Look Below the Impervious Surface

The public has 90 days to respond to a proposed $11 billion project that would impact 48 miles of the Beltway, the American Legion Bridge, and land and water below for generations to come.

The risk is $11 billion and contamination of waterways and parkland for generations to come. And gridlock for a decade during construction. The reward is possible reduction in the commuting time of people commuting between Maryland and Virginia over the Potomac River and through Potomac and Bethesda. Commuters would pay a toll; the rest of us would pay in other ways.

Last week, the Montgomery County Planning Board staff responded with a 63-page memo to the draft environmental impact study for the I-495 and I-270 managed lane project. The proposal is to add toll lanes connecting the Virginia Beltway over the American Legion Bridge around the Maryland Beltway and up 270. The plan is to reduce traffic congestion by adding four lanes of pavement to 48 miles of highway.

The Planning Board listed hundreds of concerns, described as major issues, technically deficient issues and dozens of more critical comments.

Here is just a sampling of the comments:

“The days of highway-only projects with no public transit support or components are past, despite the efforts and focus of this project, and the blatant disregard for public sentiment on developing regional multimodal solutions is concerning.”

“The Commission must determine that the Policy for Parks has been followed. The DEIS provides imprecise and very rudimentary information about the potential impacts to parklands.”

“Detailed field review demonstrates that the current [level of detail] does not comprehensively reflect expectations of environmental impact and what will be needed to restore and mitigate for proposed construction.”

“Access decisions are flawed.”

“The DEIS does not meet the stated goal of leveraging other modes of transportation.”

“The storm water management approach presented in the DEIS is insufficient and ignores decades of degradation that the existing highways have inflicted on local land.”

“The DEIS does not sufficiently address impact to economically challenged populations or social equity as required under NEPA. To simply conclude that everyone is benefiting with travel time savings when the project design does not provide equitable access to the managed lanes creates another layer of inequity.”

“There is no discussion or analysis of how to bring transit across the Woodrow Wilson Bridge, which was designed and built to accommodate rail at significant cost to the State of Maryland. There is no indication or commitment that the American Legion Bridge will be designed to structurally accommodate rail, whether now or in the future for this significant bridge replacement project.”

“There is no indication that the financial risks due to the likelihood of delay as a result of litigation to prevent the build-alternatives, or the difficult land acquisition process, particularly to expansion of I-495 in its most environmentally sensitive areas ... will impact the financial implications both to the P3 and the potential for unexpected burden on the taxpayers. The impact to the Purple Line Partnership due specifically to cost overruns from construction delays, land acquisition difficulties, and design changes – each raised as concerns under this DEIS review – is a perfect case in point.”

Approximately 15 percent of travelers need to be off the Beltway to keep the American Legion Bridge from being clogged.

In a matter of days, the pandemic took more cars off the road than many said would be possible. Nationwide, the decrease was 30 percent by the end of March; traffic was down 36 percent in the Washington Metropolitan area, according to INRIX Research.

People aren’t using the American Legion Bridge in ways they did before; workers are using Zoom, Google Meeting Rooms and FaceTime, and telecommuting with positive impacts on the environment and traffic. But now the public has been given three months to review more than 18,000 pages of technical detail about the project.

“If we promote telework right we don’t need to expand 270 through Rockville where I grew up and it’s already 6 lanes both ways,” said Del. Marc Korman (D-16) on Twitter.

“In general, we only need 5% to 15% of drivers to avoid traffic bottlenecks during peak periods for all of the traffic jams in Maryland to dissipate,” Korman said in a letter he wrote with Del. Carol Krimm of Frederick to Maryland’s transportation secretary. “To achieve that reduction, drivers can choose – when practical – to work from home, use alternative modes of transportation, shift departure time, change travel routes, or use other Transportation Demand Management practices.”

“Those numbers are achievable and do not require billions of dollars in new infrastructure investment using risky financing methods of which we have now become all too familiar with the downsides. Moreover, saving money on roadway expansion will allow us to re-target some of those funds and focus on other critical transportation needs around our State. ...

“We have the opportunity to use the data to work with all levels of government, the Transportation Planning Board and Maryland’s other Metropolitan Planning Organizations, the private sector business community, and Maryland commuters to explore ways to reduce traffic, particularly during peak times in innovative ways.”

SO MASSIVE IS THE PROJECT, its draft environmental impact summary requires trailers to be set up outside Montgomery County libraries so people can review the document.

