of its traffic from that county. Further, the study simply assumes that the projected growth is going to occur regardless of the improvement and therefore is justified if acceptable levels of service and safety are to be maintained.

This assumption contradicts Howard County’s own 1990 General Plan which acknowledged that the County was expressing "high levels of housing growth due to major highway extensions…"It further ignores the rational nexus between ease of commuting to job centers as influencing desirability of housing location.

MD32 runs through the western portion of Howard County which has been planned as a rural conservation zone in an attempt to discourage sprawl development. In addition to being outside the County’s Priority Funding Area, several zoning techniques and a farmland preservation easement program have been implemented to maintain its existing rural character. Nevertheless, pre-existing subdivided lots and clustering would be expected to result in almost 7,567 potential new housing units according to the Draft Study. The study also contains assumptions that, for some reason, this does not constitute a continuation of "sprawl" since it follows Howard County’s zoning code regulations designed to protect the area’s rural character. These same regulations have been criticized by the Maryland Office of Planning’s analysis of agricultural preservation regulations which rank Howard County’s zoning system as a "development" system rather than a true presentation system. Thus, the use of the State’s "Smart Growth" philosophy should be applied to projects such as MD32 if the stated goal of Howard County to protect its rural districts is to be met and not further weakened.

In addition to the impacts from the potential housing development in the region, the Study also ignores the potential new commercial development likely to be promoted by the development of an upgraded 32. A major employment center has been in Howard County’s Plan for the intersection of I-70 and MD32. One can also easily expect numerous commercial rezoning applications along the various new intersections, justified by a "substantial change in the character of the neighborhood" finding required under Article 66B and promoted by both the highway improvements and the new residential population.

While advocates of increased highway capacity argue that these plans only anticipate predetermined growth patterns, the State’s new Smart Growth strategy is designed to not reward those same patterns which have been determined to be counterproductive to a healthy and efficient region. Increased highway capacity should not be a reward or incentive for promoting housing in Howard’s Western region, yet it appears that an upgraded MD32 will do just that.

The real issue concerning the proposed role of MD32 is how and if you accept its primary function as a commuter road for Carroll County. Again, the 1990 Howard County Plan recognized that Howard’s strategic position between employment centers would lead to increased commuter traffic. The Plan also recognized that the paramount issue for the County’s western roads was safety rather than capacity.

And it is the Study’s failure to acknowledge the significant development shed of Carroll County that is its biggest mistake from a land planning perspective.

This section of Howard County abuts the Freedom/Sykesville area of Carroll County, an area experiencing large development growth in the last ten years and planned to be a major growth center in the County. MD32 runs right through the middle of the area and would reasonably be expected to significantly improve the commuting times of Carroll commuters as an alternative to I-70 to Rt. 29.

The Freedom/Sykesville Plan is encouraging substantial acreage ( ) to be rezoned from an agricultural designation to promote new residential and commercial development. The Plan calls for redevelopment of the 1300 acre Springfield Hospital property into a major employment center. All of this actively has been ignored in the evaluation of potential impacts in the Study, except for the increases in traffic. In my opinion, MD32 as upgraded for "safety" reasons, is really the middle leg of a future extension into this growth area and which is being ignored for this study.

That increased highway capacity can lead to bolstering arguments for future rezoning applications is secondary, perhaps, to the circular appeal that improving such capacity often plays into the arguments of developers needing to overcome Adequate Public Facilities regulations. Both Howard and Carroll County developers stand to benefit in future cases where excess capacity would be an argument to allow more development than would otherwise be permitted to occur.

In summary, the Draft Impact Statement is substantially flawed for ignoring the impact of the significant pressures in adjoining Carroll County. It further fails to fundamentally underestimate the resultant development pressures resulting from an upgraded MD32 and its relationship to Maryland Smart Growth strategy.

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