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Draft City Comments on Beltway Expansion Project

At tomorrow’s meeting, the Council will consider approving a letter to the MDOT/SHA about Draft Environmental Impact Statement (DEIS) for the I-495 and I-270 Managed Lanes Study, in particular its impact on College Park. On July 10, 2020, the Federal Highway Administration (FHWA) and the Maryland Department of Transportation State Highway Administration (MDOT SHA) released the Notice of Availability of the DEIS and announced a 90-day review period including several public hearings. The deadline to submit comments has been extended until early next month.

The City Council has previously written to the Governor to oppose the Managed Lanes project and the P3 program. After reviewing the information provided in the DEIS, the City Council remains opposed to the project and strongly recommends the No-Build Alternative as the responsible course of action.

The City has identified significant concerns and areas requiring additional information that should be addressed in the DEIS. These are described below. I’ve asked to have languages asking alternative sites for the Odessa Parka and the Polish Club properties.
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Direct Access Interchanges
US 1 and I‐495: It is not clear how this intersection will be rebuilt including adjustments to the ramps and reconstruction of the US 1 bridge. Any bridge reconstruction should include bike lanes and crosswalks at ramp intersections to eliminate the barriers for pedestrians and bicyclists created by I‐495. Greenbelt Metro and I‐495: It is assumed that a full interchange at this location is in place, however, this interchange was proposed to be constructed in conjunction with private sector development of WMATA property which has been canceled. The cost of building this interchange needs to be included in the project budget. More information is also needed about the realignment of the entrance to the Greenbelt Metro Station.

Noise Barriers
All noise barriers are proposed for replacement and some will be increased in length and height. It is requested that a noise barrier be extended along the northern property line of 4700 Edgewood Road and that the maximum height be used to buffer all single‐family homes in College Park. The use of roadside vegetative barriers in these areas is highly encouraged to improve air quality and reduce concentrations of downwind pollutants.

Property Acquisition
Partial acquisition of 34 properties in College Park is proposed including two City‐owned properties. For private property, acquiring even a small strip of land could result in the property becoming nonconforming under the Prince George’s County Zoning Ordinance. These specific impacts need to be identified for each property.

Polish Club of College Park:
This 5.6‐acre property contains woodlands, wetlands and wildlife and adjoins the Hollywood neighborhood, Hollywood Park and a K‐8 school and preschool. Please clarify if a full or partial acquisition is contemplated. The proposed use of this site for construction staging and materials storage would result in unacceptable impacts to this neighborhood in terms of vehicle exhaust, noise, loss of tree canopy and construction traffic. Should this property be used in this manner for the short term, it is requested that a long‐term reuse plan be developed to provide an amenity for the community.

10020 51st Avenue:
The limit of disturbance, as shown, would eliminate driveway access to this property.

Sunnyside Outlots/Odessa Park:
Approximately half of this property, proposed to be developed by the City as a park and playground, would be used for a storm water management facility. This will reduce the design footprint of the park and place proposed improvements closer to existing residences reducing its attractiveness and utility. Odessa Park should be added to the parks inventory and evaluated. More detail on the Park Impacts

Hollywood Park:
While the impacts are listed as de minimis, there is concern about how the realignment of the Greenbelt Metro Station access road might impact the viewshed and noise in the park and larger neighborhood.

Cherry Hill Road Park:
The natural areas of this park will be significantly impacted by the substantial loss of trees, which will further degrade the green infrastructure surrounding the City. Additional information is needed so that we can understand the full extent of impacts to parkland and how to make the park systems whole through mitigation.

Streams and Waterways
The College Park area has three streams that will be impacted by the project: Indian Creek, Little Paint Branch and Paint Branch. As many neighborhoods in the City lie within the 100‐year floodplain, the
increases in impervious surface from the project and changes to groundwater and hydrology, elevate the risk for increased flooding. Additional floodplain modeling for this watershed must be done now to understand the full impacts and offer mitigation strategies. It cannot wait until later in the design phase. We are also concerned that local water quality will be degraded and endanger aquatic biota in the streams that cannot tolerate warmwater conditions.

Green Infrastructure and Forest Mitigation
College Park is already experiencing a decrease in tree canopy based on development activity, which will be exacerbated by this project. The green infrastructure corridor along the Beltway offers ecologically important undeveloped land which will be disrupted by the project. Study area impacts are reported in the DEIS but are not broken down to the local level. Please provide this information in the FEIS. While the City is poised to lose green infrastructure, it is unlikely to be the beneficiary of forest mitigation. Under Maryland Reforestation Law, a minimum of five contiguous acres of public land is needed for replanting within the same watershed. Please reconsider this standard in College Park and other communities in the Developed Tier where this standard cannot be met. City staff will work with M‐NCPPC and your team to identify alternative sites to help restore the tree canopy in the College Park area.

Traffic Congestion
The stated purpose and need for the project is to provide congestion relief and accommodate future long‐term traffic growth. The traffic modeling and analysis in the DEIS is insufficient to conclude that the project will meet this need for several reasons. The analysis needs to be updated using the most recent traffic data from the Metropolitan Washington Council of Governments (MWCOG), and to consider the impacts of increased capacity on land use. It is unrealistic to assume that there will be no effect, therefore, the number of new trips generated is underestimated. Consideration also needs to be given to the effects of the pandemic on traffic growth patterns as many people may permanently transition to telework. The likely increase in the use of Autonomous Vehicles in the future is not addressed and should be.

The City is concerned that induced traffic demand on arterial and collector roads leading to the Beltway such as Baltimore Avenue, Rhode Island Avenue and MD 193 is underestimated. These roads are already highly congested and specific details for them need to be provided in the FEIS including an analysis of traffic, noise, and air quality impacts.

It is unfortunate that no public transit options were included as alternatives retained for detailed study in the DEIS. This should be revisited along with transportation systems management (TSM) and transportation demand management (TDM) as serious strategies with less environmental and financial costs.

Environmental Justice
The DEIS claims that all Build Alternatives under consideration will benefit minority and low‐income populations (Environmental Justice (EJ) communities) but does not adequately explain this conclusion. College Park census blocks in the study area meet the definition of an EJ community yet measures to mitigate any potential disproportionate effect on them is missing. The report does not give sufficient attention to the fact that the expected high toll prices may be too much of a cost burden to the EJ community. Equitable access to the managed lanes has not been demonstrated and recommendations such as toll subsidies should be included.

Outreach and input from the EJ community is also missing and must be addressed prior to any second phase of construction. Only one stakeholder meeting in June 2019 is reported but the feedback from the meeting has not been included. Better public participation and involvement is needed. For the reasons stated, the City Council finds that the DEIS falls short of meeting the purpose and need for the project, and that the environmental and other costs far outweigh the benefits of the project.

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