Statement of
On The
Draft Environmental Impact
Statement
And
Draft Section 4(f)
Evaluation
For The
Intercounty Connector
Submitted To The
Streamlined Joint
Environmental Review
With Concurrence From
U.S. Army Corps of
Engineers
Maryland Department of the Environment
In Cooperation With
U.S. Environmental
Protection Agency
U.S. Fish and
Wildlife Service
National Park
Service
Maryland
Department of Planning
Maryland
Department of Natural Resources
Maryland National Capital Park and Planning Commission
Tuesday, January 4, 2005
Introduction
My name is Norris McDonald and I am the founder and president of the African American Environmentalist Association (AAEA). This written statement is being submitted to express our support for the Intercounty Connector (ICC). AAEA supports the connector because it will enhance human ecology in the Washington Metropolitan Area without significantly impacting animal and plant ecologies.
The Draft Environmental Impact Statement (DEIS) is required by the National Environmental Policy Act of 1969 (NEPA) and the Draft Section 4(f) Evaluation is required by the Department of Transportation Act of 1966, which is intended to help preserve public park and recreation lands, wildlife habitat, waterfowl refuges and historic sites.
AAEA supports Corridor 1 over Corridor 2 unless the latter can eliminate the southern route in Prince George’s County. AAEA supports Corridor 2 if the unusual southerly direction can be eliminated and if a northerly route can connect to I-95 north of I-198 near Brooklyn Bridge Road. We prefer Corridor 2 because it is farther out from I-495 and, if our changes were incorporated, it would reduce travel times even more between Baltimore and I-270. The Corridor 2 northern route could go from the Burtonsville Shopping Center area to the vicinity of Brooklyn Bridge Road area to connect with I-95. We would eliminate the connection to U.S.-1 with this alternative.
The Washington Metropolitan Area needs an outer beltway. The ICC is the least of the improvement we need in the Washington Metropolitan Area to efficiently move our vehicles. The Woodrow Wilson Bridge replacement and the improvements at the ‘Mixing Bowl’ will significantly improve mobility in the Washington Metropolitan Area. Unfortunately, these improvements, along with an outer beltway should have been made two decades ago. We are just catching up to the roadway needs of the region. We should also begin the process of building a subway beltway to increase metro rider ship. Of course, that is not the subject of this hearing.
The African American Environmentalist Association was founded in 1985 and is a national, nonprofit organization dedicated to protecting the environment, promoting the efficient use of natural resources, enhancing human, animal and plant ecologies and increasing African American participation in the environmental movement. AAEA is based in the Washington, DC Metropolitan Area with chapters nationwide and members worldwide.
Project Purpose
The main reason that AAEA supports the connector is because we want parents to get home to their children sooner. We also want businesses and the general public to have mobility options that will reduce travel times. This is the fundamental purpose of the connector - - to move more people around faster. We believe that the connector will accomplish this goal with very little impact to the environment. Congestion on the I-495 Beltway is unbearable at times. The Intercounty Connector should have been built twenty years ago.
The purpose of the ICC is in conformity with AAEA goal number three: “Enhance human, animal and plant ecologies.” The ICC enhances the human ecology by improving mobility, while assuring minimal impacts to animals and plants. Again, the benefit to parents getting home to their children earlier is incalculable. We wish that there were no such thing as a latchkey kid. To the extent that modern society dictates such circumstances, at least we can do everything we can to get parents home earlier. This can also be done while enhancing economic development because businesses can move goods and services around more efficiently.
Environmental Stewardship
AAEA believes the connector will have little impact on the north-south stream valleys and parks. We have walked portions of all of the tributaries to the Anacostia River. We believe that a low-impact highway can be built between I-270 and I-95/U.S.-1. Plans call for the connector to be built in an environmentally sensitive manner using techniques to avoid, minimize and mitigate impacts. Just as I-495 provides almost incalculable benefits to the public in the Washington Metropolitan Area with minimal direct environmental impacts, so to will the connector. Because the connector will be going through an already highly developed area (Corridor 1), there will actually be opportunities to incorporate restoration enhancements and improvements to natural, cultural and community conditions. We understand that the Study Team is proposing environmental stewardship features that are above and beyond what is required for compensatory mitigation.
