February 18, 2004

Chairman Chris Zimmerman
Chair, Transportation Planning Board
Metropolitan Washington Council of Governments
777 North Capitol Street, N.E., Suite 300
Washington, DC 20002-4290

Dear Chairman Zimmerman Members of the TPB,

In Item 10 for today’s meeting, the State of Maryland is asking to include the Intercounty Connector (ICC) into the Constrained Long Range Plan (CLRP) and Transportation Improvement Program (TIP), along with accelerating several other highway projects. We strongly oppose inclusion of the ICC into the CLRP and TIP, and urge you to vote to delay any consideration of this CLRP and TIP amendment until completion of the ICC EIS process and the COG-TPB Regional Mobility and Accessibility study.

This would be the first time in the TPB’s history that a segment of the Outer Beltway would be included for construction. If you approve the ICC, you will be making an irrevocable, and damaging, decision about the future growth pattern of the region. In fact, the ICC will undermine the $10 billion investment in the Metrorail system and shift yet more economic development from Prince George’s County and the eastern side of Washington, DC.

This is a decision which goes to the very heart of your Federal charter and responsibilities as a Metropolitan Planning Organization (MPO) for a financially constrained long range plan that works toward improving air quality and that accounts for public input and environmental justice and economic equity. You have had plenty of public input over the last decade, and never in the TPB process has there been consensus support for the Outer Beltway. In fact, this one issue has divided the public, the groups most involved with the TPB, and the TPB itself, more than any other.

A review of the “Getting There” public visioning process of 1996-97 shows that the broadest support was for things other than Outer Beltways, including transit, transit-oriented development, more compact, walkable growth patterns, and pedestrian and bicycle investments. In fact, the Board of Trade was so concerned about the lack of support for the Outer Beltways that they issued their own series of Transportation Reports in 1997.

We in turn, issued a response titled “Highway Robbery,” which makes the case for a transit and land use alternative to Outer Beltways. This is just one of a series of reports and analyses by non-profit groups and government agencies over the last decade which demonstrate the benefit of transit, transit-oriented development, and mixed-use walkable communities over that of Outer Beltways and more sprawl development.

The “Network of Livable Communities” report and Montgomery’s Balanced Land Use Scenario show that this approach would reduce vehicle miles traveled, vehicle trips and air pollution. In fact, the Balanced Land Use scenario showed that shifting more jobs to southeastern Montgomery County, and by implication to Prince George’s, and adding more housing to the job-rich I-270 Corridor with additional transit, would perform as well as, or better than, the ICC and have fewer environmental impacts. The BLU approach reduces east-west commutes by bringing more jobs to Prince George’s County and reduces vehicle miles traveled and air pollution. We have submitted to you a short history of the land use and transportation discussions in the region, and it should be included in your packet.

In short, a decision to include the ICC in the CLRP would represent a vote for an Outer Beltway over a transit, smart growth and transit-oriented development solution for the region, one that has had strong support over many years and has been shown to meet regional air quality, transportation, and economic equity goals.

We urge you to oppose this step for the following additional reasons:

1. Failure to Address Traffic Congestion: The last Draft Environmental Impact Statement found that: “None of the ICC alternatives will have a substantial impact on the levels of service [congestion] experienced by motorists on the Capital Beltway, I-270 or I-95 within the Study Area.’”(DEIS on the Inter County Connector, Volume 3, VI-23).” In addition, an M-NCPPC study found that the ICC would not shorten travel times to Baltimore-Washington International or Dulles airports.

2. Increased Air Pollution: The addition of a 6-lane, 18-mile highway will inevitably increase vehicle miles traveled and air pollution for our region, which is already in SEVERE non-attainment. This region and the EPA have just lost three air quality lawsuits for failure to adequately reduce mobile source pollution. Failure to meet clean air standards could lead to a cut-off in federal funding for badly needed projects in all jurisdictions.
   1. The “GoMontgomery” plan with the ICC showed a 39% increase in highway vehicle miles traveled over future baseline conditions. The DEIS showed that the ICC itself would lead to a greater than 9% increase in VMT over baseline conditions on both the ICC and local roads. The ICC would induce sprawl development and additional long-distance commuting without reducing traffic.

   2. The ICC is being funded in part by cuts in transit service, which will in turn contribute to increases in air pollution.
   3. By pursuing the ICC, Maryland will be taking advantage of recent expenditures for adoption of additional TERMS by all three jurisdictions. It should be of particular concern to DC that they have expended air quality funds to allow construction of a highway, which will shift jobs and investment away from the city.

   4. Approximately 50,000 children and 100,000 adults suffer with asthma in the Washington region, a condition worsened by ozone pollution

3. ICC Would Cause Significant Harm to Watersheds and Water Quality: Building the ICC would undermine local, state regional efforts to restore the Anacostia River, Potomac River and the Chesapeake Bay. The ICC would slash across the headwaters of Rock Creek and four major Anacostia tributaries, and would encroach upon the Patuxent watershed, where it would threaten a major drinking water reservoir. The ICC’s environmental and parkland impacts can not be mitigated, according the U.S. Environmental Protection Agency.

4. Financial Plan is Not in Place: The ICC would not meet financial constraint requirements that bind MPO’s, since the funding plan, including extensive use of GARVEE bonds and tolls, is completely speculative. The document included in Item 10 is titled “ICC Conceptual Funding Plan – Options.” This is not a plan. In fact, with the potential cost of the ICC, including financing costs, at $3 billion before any construction cost overruns, this project will place all transit and other road projects within the Maryland side of the region at risk.

