Testimony: Comments on the supplemental draft environmental impact statement for the Maryland I-495 and I-270 managed lane project

Prepared for the Maryland Department of Transportation (MDOT) and Federal Highway Administration (FHWA) on November 1st, 2020.

My name is Baruch Feigenbaum and I am the Senior Managing Director for Transportation Policy at Reason Foundation, a non-profit think tank with offices in Los Angeles and Washington, DC. For almost four decades Reason’s transportation experts have been advising federal, state, and local policymakers on managed lanes, tolling, and public-private partnerships (P3s)

During my time at Reason Foundation, I have analyzed toll-concession P3 projects in the states of California, Georgia, Michigan, North Carolina, Ohio, Pennsylvania, Texas, and Virginia.

Due to a change in project scope, MDOT and FHWA needed to provide a Supplemental Draft Environmental Impact Statement (SDEIS) for the I-270 and I-495 Managed Lanes Project. The changes include a greater commitment to transit in the corridor and a smaller overall footprint for the reconstruction of the American Legion Bridge. In my view, these changes took an already great project and made it excellent.

According to the SDEIS Alternative 9, Phase 1 South, consisting of two additional variably priced managed lanes on I-495 in each direction and one additional variably priced managed lane on I-270 in each direction, as well as the conversion of the existing high-occupancy vehicle (HOV) lanes to managed lanes, “[W]ould significantly increase throughput across the American Legion Bridge and on southern sections of I-270 while reducing congestion. It would also increase speeds, improve reliability, and reduce travel times and delays along with the majority of I-495, I-270, and the surrounding roadway network compared to the No-Build Alternative….”

In contrast, the No Build Alternative would not address any of the significant operational issues experienced under existing conditions, and it would not be able to accommodate long-term traffic growth, resulting in slower travel speeds, significant delays, longer travel times, and an unreliable network.

But the project does more than just improve mobility; it brings a critical bridge to a state of good repair. The American Legion Bridge is one of a limited number of Potomac River crossings. The bridge deck needs to be replaced within 10 years at a cost of $1.2 billion. But with this project, the tolls from the managed lanes will pay to replace the bridge in the next few years at no expense to Maryland taxpayers.

One of the principal requests from community stakeholders was improving bicycle and pedestrian options as well as avoiding land takings. In response to those concerns, the SDEIS shows the department will construct a new shared-use path along the rebuilt American Legion Bridge.

Another request was for more transit service. The department listened, and as indicated in the SDEIS, the project developer has agreed to set aside $300 million for funding bus transit improvements on the corridor. This fits with the project’s goal of improving mobility by moving more people, as opposed to more vehicles, through the corridor.

Currently, peak-period bus service on I-270 and I-495 has limited popularity due to its slow travel speeds. But with the express toll lanes operating as a virtual exclusive busway, buses will be able to use the managed lanes for free, providing reliable service. Area transit agencies (Washington Metropolitan Area Transportation Authority, Ride On, Fairfax Connector) are expected to start new services on the corridor, including the first-ever service linking Montgomery County, MD, with Fairfax County, VA.

Vanpools will also be able to use the lanes for free. Employer-sponsored vanpools consisting of seven to 15 people transport riders from home to work, when one or both are not accessible by fixed-route transit. Upper Montgomery County residents comprise a large share of regional vanpool riders. 

These buses and vanpools, along with automobiles, currently sit in severe traffic congestion. As a state, Maryland is ranked second worst in traffic congestion. This congestion affects not only commuters, but freight movements and long-distance travel as well. And while COVID may have eased traffic congestion during the peak morning periods, the highways remain just as congested during the evenings and more congested on middays and weekends.  

The SDEIS confirms that the preferred alternative has measurable quantitative reductions in travel time. Alternative 9 will reduce delay by 18% during the AM peak and 32% during the PM peak. The American Legion Bridge will be able to accommodate 25-30% more vehicles, eliminating one of the region’s most severe choke points, which can be congested up to 12 hours per day. The number of failing roadway segments will be reduced by 12% in the AM peak and 42% in the PM peak, a 29% overall reduction in the percentage of lane-miles operating at Level “F” service. Finally, vehicle-hours of delay on all Montgomery County arterials will be reduced by 4.8% daily, and system-wide traffic congestion on local arterials reduced by 3.5%. 

During peak hours, travel speeds increase or hold constant on all segments in both directions in both the general-purpose (GP) lanes and managed lanes. In the managed lanes, on I-495 southbound from the I-270 spur to the George Washington Memorial Parkway, speeds will average 56 mph southbound and 51 mph northbound, providing a reliable travel option. But just as importantly, speeds in the GP lanes will average 51 mph southbound, an improvement of 15 mph, and 45 mph northbound, an improvement of 9 mph. These speeds show the construction of the managed lanes benefits all corridor users, regardless of which lanes they choose to use.

On I-270 southbound from I-370 to I-495, managed lane speeds will average 58 mph and GP speeds will average 50 mph, an improvement of 4 mph. Northbound, speeds don’t see much of a change largely because there is not much congestion on I-270 northbound in the morning.

The difference in speed is just as impressive during the PM peak. In the managed lanes between the I-270 spur and GW Memorial Parkway, southbound speeds will average 23 mph and northbound speeds 59 mph. In the GP lanes, the numbers are 7 mph and 52 mph, respectively, with a 15 mph improvement in the southbound direction. On I-270, southbound managed lane speeds average 56 mph and northbound managed lane speeds average 37 mph. GP lanes speeds of 56 mph and 28 mph don’t change much from today.

The SDEIS shows that the I-495 and I-270 managed lanes will benefit drivers, transit users, bicyclists, and pedestrians, delivering the multimodal vision of Montgomery County residents.

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