Upon reviewing the information in Table 3 of the ICC Study that includes descriptions of the socioeconomic/cultural environmental resources, natural environmental resources and cost estimates, AAEA selects the following options along Corridor 2:
Segment 1: Rock Creek Option A
Segment 2: No options
Segment 3: No options
Segment 4: No options
Segment 5: Option A: terminate ICC at US-1 (An Option C should include termination at I-295)
Segment 6: Without Interchange at Layhill Road. Spencerville Option A with ICC over Good Hope Road to Burtonsville Option B. Spencerville Option C to Burtonsville Option B.
Segment 7: We do not support this southern route. We understand the attractiveness of the route because of the open land between I-198 down to I-95, but Baltimore motorists will have to backtrack using this route.
Segment 8: We do not support his southern route.
AAEA selects the following options along Corridor 1:
Segment 1: Rock Creek Option A
Segment 2: No options
Segment 3: Northwest Branch Option A without interchange at Layhill Road.
Segment 4: No options
Segment 5: Option A [terminate ICC at U.S.-1
Segment 6: No options
Segment 7: No options
Segment 8: No options
Socioeconomic Environment
The ICC DEIS conducted an Environmental Justice analysis and a Community Impact Assessment. These analyses indicate no significant impact because of the project. The ICC will enhance minority communities in the Washington Metropolitan Area by improving mobility. The project is not complicated by cutting off a minority community from the larger community that is part of many transportation equity complaints. We also understand that information on Title VI of the Civil Rights Act will be available at the public hearings.
The ICC DEIS Environmental Justice analysis concludes that, “Based on the results of the technical studies conducted for this project, it has been determined that all areas that contain low-income or minority populations would experience benefits or changes similar to those of the overall study area population, and would not experience disproportionately high and adverse effects. Moreover, to the extent that mobility is enhanced between Baltimore and the I-270 and Dulles Toll Road corridors, and Prince George’s County and these same tech corridors, it will enhance opportunities for minority companies and entrepreneurs.
Corridor 1 has fewer Section 4(f) sites than Corridor 2. Corridor 1 has fewer adversely affected National Register of Historic Places Eligible Properties. Corridor 1 has fewer business community facility displacements but more residential displacements than Corridor 2. Corridor 1 has fewer total right of way acres than Corridor 2. Corridor 1 has more noise-impacted areas than Corridor 2.
Smart Growth
We favor Corridor 1 from a Smart Growth perspective. Corridor 1 fulfils the goals of the Smart Growth initiative because it is already close to water, sewer, electric, gas, schools and other established infrastructure. Corridor 1 has been included in several master plans and impacts are less because Corridor 2 was never planned and goes through more rural communities. The University of Maryland’s Maryland Transportation Initiative (MTI) economic analysis indicates that estimated annual travel timesavings are valued at $203 million for Corridor 1 for trips originating or destined to the ICC impact area in 2010. Corridor 1 would also provide greater travel time savings benefits ($250 million) than Corridor 2 ($210 million). Annual vehicle operating cost savings are estimated at $11 million in 2010 and $15 million in 2030 for Corridor 1. The improved reliability due to an ICC for travel to or from the ICC impact area is estimated to be approximately $100 million annually. Total user benefits are estimated to exceed $300 million in 2010 and $370 million in 2030 in the ICC impact area for Corridor 1.
Although Corridor 2 lies outside of a Priority Funding Area (PFA) as defined by the Maryland Smart Growth Initiative of 1997, we believe that the mobility enhancements outweigh additional costs to the counties to provide the necessary public facilities required to handle development. The MTI economic analysis indicates that estimated annual travel timesavings are valued at $172 million (in 2004 dollars) for Corridor 2 for trips originating or destined to the ICC impact area in 2010. Annual vehicle operating cost savings are estimated at $9 million in 2010 and $14 million in 2030. The improved reliability due to an ICC for travel to or from the ICC impact area is estimated to be approximately $87 million for Corridor 2. Total user benefits are estimated to exceed $255 million in 2010 and $310 million in 2030 in the impact area for Corridor 2. The University of Maryland study team concluded that if Corridor 2 is selected, business establishments would generate about 16,850 new jobs in the ICC area of influence, with about 10,460 in Montgomery County and about 6,300 in Prince George’s County. Approximately 16 miles of Corridor 2 lies in Montgomery County and four miles lie in Prince George’s County.
The economic benefits generated by the ICC will more than adequately provide funding for any community water and sewer, school facilities or other public facilities that might be required to handle development in the impact area.
