COMMENTS SUBMITTED BY KENT CONSERVATION AND PRESERVATION ALLIANCE TO MARYLAND TRANSPORTATION AUTHORITY IN RESPONSE TO MARYLAND TRANSPORTATION NOVEMBER 15TH ONLINE SCOPING PRESENTATION.
Bay Crossing Study presented on November 15th by the MDTA brought up many questions and concerns for the Board of Directors of Kent Conservation and Preservation Alliance. This comment letter is our offering of major points and questions in response to the call for scoping comments by the public.
- WE BELIEVE THAT AT THE LEAST A 60-DAY SCOPING COMMENT PERIOD SHOULD BE SET, NOT THE MINIMUM 30 DAYS. The Public Scoping Meeting was held on November 15th inviting comments to be submitted by a December 15th deadline. This is insufficient time to allow for meaningful public input.
- THE PUBLIC IS REQUIRED TO FILE UNDER THE PUBLIC INFORMATION ACT (PIA) IN ORDER TO RECEIVE DOCUMENTS THAT SHOULD BE ON THE RECORD. A request to access agenda and minutes from a meeting held on October 25, 2017, referenced in the Federal Highway Administration 10/11/2017 filing on the Federal Registry, was denied.. We received notification that in order for us to obtain records, we would need to submit a request under the PIA. We duly filed our on-line PIA request on November 30th with the Maryland Department of Transportation. To date we have received no documents nor have we had acknowledgement that the request was received. Since we believe these documents should be freely available on the MDTA website, this does not bode well for an “open and transparent” process.
- OUTLINE THE SPECIFICS OF TRANSPORTATION STATUTE 4-407 OBLIQUELY REFERENCED IN THE NOVEMBER 15TH ONLINE PRESENTATION. The residents of the Eastern Shore should be given a detailed interpretation of how the language would be exercised, the practical implications, and why this express consent is not already under consideration before the study begins.
- WHAT WILL BE THE TOTAL CO2 FOOTPRINT FOR ALL OF THE BUILDOUT FOR THE SPAN, NEW ROADS AND IMPROVEMENTS TO EXISTING ROADS? Any crossing will require major upgrades to existing roads that lead to and from the crossing as well as new construction. The span itself, no matter where placed, will require concrete and steel. Roadways will require ground disturbance, removal of topsoil, vegetation, trees, and laying of,concrete and asphalt. During all of this construction there will be many gallons of fuel spent to run the equipment and haul the dirt, supplies, and personnel to the construction zones. There will be major traffic tie-ups in the areas of construction with cars idling in place waiting to move. Finally, as with any new highways increases in traffic will occur. With all of this we would like to know how the cradle to grave CO2 footprint for an undertaking of this size is being calculated. These measurements should include, but be limited to, impacts from loss of forests’ and farmland as well as the manufacturing and transportation of material that are needed in the whole project.
- THIS HIGHWAY IS NOT COMPATIABLE WITH THIS PROTECTED RURAL HISTORIC LANDSCAPE OR KENT COUNTY COMPREHENSIVE PLAN. Kent County has repeatedly stated that a bridge crossing through our county would not be compatible with our rural historic landscape. Page 51 of our Kent County Comprehensive Plan states clearly that the County is opposed to building a bridge into Kent County. The development pressures that it would bring to our county are enormous. We can see that Kent Island and the Narrows, as well as some of Talbot and the rest of Queen Anne’s County, have been developed for commuters to the Western Shore. There is a direct link to the increased development in Middletown, DE and the DELDOT bypass to Rt. 301. This is not the kind of development we should be encouraging. Turning Kent County strip-mall, fast-food corridor and rubber stamp of “anywhere USA” is antithetical to the character that defines the best of Kent County.
- DIVIDING FARMS WITH A HIGHWAY WILL MAKE FARMING MORE DIFFICULT IF NOT IMPOSSIBLE. Highways passing through farmland cannot just skirt the edges of the farms. Land taken through eminent domain will traverse through many farms in a way that will make the remaining land impractical to farm, further eroding our agricultural economy and rural agrarian culture.
