Jump on This! A 15-Day Extension to Tell MDOT and the FHWA what’s Wrong with the Toll Lanes. New deadline: 11/30

We need to grab this chance to submit public comments, even if the circumstances show MDOT’s lack of respect for the public:

  • MDOT ignored calls from elected officials for a 90-to-120 day public comment period.

  • MDOT delayed granting the extension until COB on the very last work day before the original deadline.

  • MDOT deliberately limited the extension to the 15 days that include the year’s busiest travel and shopping periods plus Thanksgiving and Hanukah.

No matter: We will be heard

Consider this issue of the newsletter a mini-tour of project deficiencies and low-lights. All the items below will give you information and ideas for your comments on the project’s Supplemental Draft Environmental Impact Statement (SDEIS). Note:

  • Comments can be as short or involved as you want.

  • If you’ve submitted a comment already, thank you, and consider writing another on different points (there’s no shortage of points).

How to submit your comments

Do any of the following by 11:59 p.m. on Tuesday, November 30 (click here to access all instructions):

Start every comment the same way

Use these words near the beginning of your comment so MDOT cannot misrepresent your intent (something they’ve done before) when they tally public opinion: “I support the no-build option and oppose the I-495/I-270 toll-lane project.”

Take inspiration and ideas from the Rockville Mayor and Council’s powerful SDEIS comments:

  • “It is critical that MDOT and [the Federal Highway Administration] reinstate transit as a key project element...”

  • “The Purpose and Need omits safety considerations typically featured for transportation projects...”

  • “…implementing only Phase 1 South will create a major congestion and bottleneck in the eastbound direction at the points where the managed lanes end…and cause an existing chokepoint to get even worse.”

  • “The issue of economically challenged populations or social equity continues not to be adequately addressed by the SDEIS.”

Tell MDOT that Innovative Congestion Management (ICM) on lower I-270 works; toll lanes won’t!

  • If you use lower I-270 now, you know that barring an accident, construction, or storm, traffic is generally free-flowing.

  • The welcome congestion relief was created by MDOT’s ICM program, which began in 2017 and is now 77% complete.

  • The ICM program installed ramp metering, extended merge lanes to create extra through lanes, converted a shoulder to an HOV-2 lane, and turned an old HOV-2 lane into an extra through lane.

  • But the toll-lane project would destroy the taxpayer-funded ICM improvements on lower I-270, create congestion where there is none, and make the notorious I-270 northern bottleneck even worse.

  • Lower I-270 will be irreparably harmed by toll lanes. Read all the details here.

Point out that the SDEIS traffic model is spectacularly flawed

  • Our partner, the Maryland Transit Opportunities Coalition, found that, “The output of the SDEIS’s traffic model is contrary to common sense, logic, and traffic forecasting done by MDOT itself….”

  • Read here why MTOC, DontWiden270.org, and Citizens Against Beltway Expansion called for retraction of the SDEIS until the failed traffic model could be fixed.

Consider these excellent points from our partner Citizens Against Beltway Expansion

Click here for paragraph-long summaries of the items below, and more:

  • “After enduring 5 years of construction delays, drivers who use the general lanes [northbound from the American Legion Bridge to the intersection of I-270 and I-370] will be rewarded with a 7 minute and 30 second increase in their daily commute, round trip.”

  • 500 acres of tree canopy would be cut down.

  • 15 parks would be harmed, including 3 national parks.

  • MDOT would not treat most of the stormwater runoff, which would further degrade local waterways.

  • MDOT did not analyze the impact on global warming.

  • There is no assessment of whether low-income communities or communities of color would suffer more of the harmful impacts.

Give MDOT your opinion of the sky-high tolls just approved on 11/18/21

See the table of final tolls here (p.78 of the file). Note:

  • The maximum toll rates apply when there’s heavy congestion, the only times most people would consider using toll lanes.

  • The tolls in the table are in 2021 dollars. Given the approved yearly escalation rate, tolls for passenger vehicles will be well over $4/mile when the toll lanes open. That means $50 tolls to drive from the George Washington Parkway to Shady Grove!

