The opening statement in the P&N draft (available on the study's Web site at www.iccstudy.org) says that the ICC is "intended to link existing and proposed development areas between the I-270 and I-95/US 1 corridors . . . with a highway." It adds that the ICC is also intended "to increase community mobility and safety; to facilitate the movement of goods and people to and from economic centers; to provide cost-effective transportation infrastructure to serve existing and future development . . .; to help restore the natural, human, and cultural environments from past development impacts in the project area; and to advance homeland security."
Noticeably absent from this list of justifications for the ICC is any statement that the highway is key to the effort to "end gridlock" in the county, as claimed by many politicians in the last election. In spite of the emphasis on renewed development in the P&N, officials are generally silent on that issue in their public statements, emphasizing instead the theme of congestion relief. For example, in May the Governor stated that "the transportation needs of Montgomery County families and businesses have been ignored for too long. My administration is determined to build the ICC and make life on the road easier for Maryland commuters" ("New Money Fuels Momentum for Governor's Top Transportation Priority," Montgomery Gazette, May 1, 2003).
Eyes of Paint Branch submitted comments on the June draft of the P&N in July, calling it biased and stating that "the study area and draft P&N statement are tailored so that the study will result in approval of the ICC." We are particularly concerned that the study outcome has been predetermined because the P&N calls for building a highway, rather than finding the best way to meet the area's transportation needs.
We made several general comments, including that the study area should include all of Prince George's and Montgomery counties and should be expanded to Route 32, and that the study must look at a transit alternative.
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Hikers cross the Good Hope tributary near the ICC Master Plan Alignment. |
We also made a number of specific comments objecting to needs presented in the P&N. For example, with regard to the need for environmental restoration, we said "the environmental impacts from past development are a completely different subject than the environmental impacts from a potential major roadway and they must not be confused." As the Environmental Protection Agency pointed out in its comments, "to frame the discussion in terms of the natural environment needing a transportation project is awkward at best."
With regard to the need for homeland security, we said that justification should be removed and that "homeland security is a weak argument that could be viewed as a strategy to frighten the public." Prince George's County Council member Thomas Dernoga also commented on the homeland security justification, calling it "a cynical exploitation of a critical concern" and adding that "an east-west road, far removed from the Beltway, which promotes congestion at its east and west termini, does nothing to disperse traffic out of the immediate Washington, D.C., area. It is very disturbing to see government agencies seek to exploit such a vital concern to jump-start a failed transportation project."
We also noted that "notably and unconscionably absent from the P&N statement is any acknowledgment of the severe ozone (smog) pollution problem in the greater Washington, D.C., area, in direct violation of the National Ambient Air Quality Standards, which poses a serious health threat to area residents." We added that the study "must examine the impact of such a road on the region's already abysmal air quality."
Eyes of Paint Branch also included in our P&N comments criticism of the P&N review process itself. We noted that SHA did not inform the public about the entire draft P&N at its two public open houses in June; it presented only a summary version. SHA also did not let people know they could comment on the P&N or that it was a work in progress. SHA advertised no deadline for comments to be submitted and did not inform the public of the significance of a P&N for determining the parameters of the subsequent Draft Environmental Impact Statement.
SHA issued a slightly revised draft of the P&N statement in August, which ignored the points made by Eyes of Paint Branch, as well as the points in comments that we have read from other concerned individuals, organizations, and government agencies.
The federal environmental agencies (EPA, Army Corps of Engineers, U.S. Fish & Wildlife Service) were not required to concur on the P&N. This is a fundamental change in the process, as compared to previous studies, and is likely to have profound consequences. This unfortunate occurrence is a result of the "streamlining" process, despite assurances from officials that "streamlining" would not result in any steps being omitted.