- LOSS OF PRESERVED FARMLANDS. In building access roads, there would be no way to avoid the preserved lands that Kent County and the State have invested so much time and money on. With the loss of preserved land development pressure would increase on all agricultural land in the County. An access highway will also negatively impact the Priority Preservation Areas of the County.
- WHERE ARE YOU MOVING CARS TO? The average weekday traffic by 2025, as estimated by the task force study of 2005, would be 85,000. Opening a new span in Kent County, as we have seen on Kent Island, triggers land to be developed into sprawl. Therefore traffic above the 85,000 is likely. However, the 85,000 is not much above the current capacity for the existing spans, noted as 82,500. With creative use of tolls, increases in ride share, mass transit, and flex time, that is a manageable amount of traffic. Therefore it appears that the sole purpose of another bridge is to encourage more growth on the Eastern Shore, while leaving the jobs on the Western Shore and to move cars to the beaches of Maryland and Delaware. With more lanes added the entrepreneurs in beach communities, both in Delaware and Maryland, will seek to increase capacity, there by creating an inevitable feedback loop of more traffic and more congestion. Weekend reduction of back-ups should not be the major criteria under consideration.
- SHOULD THE DESTRUCTION OF MORE LAND IN NEW CORRIDORS BE CONSIDERED WHEN THE CURRENT BAY BRIDGE HAS ALREADY DONE A REALLY GOOD JOB OF THAT AT THE CURRENT LOCATION? Zone 3, the existing bridge, already has infrastructure in place and has already destroyed large swaths of farmland, wetlands, neighborhoods, sensitive resources, and historic resources. A span at a new location would extend that damage to intact landscapes. Bottlenecks at 50 and 404 will still need addressing unless the span is built south of the current Bay Bridge.
- PROJECTED GROWTH IS GREATEST FOR CECIL, WICOMICO, AND WORCESTER UNLESS THE TRAJECTORY IS CHANGED BY MAKING KENT COUNTY A SUBURB OF BALTIMORE CITY AND COUNTY. Household growth trends 1970-2030, as provided in the task force summary, show pretty convincingly that growth is in the northern and southern counties. Kent County has consistently stated that it would like to see slow controlled growth that does not harm the rural nature of our county. However that trajectory and growth would be changed significantly if a bridge were put into Kent County.
- MARYLAND SHOULD INVEST IN THE LOCAL ECONOMIES OF THE EASTERN SHORE INSTEAD OF BUILDING A BRIDGE TO FEED OCEAN CITY, AND THE BEACHES OF DELAWARE. Maryland should be maximizing high-wage economic growth on the entire Eastern Shore and discourage commuting to the Western Shore. Kent County now has 1G Internet, is a magnet for retirement and second homes, has recently added an enterprise zone, and major revitalization of the Chester River waterfront is underway. If the state is interested in increasing the economic indicators of the Eastern Shore, it should invest in our businesses, communities and schools. The plan to build out infrastructure that encourages commuting attracts fast-food restaurants, gas stations and convenience stores, where workers typically make unsustainable wages. Commuter communities are incompatible with our comprehensive plan and our rural cultural and historic heritage.
- A BRIDGE TO KENT COUNTY SACRIFICES THE RESIDENTS OF THIS SMALL COUNTY FOR THE ECONOMIC BENEFIT OF OTHERS. The fact that the Bay Bridge is critical to the economic vitality of the Lower Eastern Shore because of tourism means that the life of residents not living on the lower shore will have their enjoyment, pursuit of happiness, and protection of open space and farmland curtailed in order to feed the economic engine of Ocean City.
- DIRECT ACCESS WITHIN EASY COMMUTE TO DELAWARE TAX FREE SHOPPING. Adding another access to the Eastern Shore with a short commute to Delaware would make a convenient trip for Maryland residents to avail themselves of the tax-free shopping in Delaware. That state already has a negative impact on Eastern Shore community businesses. Many vacationers traveling to the beach by way of the existing Bay Bridge do not end up in Maryland, but instead head to the Delaware beaches bringing no benefit to Maryland businesses.