  • Note the exorbitant tolls for multi-axle trucks. The cost will drive big rigs into the general lanes, causing more -- and more serious -- accidents, extra wear and tear on the roads, more trucks on secondary roads, etc.

Call MDOT on the project’s outrageous financial risk to taxpayers

  • This truth-telling editorial in the Washington Post says it all: “Hogan has claimed that the lanes would have ‘virtually no cost to taxpayers,’ because the 50-year deal…would be paid for using private financing. That’s not true.”

  • The public’s going to pay for those toll lanes one way or another: through sky-high tolls, taxes, fees, assumption of financial risk, compensation to the rapacious Australian contractor for revenue shortfalls, and much, much more.

Please submit your comments to MDOT ASAP. The deadline is 11/30!

Please share this newsletter widely so others will know to submit comments, too. Thank you!

MDOT Grabs Another $45M from Taxpayers for Toll-Lane Boondoggle! Write to MDOT by 11/15: U.S. Law Says Our Comments Count!

 Read all about our critically important action item right after this shocking, $45M news.

 

That’s our public money!

MDOT keeps claiming the P3 comes at no net cost to taxpayers. But the Board of Public Works just voted 2-1 (the Governor and Comptroller “for”) to add $45M to a $90M project support contract.

And who did Hogan and Franchot blame? The public!

Brace yourself, and then read the transcript of the shameless pre-vote discussion. Only Treasurer Nancy Kopp defended the public interest.

 

Action Item: Submit your SDEIS public comment! Deadline is November 15

 

The public has just a week left to submit comments on the P3 Supplemental Draft Environmental Impact Statement (SDEIS).

MDOT and the Federal Highway Administration (FHA) carefully track the number of comments received and whether they’re favorable/unfavorable to the toll lanes. By law, MDOT must reply to substantive comments.

Write now! The deadline is 11:59 on November 15.

Be sure to start your comment with: “I support the no-build option and oppose the I-495/I-270 toll-lane project.”

To submit your comment, do any of the following (click here to access all instructions):

Jeffrey T. Folden, P.E., DBIA
Director, I-495 & I-270 P3 Office Maryland Department of Transportation State Highway Administration
707 North Calvert Street
Mail Stop P-601, Baltimore, MD 21202

 

Our valued partner Citizens Against Beltway Expansion (CABE) created an excellent summary of SDEIS Points and Deficiencies to guide your writing. Pick your preferred topics -- CABE’s summary has details on all these important subjects:

  • Toll lanes won’t improve daily commutes

  • Taxpayer subsidies

  • Relocating utilities

  • Pollution and global warming

  • Harm to parks and other greenspaces

  • Selected impacts on Rockville

  • Environmental justice issues

  • Failure to study alternatives to toll lanes

 

Will SDEIS public comment period be extended?

 It’s a nail biter. Some very smart elected officials sent powerful requests for an extension, but so far MDOT hasn’t budged. Read the persuasive letters to MDOT and FHA from:

Sometimes all you need is a picture

Look at what MDOT and Transurban have planned for us at Cabin John Parkway and the Beltway, should the toll-lane scheme be implemented. Imagine driving this. Or living nearby. And remember that the SDEIS showed virtually no gains in rush hour drive times after all this is built.

Purple = Toll-lanes
Orange = Flying overhead ramps
Yellow = General purpose “free” lanes
Hot Pink = Limits of disturbance, which our experts say are underestimated
Boxed comments = MDOTs own “identifiers”

Toll-lane traffic model just found to be invalid, illogical, and wrong (a lot like the rest of the project). We’ve got til 11/15 to tell MDOT: “We’re on to you!”

The absurdities of MDOT’s traffic forecasting claims (adding toll lanes in Bethesda ends traffic jams near Annapolis??) were just uncovered by our valued partner, the Maryland Transit Opportunities Coalition. Accurate traffic forecasts are critically important. If they can’t be trusted, then MDOT’s Supplementary Draft Environmental Impact Statement (SDEIS) -- the public’s only means of evaluating the P3 project -- can’t be trusted either. DontWiden270.org and other grassroots groups are urging the Federal Highway Administration to require a do-over.

