NEPA Scoping Comments on MD 355 Crossing Study
May 25, 2010
The Action Committee for Transit has reviewed the material presented by
MCDOT Officials and their representatives at a public meeting held on May
11 regarding the MD 355/Rockville Pike Crossing Project and reaffirms our
objections and concerns raised in correspondence included in the NEPA
record dated February 3, 2010.
This project is masquerading as a pedestrian safety and transit enhancement effort with the intent of building highway capacity only thinly veiled. Major changes are needed. High-speed elevators to the Metro mezzanine on the Navy Hospital side of Route 355 must be analyzed as a stand-alone alternative. The Purpose and Need statement must be reformulated.
The Purpose and Need Summary has been restated without providing the Purpose and Need Statement-even though design alternatives have been evaluated and preselected for public presentation. The project Title and
Purpose and Need Summary statements preclude the evaluation of critical objectives studied and discovered during the WMATA Medical Center Access Study. The present study promotes variations of highway interchanges at MD 355/South Wood Road/South Drive without independently assessing the WMATA report options. The public is given highway interchange options to comment on with the WMATA options as added features with added cost. The cost benefit of a bank of elevators on the NNMC side, for instance, is not evaluated and compared to the costs and benefits of the multiple highway interchange designs.
Under “Purpose of Project” the first bullet point states: "Enhance/improve access to mass transit facilities".
ACT notes that travel time for transit users, with the Metrorail cohort estimated to be 80 percent of the total, has not been identified as a primary metric for evaluation. The criteria for this “Purpose” has been left vague.
The second bullet point states: "Improve the mobility and safety of pedestrians and bicyclists crossing MD 355/Rockville Pike and improve traffic operations at the existing intersection of South Wood Road/South Drive/MD 355." This purpose statement has two conflicting goals forced together with the later goal: “Improve traffic operations” as the guiding intent. The intersection in question is not identified in the Montgomery County Master Plan of Bikeways as a bicycle route. Further, pedestrian crossings are almost entirely limited to transit users that could be given means other than crossing MD 355 to access the NNMC from either bus or rail transit.
Transit safety, despite the very slow and unsafe emergency egress times of the MetroRail platform, is not given consideration.
ACT believes that highway interchanges or other, similar designs for MD 355 will create or increase hazards for pedestrians and bicyclists at intersections to the immediate north and south of the project intersection. Specifically, Cedar Lane and MD 355 and Jones Bridge Road and MD 355. Both of these intersections are iidentified in the County Master Plan of Bikeways.
The five points under “Goals and Objectives” do not identify two key issues:
- Improved transit service that can be provided by shorter routes to
transit (both bus and rail)
- The safety issues related to the grossly substandard passenger escape times of the Metrorail station platform.
Additionally, the fifth bullet point raises an issue outside the scope of
the project: "Improve efficiency of existing and future emergency and transit vehicles
moving between campuses."
ACT has shown from County testimony that the data on present and expected
emergency vehicle trips cannot be taken seriously as a need.
A project analysis that can adequately assess the benefits of design solutions that decrease travel time for MetroRail users through a new bank of high speed elevators exiting on the NNMC side of MD 355, analyze the full range of safety considerations posed by the current conditions of the Metrorail Station, adding additional bus stops on the NNMC side, improvements to the existing crosswalk needs to be undertaken.
Public notice continues to be inadequate for this NEPA process with limited announcements of the last meeting having been made.