Save The Trail Petition

Testimony:  Purple Line Impact on Trail

Purple Line Public Hearing

Wednesday, 19 November, 2008

Statement by Robert B. Smythe 

Good evening.  My name is Robert Smythe.  I live on Wellington Drive, west of Wisconsin Avenue and a few hundred yards south of the Bethesda Metro Station and the Capital Crescent Trail.  I am the President of the Sacks Neighborhood Association. The Sacks subdivision is comprised of 60 single-family homes bordering downtown Bethesda.

Like many other citizens of Montgomery and Prince Georges Counties, I am concerned about traffic congestion, air pollution, energy consumption, loss of trees, open space and recreational opportunities.  Unlike most speakers at these public hearings, I am not here to state a preference for one of the Purple Line alternatives presented in the draft Environmental Impact Statement (EIS).  I’d like to tell you why, and why I think that it is also inappropriate for our elected public officials to be supporting any one of the alternatives described in the EIS at this point in time.  Put simply, the documents before us are so inadequate, inaccurate, and biased that they cannot be relied upon as a sufficient basis for objective, responsible, decision-making on this matter.

I should explain the basis for my opinion.  I have been an environmental professional for more than 35 years.  I was on the senior staff of the President’s Council on Environmental Quality when we wrote and issued the federal regulations that govern the process and content of environmental impact statements (40 CFR Parts 1500-1508) pursuant to the National Environmental Policy Act (NEPA).  Environmental impact assessment is my principal field of professional expertise, and I have written and consulted extensively on this subject.

The basic purpose of the EIS process is to provide, early on, an objective analysis of the potential environmental impacts, both direct and indirect, immediate and long-term, of any proposed major federal action.  The process was NOT designed to generate a record of justification for decisions already made.  To the contrary, the documents generated as part of the NEPA process are supposed to, and I quote, “…insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken.  The information must be of high quality.  Accurate scientific analysis, expert agency comments, and public scrutiny are essential to implementing NEPA.”  (40 CFR Part 1500.1) 

In my professional opinion, the draft EIS for this proposed action fails to meet this most basic requirement.  In its tone and content it reads more like a marketing proposal intended to sell us, the taxpayers, a specific product than like the kind of objective, comparative evaluation done, for example, by Consumer Reports for new automobiles or other large consumer items.  Since this project involves the potential expenditure of a billion or more dollars in public funds, or more than 50,000 times the cost of an average automobile, shouldn’t we insist upon having a standard of careful, objective, unbiased analysis at least equal to that available for buying a car?

It would take much longer than three minutes for me to discuss in detail the many ways in which this draft EIS fails to comply with these regulations, so let me summarize for you a few of them.

First, the analysis of alternatives.  Agencies are required to “…rigorously explore and objectively evaluate all reasonable alternatives...”…to “devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits….”  (40 CFR Part 1502.14)  Instead, this EIS is consistently biased toward light-rail transit (LTR) alternatives, and presents only one alternative— a bus rapid-transit (BRT) alternative—that does not terminate at the Bethesda Metro station, despite the obvious and urgent need to provide better public transit access to the Navy Medical/NIH complex to serve the huge projected increase in employment and traffic that will result from the relocation of the Walter Reed Army Medical Center to that already-congested site. 

Second, the analysis of impacts on natural resources and open space.  This EIS essentially dismisses all such potential impacts by declaring them to be not appreciably different between alternatives.  In doing so the document disregards the significant impacts of all alternatives on these important resources, to say nothing of the potential degradation or loss of a very popular and heavily used recreational resource—the Georgetown Branch of the Capital Crescent Trail.  If in fact it is in the greater public interest to diminish or eliminate this highly-valued resource, the agency and the public officials proposing this action should at least have the honesty to say so.  Contrary to what you may have heard, the EIS contains no assurances that this will not happen.

Third, the accuracy and currency of data.   The EIS presents projections, or at least assertions, of potential costs, ridership, transit times, and vehicle traffic reduction and/or increases for the various alternatives.  Several persons with independent expertise on these issues have raised serious questions about the factual basis and analytical methods used for these projections.  Furthermore, the document is grossly inadequate in its treatment of the potentially serious secondary or cumulative effects of altered traffic, parking, and pedestrian patterns on local streets and neighborhoods, especially near proposed new transit stations, that will result from construction and operation of any of the proposed alternatives.

These and other substantial flaws in the draft EIS for the Purple Line render it grossly inadequate as an objective basis for the long-term decisions and financial commitments that this huge transit proposal requires.  In my opinion it should be withdrawn and substantially revised to correct these fatal deficiencies. 

Thank you.

Robert B. Smythe, Ph.D.

4807 Wellington Drive

Chevy Chase, MD  20815