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September 22, 2009

We at the Action Committee for Transit read the Planning Board's report on growth policy with great interest. The first half of this report is an outstanding analysis of the transportation and land use issues the county faces. We face demographic and environmental challenges that cannot be met by continuing past planning practices.

As the Planning Board points out, the Adequate Public Facilities Ordinance needs changes to accommodate mixed-use transit-oriented development. But as we see it, the problem lies deeper than that. We believe the APFO rests on a flawed premise. It treats the symptom of the disease – crowded intersections – in a way that worsens the underlying cause – land use that forces people to drive too much. It's like treating the flu by taking a cold shower to bring down the fever.

One of the two transportation tests in the APFO, the regional test (PAMR), is widely acknowledged to be flawed. As this test measures transit accessibility, Brookeville and Potomac have better transit service than Rockville. All of Bethesda is given one average score, when the average of transit access between downtown Bethesda and Glen Echo tells you nothing at all about how easy it really is to get to either of them. More fundamentally, when the PAMR pushes development away from built-up areas, it winds up exacerbating congestion rather than preventing it.

The local test (LATR) has received less criticism, but in our view it is even more of a problem. The incentive created by this test is to move as many motor vehicles as possible through every intersection, regardless of negative effects on pedestrians, transit users, and nearby residents and businesses. The LATR is also a serious impediment to transit-oriented development (contrary to the assertion on p. 30 of the Planning Board report). The area around Glenmont Metro, which cries out to be rebuilt on a more human scale, has been under a de facto moratorium due to LATR, and LATR has also been an obstacle to transit-oriented growth at Friendship Heights.

The basic concept of the current APFO is first come, first served. Developers are at first allowed to dump as much traffic as they like onto the roads. When conditions in one place become intolerable, the rules suddenly change. Late-comers are required, at great expense, to undo the mistakes of those who came before them. Or they can, and many do, relocate to outer areas where they will be first in line, and are free to create new traffic problems.

This basic flaw needs to be fixed. As we told the Council two years ago, the PAMR and LATR should be replaced by tests that address the underlying disease of too much need to drive. We recommend a regional test that limits the vehicle miles traveled (VMT) from new developments (per housing unit or per job). The local test should restrict the number of motor vehicle trips generated from a development.

With one exception, the Planning Board recommendations fail to address the underlying flaw in the APFO. That exception is the recommendation for White Flint. We enthusiastically endorse the proposal to tie new development to the rebuilding of Rockville Pike as an urban boulevard that is an inviting destination for pedestrians and transit riders.

Our views on the specific Planning Board recommendations are as follows:

1. Alternative PAMR procedure – The criteria for eligibility for this procedure are too loose. A location with rush-hour-only bus service running in one direction does not have “high-quality transit.” High-quality transit is transit that enables one to live conveniently without a car. Either this procedure should be limited to Metrorail stations, or it should require two-way bus service 18 hours per day seven days a week, headways ten minutes or better in rush hour, twenty minutes mid-day, and half-hour evenings and weekends.

2. Allow LOS E on urban roadways – We support this change, but strongly disagree with the characterization that this change will make the treatment of road and transit access “symmetrical.” The PAMR is inherently asymmetrical because it allows development in places with no transit access, if the roads are uncongested, but does not allow development in places with excellent transit access, if the roads are too congested.

4. Transfer trips to Metro stations – We support this change. It would alleviate somewhat the damage caused by PAMR lumping together areas near and far from Metro.

5. Adjust trip generation rates – The trip generation rates used for LATR do not match reality, and the proposal falls far short of what is needed to fix them. An 18% reduction is proposed in trip generation rates for residences near most Metro stations (currently 0.41 am, 0.47 pm), with no change in the lower number (0.30) currently used for Bethesda, Friendship Heights, and Silver Spring. A recent report by the Transportation Research Board measured peak-hour1 trip generation at apartment buildings near Grosvenor and Silver Spring Metros. At Grosvenor, the trip generation was 8% less than current LATR assumptions, and at Silver Spring it was 33% below the current number2 .

The current trip generation rates were developed before the current popularity of urban living and are obsolete. Current rates for Silver Spring and Bethesda (and possibly Wheaton) should be reduced from 0.30 to 0.20 to reflect the new data from the TRB. The 18% reduction should be applied at Metro stations like Grosvenor that lack significant retail: Grosvenor, Forest Glen, and Glenmont. The remaining stations, where mixed use development exists or is planned, but falls short of matching the diversity and scale of Bethesda and Silver Spring, should get an intermediate number – the value of 0.30 might be kept for Friendship Heights and extended to the remaining stations.

6. White Flint – As stated above, we strongly support this recommendation.

7. New policy areas – We support the change at White Flint, but oppose the creation of a Life Sciences Policy Area. In its September 15 letter, MDOT warns that without $1.3 billion in state transportation expenditures assumed by the draft Master Plan, plus additional expensive widenings of Sam Eig Highway and I-270, severe congestion will occur on local roads surrounding the Sector Plan area. If the policy area shrinks, this congestion would not count in the PAMR calculation. Highway congestion in this area should not be ignored in the PAMR, if the current PAMR is retained.

Also, the Planning Board does not explain how it will be feasible to measure the PAMR tests in this small area. When the PAMR was first introduced, transit advocates pointed out the need to measure transit accessibility separately in Metro station policy areas. We were told by Planning Board staff that it is not feasible to apply the PAMR tests in such small areas. How is it that the PAMR test can now be applied in the Life Sciences Center? If separate areas are to be broken out for testing, the sectors around the existing Metro stations should have a higher priority than Gaithersburg West.

1. Peak-hour trip generation is measured for the hour when the most trips entered or left the building. In a mixed-use area, the peak hour for residential trips will generally not coincide with the peak hour of congestion, which will be dominated by workplace trips. Thus, the trip generation in the most congested hour will be even less than reported by this study.

2. The Planning Board also cites a study by MWCOG, but the MWCOG study covers a larger area and goes farther away from the Metro stations.