Advocates with the Sierra Club and Citizens Against Beltway Expansion (CABE) are requesting public help to assist their experts and attorneys to read and get ready to respond.

“This Project is one of the largest of its type ever proposed and will cost more than $11 billion dollars … and will affect the lives of Maryland residents and their communities, land, and water for generations,” according to U.S. Senators Ben Cardin and Chris Van Hollen and U.S. Representatives Jamie Raskin and Anthony Brown.

“To ensure genuine public access, broad awareness of the process, and serious public engagement with the issues raised,” they asked the public be given 30 additional days to review the draft environmental impact study and give feedback to the Maryland Department of Transportation, State Highway Administration and Federal HIghway Administration.

“Many of our people are facing sickness, stress, and unemployment,” they said.

FOUR VIRTUAL MEETINGS for the public to respond have been currently scheduled for 9 a.m. to 8 p.m. on Tuesday, Aug. 18; Thursday, Aug. 20; Tuesday, Aug.25; and and Thursday, Sept. 3.

Construction is planned to begin as early as 2021 and the first phase of the project would include the American Legion Bridge and the segment that extends from I-270 to I-370/Maryland Route 200 (the road formerly known as the ICC).

The Maryland Board of Public Works, a three-member body made up of Governor Larry Hogan, Treasurer Nancy K. Kopp and Comptroller Peter Franchot (who has announced he will run for governor in 2022), voted 2-1 (Franchot and Hogan in favor), in January, to speed ahead with the project as a public-private partnership. The solicitation process will begin with Phase 1 on I-495 beginning in the vicinity of the George Washington Memorial Parkway in Virginia to I-270 in Maryland and on I-270 from I-495 to I-70. I-495 from the vicinity of the George Washington Memorial Parkway to the I-270 west spur, and the I-270 west spur to I-370, would be delivered first.

TRAFFIC CONGESTION affects many lives around the Beltway. More than 235,000 vehicles crossed the American Legion Bridge daily, at least until the beginning of the pandemic.

Hogan made the claim: “The project is expected to cut commuting time in half for many travelers, reduce congestion in the regular lanes by 25 percent, provide 40 percent more lane capacity over the old bridge, and include bicycle and pedestrian paths across the Potomac River.”

“Our teams have identified a way to fix one of the worst traffic hot spots in the country,” said Virginia’s Governor, Ralph Northam. “This demonstrates what can get done when leaders come together to find shared solutions to tough regional problems. This is about helping people see their families more, grow their businesses, and further unlock the region’s vast economic potential.”

But with climate change rivaling coronavirus as an existential threat, reducing carbon pollution means reducing car travel.

“Transportation is the leading source of climate pollution in Maryland. Our transportation strategy must, first and foremost, focus on reducing vehicle miles traveled and expanding mass transit,” said Josh Tulkin, Director of Maryland Sierra Club. “We need to be honest about global warming and the impacts of our actions. You cannot expand highways and magically mitigate the carbon pollution.”

Their Own Words:

“The Draft Environmental Impact Statement weighs 90 pounds. That alone indicates that this project warrants intense scrutiny. We are concerned that this massive highway project will exacerbate harm to our health and environment. The Sierra Club and other organizations have been denied, delayed or charged $300,000 for public information requests that would have shed more light on this project. We need more time to comment on this controversial proposal.” — Josh Tulkin, Director, Maryland Sierra Club

“Experience shows that highway expansions increase, not decrease, driving demand. By fueling more long-distance living and commuting, toll lanes are a massive, generational alteration of our landscape and come at high cost to homes and neighborhoods, people and health, and the natural environment.” — Jane Lyons, Maryland Advocacy Manager of the Coalition for Smarter Growth

“The $11 billion I-495/I-270 expansion is too big and will affect too many lives over the next 50 years for Marylanders to accept an 18,000 page draft environmental impact statement that offers vague assurances that pollution and flood risk won’t increase and parks and communities will be protected. We urge MDOT to give the public the time it needs to review this draft statement and to release the secret traffic and revenue studies being used to justify this massive, high-risk project. Maryland cannot afford a repeat of the crisis plaguing the Purple Line, the Hogan administration’s first public-private partnership. — Brad German, Co-Chair, Citizens Against Beltway Expansion