Natural Environment
AAEA is confident that the ICC can be built without significantly impacting wetlands and forested areas. The connector will have a very small footprint that should not significantly upset area flora and fauna. Corridor 2 will have less impact than Corridor 1 on the trout spawning and nursery habitat of Paint Branch.
The ICC will have longer bridge lengths, which will protect wetlands, vegetation, habitat, wildlife and streams. The ICC will utilize state-of-the-art culvert design techniques. The ICC will span streams and floodplains with bridges rather than culverts. Construction will minimize the number of trees that have to be removed and will avoid or minimize impacts to ecologically sensitive areas.
Corridor 1 has fewer wetlands acres in the impact area than Corridor 2. Wetlands acres created by mining are about equal in Corridor 1 and Corridor 2. Corridor 1 has more streams per linear feet than Corridor 2. Corridor 1 has more acres of floodplains than Corridor 2. Corridor 1 has more forest area acreage that Corridor 2. Corridor 1 would result in filling in fewer acres of the 100-year floodplain than Corridor 2.
Neither corridor has a listed species under the Federal Endangered Species Act. Both corridors have 1-3 plant species listed under State threatened, endangered or avoidance regulations.
Corridor 1 impacts less farmland than Corridor 2. Both Build Alternatives impact parks and historic sites pursuant to Section 4(f) of the U.S. Department of Transportation Act of 1966. Corridor 2 impacts significantly more parks and historic sites under this provision than Corridor 1.
Air Quality
The Washington Metropolitan Area is a non-attainment area for ozone. AAEA has serious concerns about air quality. One penalty under the Clean Air Act calls for a moratorium on funding for new highways for regions in violation of the clean air law. Of course, highways do not cause air pollution. Cars and stationary building sources cause air pollution. AAEA is working and will continue to work to solve the emissions problems that cause air pollution. The Metropolitan Washington Council of Governments, which analyzes impacts of future transportation projects on air quality, has determined that the ICC would be in conformity with the State Implementation Plan (SIP) for air quality.
Build Features
The ICC will have a small footprint similar to I-295. Just as I-295 provides valuable access to Baltimore and other Northern regions with a very small footprint and provides a parallel artery to I-95 for such access, it is a good comparison for how the ICC will work. ICC features include:
· Six-lanes (three in each direction)
· Limited Access
· Electronic tolls with no toll plazas
· Low roadway profile
· Other environmental stewardship features.
Corridor 1 Alternative. AAEA supports the Corridor 1 Alternative over the Corridor 2 Alternative because of Smart Growth considerations and because of the unnecessarily circuitous route of Corridor 2 in Prince George’s County
Corridor 2 Alternative. AAEA prefers the Corridor 2 Alternative because it is farther out from the I-495 Beltway and significantly reduces travel times between Baltimore and I-270. We only wish that the route would proceed farther to the north at I-95.
Tolls
We oppose the toll collection proposal because it will be burdensome. Not all users will be registered for the electronic toll collection, so some system will have to be established to deal with this problem. It will lead to a toll plaza sooner than later. The video tolling system is also cumbersome. The ICC should not be a toll road. A toll will increase congestion and delays and is contrary to the very purpose of the ICC. The toll also represents a burden on low-income people.
Cost
Corridor 1 costs more than Corridor 2. These costs should be somewhat offset by the fact that Corridor 1 is in a Smart Growth Priority Funding Area.
Travel Times and Reliability
This section of the DEIS shows significant reductions in travel times between specific destination points. This is the major benefit of the ICC. The trip from Gaithersburg to the Baltimore Washington Airport will be reduced by about 30 minutes using Corridors 1 and 2.
Jobs
Corridor 1 creates an additional 156,000 jobs and Corridor 2 creates 107,000 jobs accessible within a 45-minute commute.
Rocky Gorge Reservoir
Corridor 2 could have direct impacts on the Rocky Gorge reservoir watershed, particularly the northern path proposed by AAEA. Corridor 1 does not cross the Rocky Gorge watershed and would not impact the reservoir.
Conclusion
AAEA’s preferred alternative for the ICC is Corridor 1 unless a northern route can be instituted for Corridor 2. The ICC is needed to enhance home life for families in the Washington and Baltimore Metropolitan Areas. The ICC is needed to improve economic development conditions in the Washington and Baltimore Metropolitan Areas. The ICC will have minimal environmental impacts in the Washington Metropolitan Area. Any small impacts are being addressed with mitigation measures that more than adequately resolve environmental protection issues. The ICC provides an environmentally friendly solution to congestion in the Washington Metropolitan Area.