Comments on 3rd Bay Crossing Draft Environmental Impact Statement

Gregory Murrill
Division Administrator
Federal Highway Administration
George H. Fallon Building
31 Hopkins Plaza, Suite 1520
Baltimore, Maryland 21201

James F. Ports, Jr.
Executive Director
Maryland Transportation Authority
Point Breeze
2310 Broening Highway
Baltimore MD 21224

Re: Comments on 3^rd Bay Crossing Draft Environmental Impact Statement

Our position

The undersigned organizations, having considered all the alternatives contained in the Chesapeake Bay Crossing Draft Environmental Impact Statement (DEIS), strongly support the “no build” alternative.  We ask that the Final Environmental Impact Statement contain a full evaluation of how an electric bus/minibus and van rapid transit (BRT) system together with Transportation System Management/Transportation Demand Management (TSM/TDM) and an electric ferry system could best be combined into a fully-integrated, flexible solution that is a viable alternative to a new bay crossing.

How alternatives were considered

The DEIS was supposed to comply with the National Environmental Policy Act and consider a reasonable range of alternatives. Unfortunately, it did not do so. Instead, the DEIS authors adopted a conclusions-first approach that eliminated serious consideration of any alternative other than what they wanted – a 3^rd bay crossing corridor selected from among 14 corridors considered.  The way the study’s purpose and need criteria were written, each alternative had to provide:

• adequate capacity
• dependable and reliable travel times
• flexibility to support maintenance and incident management in a safe manner, and
• financial viability (i.e., be fully self-funding). 

Modal and operational alternatives (MOAs) such as BRT, a ferry service, and TSM/TDM were each considered only as a stand-alone alternative so were eliminated from consideration because they were not viable by themselves.  A combination of the MOA in an integrated solution would have met the above criteria and would have done so in a safe, equitable, and much more environmentally friendly manner than how traffic is handled now.  Unfortunately, the Maryland Transportation Authority (MDTA) structured the study to prohibit consideration of such an alternative.  

Why no-build is the best alternative?

There are a number of reasons why “no-build” should be the preferred alternative, and that  significant improvements should instead be made in existing infrastructure and traffic management processes

The impact of climate change on our future growth patterns can’t be ignored

Climate change is already happening and may fundamentally alter growth of and traffic to Eastern Shore communities. According to the Maryland Department of the Environment, “With 3,100 miles of shoreline, Maryland is the fourth most vulnerable state to suffer the effects of sea-level rise associated with climate change. Rising sea levels and increased storm intensity could have devastating and far-reaching impacts on the Atlantic coast and the Chesapeake Bay ecosystem that affect the environmental, recreational and economic benefits enjoyed by Maryland and her visitors.”[1]

Projections of future growth in traffic to the Eastern Shore are not reliable because they are based on past experience, before climate change became so evident and before the COVID-19 pandemic dramatically reduced daily commuting. How much traffic growth will be affected in the future by continuing telework is not known.   

With climate change already underway, traffic growth projections being unreliable, and increasingly adverse impacts on our states’ shoreline being inevitable, planning to build another multi-billion dollar bay crossing just isn’t prudent. 

3^rd bay crossing would increase global warming emissions

Transportation is the largest source of climate-damaging greenhouse gases in our state.  The plan to add more driving lanes by building a 3^rd bay crossing represents an outdated business-as-usual “car-centric” model that has contributed to where we are today.  U.N. Secretary General Antonio Guterres warned leaders at the White House Summit in April that the world is “racing toward a threshold of catastrophe” unless it moves more rapidly to address climate change.[2]

The Maryland Department of Transportation (MDOT) periodically cites an academic study that showed limiting vehicle idling in traffic congestion (by adding more traffic lanes) can cut carbon emissions.  However, an author of that study debunked that claim and said it doesn’t mean adding more lanes will clean the air.[3]

Traffic congestion would occur with a 3^rd bay crossing

Numerous academic studies and many years of practical experience have shown that expanding highways and bridges “induces demand”, that is, attracts more drivers because they believe their travel will be faster.[4] This means traffic congestion will occur again in the future after billions of dollars have been wasted building a new bridge. That money could be better spent for other purposes, such as building the Red Line in Baltimore, or creating electric bus/minibus and van rapid transit and electric ferry systems to cross the bay and lessen the number of cars seeking to cross the 2 bridges. 