“This proposed expansion threatens our national parks, including Greenbelt Park, C&O Canal, George Washington Memorial Parkway, Suitland Parkway, and Baltimore-Washington Parkway, without solving the region’s transportation needs. Should this proposal move forward, over 300 acres of local parkland – including valuable green space in an increasingly urban area – could be paved over. Instead of pursuing this new and costly highway expansion, the National Parks Conservation Association urges the Maryland Department of Transportation to examine the many alternatives available that will address our transit needs without sacrificing our parks.” — Pamela Goddard, Mid-Atlantic Senior Program Director, National Parks Conservation Association

“Rock Creek is just one of the many special places that will be impacted by the proposed $11 billion expansion of I-495 and I-270. These impacts will extend far downstream, including into the creek through the nation's first urban national park, Rock Creek Park. The public deserves a full range of alternatives for these sensitive waterways, habitat corridors, and public lands and time to fully consider them. — Jeanne Braha, Executive Director, Rock Creek Conservancy

"How precious is breathing? How important is it to preserve natural spaces and protect the health of residents of this region? We at the Audubon Naturalist Society want MDOT and the SHA to tell us, because the delivery of this 90-pound EIS for an $11 billion project with only 90 days to review it suggests that our health and well-being are not a top priority. Taxpayers deserve better.” — Denisse Guitarra, Maryland Conservation Advocate, Audubon Naturalist Society

“MDOT gave assurances that the public would have an opportunity in the DEIS process to actively participate in the consequential decisions related to the I-495 & I-270 project. However, in releasing an 18,000-page DEIS in the middle of a health and fiscal emergency, and then failing to provide adequate time for document review, MDOT shows disregard for public input. No one knows what post-pandemic commerce, employment, and traffic patterns will look like – the entire effort should be paused until the pandemic subsides.” — Linda Rosendorf, Don’t Widen 270

“Had the Governor and the Maryland Department of Transportation followed a process that allowed for sufficient constituent input and alternative proposals before announcing this massive, destructive plan, the citizens of Maryland would not be in the position of pointing out the obvious. The plan is deeply flawed and may very well cause more harm than good.” — Cecilia Plante, Maryland Legislative Coalition

Source: Sierra Club of Maryland

Links for Information

https://495-270-p3.com/wp-content/uploads/2020/07/DEIS_June-2020.pdf

https://495-270-p3.com/virtual-hearing/

https://495-270-p3.com/

https://montgomeryplanningboard.org/wp-content/uploads/2020/07/5d.-I-495-I-270-Managed-Lanes-Study-DEIS-Comments.pdf

Read the Documents at Montgomery County Libraries:

Potomac Library; Chevy Chase Library; Davis (North Bethesda) Library; Kensington Park Library. Hard copies will be available in trailers in the library parking lots. Viewing hours: Tuesday and Thursday 11 AM to 7 PM, and Sunday 12 to 5 PM. Once libraries are open to the public, the hard copies will be available for review in the libraries during normal branch hours.

Get Involved

Public Hearings:

The Federal Highway Administration, Maryland Department of Transportation State Highway Administration, the Maryland Department of the Environment (MDE) will conduct six public Hearings. The U.S. Army Corps of Engineers (USACE) will participate in one hearing on August 25. The public will have 3 minutes to provide their testimony and registration is required for both virtual and in-person hearings. Hearing materials can be viewed starting July 31 at the document availability locations or on the program website.

THURSDAY, SEPT. 10, 2020 – Montgomery County

Hilton Executive Meeting Center

1750 Rockville Pike

Rockville, MD 20852

Virtual Meetings

Four virtual hearings are planned from 9 a.m. – 8 p.m.:

Tuesday, Aug. 18

Thursday, Aug. 20

Tuesday, Aug. 25

Thursday, Sept. 3

https://495-270-p3.com/

Give Feedback

Comments on the I-495 and I-270 Managed Lanes Study Draft Environmental Impact Statement/Draft Section 4(f) Evaluation will be accepted between now and Oct. 8, 2020 by 11:59 p.m. MDOT SHA and FHWA will review all comments and consider and respond to all substantive comments received in the preparation of the Final Environmental Impact Statement. See https://495-270-p3.com/your-participation/provide-feedback/

Email at MLS-NEPA-P3@mdot.maryland.gov

Send a written letter about DEIS:

Lisa B. Choplin, DBIA

Director, I-495 & I-270 P3 Office

Maryland Department of Transportation State Highway Administration

I-495 & I-270 P3 Office

707 North Calvert Street

Mail Stop P-601

Baltimore, MD 21201

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