Public Statements on Beltway Expansion

Photo by Mariordo (Mario R. Duran Ortiz) - Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=19209537

Comments by the Friends of Cabin John Creek (FoCJC) on the Draft Environmental Impact Statement (DEIS) for Possible I-495/I-270 Expansion

Summary

The Friends of Cabin John Creek (FoCJC) is an incorporated 501(c)(3) entity that works to protect and enhance the Cabin John Creek (CJ Creek) watershed.  FoCJC strongly advocates for mitigating impacts of any I-495/I-270 expansion on the watershed. Many of the alternatives have the potential to have both short-term and long-term negative impacts on the watershed. It is our position that the chosen alternative must avoid or mitigate all short- and long-term negative impacts to the health of the watershed.  Additionally, because stormwater runoff is the CJ Creek's main enemy, we strongly support the following: (1) the retrofitting of the existing highway system with current best management practices for stormwater management, (2) close adherence to current stormwater management regulations for new public construction, and (3) minimizing the destruction of parkland for highway expansion since that has adverse impacts for the local streams.

 

The CJ Creek watershed is and will be the most impacted watershed as a result of any changes to I-495/I-270. Both Green Infrastructure (GI) hubs and Targeted Ecological Areas (TEAs) and a large variety of fish species are associated with the Cabin John Creek watershed.  This is a watershed where extra effort should be made to protect it.

 

Our Positions

    1.  We are opposed to the taking of public open space that protects creeks. In Cabin John CEA Analysis Area, the project will require partial right-of-way acquisition of 5 acres from 3 parks. (Appendix E, p . 172 –  also labeled as Technical report, Appendix D, p.6).   As noted in the DEIS, we would expect MDOT to make “every reasonable effort” to avoid wetlands, waterways and parklands.

    2.  We support retrofitting the existing roadway with stormwater management facilities to slow the water down, settle out the sediment, and increase the amount of water that goes into the ground rather than rushing into the stream.  This is a unique opportunity to benefit the CJ Creek watershed.  Why not take the opportunity to ensure that the existing roadway meets current stormwater runoff control standards?  

    3.  Any new construction must adhere to the most current stormwater regulations and be continuously monitored and updated in order to minimize impact to the surrounding natural landscape. Storm Water Management must be emphasized regardless of whatever alternative is selected, and this project viewed as an opportunity to exceed legal minimums.

    4.  We are especially concerned about the threat to three parts of our watershed as mentioned in Comment #1 in the PDF.

    5. The No Build Alternative should be strongly considered, due to the following factors: (a)  high probability of a long-term decrease in traffic and need for road expansion due to the “new normal” of massively increased telework due to Covid-19, (b) urgent threats posed by man-induced global climate change, (c) the DEIS itself admits that “opportunities for avoidance and minimization of impacts to roadside resources are limited due to the fixed nature of the highway corridor.”  Appendix L, page 165.  

    6. Green Infrastructure (GI) hubs and corridors should be maximized to promote both wildlife and human enjoyment. 

We submitted six pages of comments on November 4, 2020, to the Maryland Department of Transportation, State Highway Administration.

Download PDF of Complete Comments Submitted by Friends of Cabin John Creek

 

Next Steps

The public comment period for the DEIS ended November 9, 2020. The next steps would be for the Maryland Department of Transportation to determine a "recommended preferred alternative" for the project and then issue a Final Environmental Impact Statement. Learn more, watch videos of the public hearings, and get updates the the project website, https://495-270-p3.com/

Background

  • The Beltway was constructed between 1961-1964 and I-270 between 1962-1975, a time when there were no stormwater regulations.

  • The state of Maryland has initiated a I-495 & I-270 Public-Private Partnership (P3) Program that will likely include actions along all of the 70+ miles of interstate in Maryland including the portions of I-495 and I-270 in the Cabin John Creek watershed.

  • Roughly 10 miles of these highways fall within our watershed and all of the work falls within someone’s watershed.

  • The I-495 & I-270 Managed Lanes Study Draft Environmental Impact Statement includes a review of the current conditions and the potential impacts of each of the alternatives. However, the state is not required to choose the alternative with the lowest impacts.

 

Issues

  • Destruction of park land. In our watershed there are private yards, private homes, and park land within or adjacent to the project area.

  • Increased runoff from increased impervious surfaces. In many alternatives there would be a dramatic increase in the width of the roadway. Adding one foot of roadway along the 70 miles of the project adds up to 8.5 acres of asphalt.

Download FoCJC's Initial Public Statement, Issued Feb. 19, 2019