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Save The Trail Petition |
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Testimony: Purple Line Impact on Trail |
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Testimony for MTA Purple Line Hearing November 18, 2008
Pam Browning, Organizer Petition to Save the Trail
These comments are made on behalf of the Petition to Save the Trail, which has gathered over 16,500 signatures opposing transit—buses or light rail -- along the Capital Crescent Trail.
MTA’s Environmental Impact Statement of the Purple Line is an arbitrary and legalistic study that completely ignores the reality that the Georgetown Branch/Capital Crescent Trail functions as one of the most popular urban parks and recreation areas in the nation. The trail is used by hikers and bikers of all ages, races, ethnicities, and abilities. It is enjoyed by the elderly, parents pushing strollers, bird watchers, families with small children, casual cyclists, teens going to and from school, athletes in training, and daily commuters.
The Trail is often cited as one of the most important amenities and resources in the Metropolitan area. It was documented to have 10,000 weekly uses in 2006*, and its use has grown substantially since that time. It is an essential link in a web of connecting trails in the region, and for this reason, it is heavily used by hikers and bikers from around the Metropolitan area.
And yet, there is no analysis in the DEIS of the significance of the Trail to the neighboring communities or to the region. Why doesn’t the DEIS reflect any of this information about the Trail? Why isn’t the State urging the protection of this unique park and recreation area?
Section 4(f) of the U.S. Department of Transportation Act of 1966 requires that the proposed use of land from a publicly-owned public park or recreation area is permissible only if there is no feasible and prudent alternative to the use. (DEIS, p. 4-14)
Well, there is an alternative – the Jones Bridge Road alternative -- which is not only feasible and prudent, it is more cost-effective than the light rail on the Trail (DEIS, p. 11), and it requires lower capital and annual operating subsidy investments and commitment of financial resources. (DEIS, p. 13)
However, the DEIS, in a footnote, states that 20 years ago, “Montgomery County reserved the Georgetown Branch for transportation use; therefore, the impacts are not subject to Section 4(f) requirements.” (p. 4-14) Thus, in the State’s eyes, this popular trail is not considered to be a park, recreation area, or open space (p. ES -4). And, apparently, for this reason, the DEIS simply ignores the current use and value of the Trail as such.
However, this narrow, legalistic interpretation of the law is wrong. The DEIS is not required to be blind to the popular use and extraordinary value of this Trail to the region. In fact, it MUST evaluate the impacts that the various transit options would have on this important resource.
And, why isn’t the EIS analyzing and evaluating major significant tree loss under the Purple Line alternatives? The Georgetown Branch/Capital Crescent Trail is a natural park lined by 17 acres of mature trees. ** Construction of a bus or transitway will result in the bulldozing of all of these trees, by the EIS’s own admission:
“The Purple Line would result in substantial visual effects to the visual character of the Interim Georgetown Branch Trail due to the presence of the Purple Line in the Georgetown Branch right-of-way and the required clearing of trees and other vegetation for construction. While new landscaping would be included in the construction, the mature trees would not be replaced. The clearing of vegetation for construction would reduce screening of the right-of-way from neighboring land uses. (Page 4-22 EIS) Clear-cutting all of the trees surrounding the Trail will have impacts on Trail users, adjacent residents, and communities, as well as air quality, water run-off, soil erosion, the health of nearby Coquelin Run. It runs counter to all the State’ efforts to deal with pollution in the Chesapeake Bay and global warming.
“Forests are the region’s most strategically important natural resource,” according to Maryland’s DNR Secretary John R. Griffin. “In addition to protecting water quality, cleaning the air and providing wildlife habitat, one large tree can eliminate 5,000 gallons of stormwater runoff annually and well placed trees can reduce energy costs by 15 to 35 percent.”
But the DEIS states “the delineation and surveying of significant trees will occur following the selection of a preferred alternative.” (p. 4-62) The omission of any impact analysis or quantification of the enormous tree loss under the five bus and rail alternatives routed along the Trail is a glaring defect in the DEIS.
The State’s utterly incomplete analysis of the value of the Trail and surrounding trees provides the basis for which the EIS grossly understates the adverse environmental impacts of the five bus and rail alternatives on the Trail, and similarly understates the relative environmental benefits to the Jones Bridge Road alternative.
The requirements of the AA process are intended to allow for an objective, efficient, and fully informed evaluation and rating of the transit projects seeking funding under the Federal New Starts process. (DEIS, pp. 1-2)
However the DEIS’s myopic, disingenuous analysis fails to meet these requirements, and it does a complete disservice to the public and our elected officials who rely on this document for a complete, objective and fair analysis of the true environmental impacts of various transit options. _______________ *Coalition for the Capital Crescent Trail Survey, 2006. **American Forests’ Capital Crescent Trail Analysis, 2007.
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