Attracting more drivers also would lead to increased sprawl development on the Eastern Shore with the new households adding even more traffic onto our roadways. This is contrary to what needs to happen to reduce emissions from the transportation sector to lessen climate change.

More drivers generate more health-damaging air pollution

The increasing number of vehicles that would use a 3^rd bay crossing would generate increasing amounts of health-damaging air pollution in addition to greenhouse gases. Traffic-related air pollution causes or exacerbates serious illnesses ranging from heart disease, strokes and dementia to lung cancer, asthma and various respiratory illnesses, and cuts short an estimated 58,000 American lives every year.[5]

A 3^rd bay crossing would damage the bay

Even though Corridor 7, the preferred alternative described in the DEIS, would have the smallest environmental impact of all the corridors studied, it still would affect more than 10,000 acres of tidal wetlands and more than a thousand acres each of non-tidal wetlands, oyster resources, and other sensitive areas, according to the Chesapeake Bay Foundation. 

Also, the increasing amount of air pollution (that contains nitrogen oxides) generated in the watershed area by the increasing number of vehicles would be bad news for the Bay and its tributaries.  Roughly one-third of the nitrogen pollution in the bay comes from the air.[6] Excess nitrogen can fuel the growth of algae blooms, which can block sunlight from reaching underwater grasses and create low-oxygen “dead zones” that suffocate marine life.

“No build” plus an integrated solution make the most sense

We are not just recommending “no build” and ignoring existing traffic congestion. Rather, we are saying the no build alternative should be selected AND that an integrated solution of modal and operational alternatives should also be implemented.  The solution should include an electric bus/minibus and van rapid transit system, in combination with a robust electric ferry system, together with a number of options offered by TSM and TDM.  An integrated solution of MOAs would inevitably offer significant flexibility, capacity, dependable and reliable travel times, and would be far more equitable and environmentally responsible than any other alternative considered.

To reduce emissions from the transportation sector and lessen traffic across the existing bridges, we must make it easier for people not to use their cars. An electric bus/minibus and van rapid transit system that has vehicles departing from population centers west of the bay, that has vehicle stops at a limited number of population centers on the eastern shore, and that runs more frequently when demand is greatest, could be very popular.  Another benefit of transit is that it is accessible to lower income and other residents who don’t own a car.

TSM options that could be used include tolls priced to encourage off-peak travel, lower-priced or possibly no tolls for high occupancy vehicles, traffic signal coordination, and proven techniques for managing traffic congestion. TDM options could include high occupancy vehicle lanes, creating more park and ride locations, incentivizing employers to offer flexible schedules, telework and transit subsidies, and incentivizing property rental companies to offer weekly rental periods that start and end on different weekdays.

Conclusion

In summary, the Bay Crossing DEIS used a conclusions-first approach that eliminated consideration of reasonable alternatives to ensure selection of an alternative that MDTA wanted - a new bay crossing corridor.  Consequently, the DEIS conclusions are seriously flawed. The no-build alternative, together with implementation of an integrated solution comprised of an electric bus/minibus and van rapid transit system, TSM/TDM, and an electric ferry service, would address current and future traffic congestion at the current bay bridges in a much more cost-effective, equitable, and environmentally friendly manner than how traffic is now handled there.

Organizations submitting this comment include:

350 Montgomery County

ArchPlan Inc.

Cedar Lane Unitarian Universalist Church Environmental Justice Ministry

Central Maryland Transportation Alliance

Coalition for Smarter Growth

Downtown Residents Advocacy Network (Baltimore)

IndivisibleHoCoMD Climate Action Team

Labor Network for Sustainability (LNS)

League of Women Voters of Maryland

Maryland Campaign for Environmental Human Rights

Maryland Conservation Council

Maryland Sierra Club

MLC Climate Justice Wing

NAACP Maryland State Conference

Solutionary Rail

Takoma Park Mobilization Environment Committee

Washington Area Bicyclist Association