5. WMATA (METRO) Funding Will Suffer to Pay for the ICC: The administration of Governor Ehrlich has been in the process of seeking operating cuts from WMATA including bus routes and Metrorail service, and has not supported the 4.5% operating support increase that Virginia and DC are supporting. To date, Maryland is not providing its share of METRO’s need for $1.5 billion to meet maintenance and ridership service improvements, including new railcars and buses, and electrical system upgrades for 8 car trains. The TPB has passed a resolution to state that one regional need is a funding priority, and that is METRO. There is no question that the ICC will be funded at the expense of METRO and other transit needs in Montgomery and Prince George’s Counties.

6. Will Increase Regional Economic Inequities: TPB’s own study of the I-270 expansion demonstrated that it shifted jobs and population from Prince George’s County and DC. Our WTC/Techway study demonstrated the same effect. The ICC would shift more jobs to I-270 and Montgomery County in general, at the expense of Prince George’s County. Montgomery already has 5 times the number of jobs as Prince George’s. The highway will exacerbate the “Region Divided” (Brookings Institution study) and ensure that Prince George’s residents must commute to Montgomery jobs and will continue to suffer some of the longest commutes in the region. We believe that this will cause the COG region to run afoul of the Federal civil rights laws as they relate to our transportation program.

7. $10 Billion Investment in Metrorail Will Be Undermined: Our region has invested $10 billion in the Metrorail system, yet dozens of Metro stations have no transit-supportive land use. Thirteen stations in Prince George’s County have almost no development at the stations. The reverse commute capacity of the system is almost completely untapped. Yet, the $3 billion ICC will bypass this investment, opening new land to development and shifting commercial development away from the station areas.

8. ICC Studies Are Not Complete; Past Study Found No Congestion Relief on Key Routes: The Draft Environmental Impact Statement has hardly begun and its impacts and costs have not been reanalyzed. The DEIS that was completed found that “None of the ICC alternatives will have a substantial impact on the levels of service [congestion] experienced by motorists on the Capital Beltway, I-270 or I-95 within the Study Area.’”(DEIS on the Inter County Connector, Volume 3, VI-23).” Federal agencies objected to the ICC in the last DEIS, and Governor Glendening cancelled the project because the traffic benefits were minor and outweighed by the financial and environmental cost.

9. COG-TPB Regional Studies Are Not Complete and Evaluated:
   1. Regional Mobility and Accessibility Study: COG and the TPB are to be credited for embarking on a multi-year land use and transportation analysis. First requested over a decade ago, this process is intended to analyze land use changes first, before selecting transportation projects for the CLRP. This analysis has already missed at least one CLRP update cycle, but must be completed and its results considered before evaluating the ICC for the CLRP. Otherwise, the rapid inclusion of the ICC, while ignoring the Regional Mobility study, will make a mockery of this long process which has engaged so many of the region’s citizens, planners and elected officials.

   2. “Getting There” Public Vision: The ICC fails to conform to the vast majority of citizen recommendations from the TPB’s regional transportation and land use visioning process, “Getting There.” Hundreds of citizens spent many months in discussions in 1995 and 1996 and drafted three reports. The “Quality of Life” and “Access to Opportunities” reports devote overwhelming attention to transit, transit-oriented development, revitalization of DC, pedestrian and bicycle friendly communities, and open space and environmental protection.

10. Current ICC Study is Predetermined and TPB Should Not Endorse Such a Process: The TPB should not lend its stamp of approval to an EIS process which has been designed to reach a predetermined outcome and fails to include the full range of alternatives.
    1. Governor Ehrlich himself has titled his transportation secretary as “Bob I Will Build It Flanagan,” and said unequivocally that the highway will be built.

    2. The Purpose and Need Statement has been intentionally drafted to ensure a highway will be built. MDOT documents on the website and provided at hearings state that transit and balanced land use alternatives will not be considered because, “This alternative would not provide for a limited-access, multi-modal highway that accommodates people and goods.” The Purpose and Need is limited to linking I-270 and I-95/Route 1 with a state-of-the-art, multi-modal, east west highway. Requests by the environmental community for a transit and land use alternative were rebuffed.

11. Outer Beltways and Bypasses Do Not Fix Congestion:
    1. The Texas Transportation Institute study so often cited for ranking our region’s congestion, also shows that our highway lane mile expansion slightly surpassed our population growth. TTI data also shows that regions that added lots of new highway capacity did no better, and sometimes worse, than regions that added very little new capacity.

    2. A primary reason is the problem of induced traffic. One study by Noland showed that in our region an average of 51% of new capacity is consumed by new traffic generated by the facility. Rather than reduce traffic, the ICC and other outer beltway segments shift development and lead to additional traffic while not relieving existing roadways.

    3. Data from the Transportation Policy Report by Montgomery County shows that a $9 billion road heavy approach with the ICC did no better and sometimes worse than a Balanced Land Use and transit approach that cost $1 billion less and had far fewer environmental impacts.

    4. A comparable bypass effort was I-287, an outer beltway for New York City through watershed areas in northern New Jersey. A 1996 New York Times article documents that the new road led to more traffic on connecting routes and failed to reduce traffic at the George Washington Bridge as intended.

Sincerely,

(via email)

Stewart Schwartz
Executive Director