Right now, though, we’ve got an 11/15 deadline to submit public comments on the SDEIS. And public comments matter! You’ll find commenting tips and details below, including a handy guide to toll-lane facts that should convince any skeptic that MDOT’s up to no good.

*** Important Action Item ***

Register for the Maryland Sierra Club’s virtual call-to-action event on legal strategy for fighting the toll lanes: Tuesday, October 26 at 7 p.m. You’ll be welcomed by former MD Governor Parris Glendening, hear an update on the P3 project, and learn how you can support the Sierra Club’s plans to stop the toll lanes through the work of the Maryland Smart Growth Defense Fund.

Much of the fight against the P3 has to be waged on legal and procedural grounds, and that requires smart, effective legal and subject matter expertise. We’re grateful the Sierra Club is working to find and leverage that expertise. The people they engage do some pro bono work, but this effort still takes considerable funds.

Please support the Maryland Smart Growth Defense Fund. It helps resource the legal strategy shared by our coalition of advocacy groups and is entirely devoted to stopping the toll-lane expansion.

Comments on the SDEIS needed! Please submit yours by 11/15. Numbers matter!

As of this writing, MDOT has granted no extension of the 45-day public comment period for the SDEIS. The current deadline is November 15.

You have the following commenting options. Click on the links below for specific instructions, or access all instructions here:

The 8,000+ page SDEIS, issued by MDOT on October 1, was supposed to give detailed information about the impact of the American Legion Bridge/I-495/I-270 project on the physical, cultural, and human environment. But the SDEIS, like the DEIS before it, lacks adequate information, analysis, and mitigations in critically important areas.

To inspire your SDEIS comments, refer to the handy guide below. You’ll also find a list of additional issues you might like to include.

A handy guide to what’s wrong with the toll lane project

Staying on top of the I-495/I-270 P3 is hard. So many moving parts and rabbit holes, so many intentional obstacles. To inspire your SDEIS comments and help you cut through the noise, we’ve put together this very abbreviated guide to refer to and share, especially with those who still need convincing that the toll lanes won’t work.

What We Know - The project’s traffic model lacks credibility.

How We Know - Analysis of traffic forecast cites pervasive errors.

What We Know - Hogan prevented an independent financial review of the P3 agreement.

How We Know - He denied State Treasurer’s funding request for financial and legal analysis (p. 6).

What We Know - The toll lanes will not help congestion.

How We Know - Free lanes will go only 7 mph for long stretches in PM rush. Bottlenecks get worse.

What We Know - The tolls will be sky-high. *

How We Know - Apply the cost escalation rate (p. 36) to the 2020 maximum toll rates (p. 22) and get $50 tolls to go 12 miles in 2026.

What We Know - Toll-setting reflects the skewed population in a key study.

How We Know - Only 27% of invited participants in this study had household incomes under $100k (p. 57).

What We Know - The full Beltway is back in the plan.

How We Know - See MDOT’s new project map.

* If you want to comment on those sky-high tolls one more time, you have til 10/28 to call the MD Transportation Authority at 855-701-1977 and leave a message; or click here to use the comment form.

Here are more topics you might like to include in your SDEIS comments

These issues are either inadequately addressed or not addressed at all in the SDEIS:

  • Impact of telework on congestion

  • Impact of induced demand

  • Increased traffic on local roads

  • Impact of 5 years of construction, and related disruptions, noise, pollution

  • Unspecified/underestimated Limits of Disturbance

  • Necessity of relocating utilities – and determining who pays

  • Air quality/air emissions, including particulate matter and the cumulative impacts of greenhouse gases

  • Climate change analysis

  • Stormwater management and water quality monitoring

  • Issues of environmental justice

  • Significant loss of tree cover, park land, and wildlife

  • Loss of portions of homeowner property (note that MDOT has said no homes will be taken for Phase 1 South)