March 9, 2026
Maryland Transportation Authority
2310 Broening Highway
Baltimore, MD 21224
Re: Comment on Chesapeake Bay Crossing Study, Tier II NEPA, Draft EIS
To whom it may concern:
I am submitting this comment on behalf of the Coalition for Smarter Growth. Our organization advocates for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. We work extensively in the Maryland suburbs of DC and also at the state level for supportive transportation and land use policies and major investments.
Please consider these comments on the Chesapeake Bay Crossing, Tier II NEPA, Draft Environmental Impact Statement:
1. EIS fails to consider more effective land use alternatives for improving access
The Development of Alternatives did not consider land use alternatives (or elements of alternatives) that can more effectively manage long-term travel demand in the study corridor. The initial Transit and Transportation Demand Management (TDM) alternatives excluded critical land use elements, which have these benefits for the project purpose and need:
- Focusing new development at existing mixed-use activity centers, walkable neighborhoods, main street towns, and transit hubs is one of the best ways to reduce vehicle trip generation and driving distances while improving mobility and access.
- Better land use planning – putting more residents and jobs close to each other and to transit stops – is also critical to making transit services across the Bay Crossing and study area successful in attracting riders and providing cost-effective service.
USDOT has found that land use is a critical policy for improved transportation outcomes and reduced environmental harm.
The Draft EIS should be revised, with new alternatives development to incorporate land use planning elements. We believe that the Draft EIS TSM/TDM alternative (includes expanded transit) with land use elements added would perform much better in terms of supporting the project purpose and need. This revised alternative and evaluation should be included in the study before project sponsors select a preferred alternative.
2. Ignores low-density, scattered suburban development generated by the project
The environmental study ignores the well documented suburban sprawl that highway capacity capacity expansion projects cause. The environmental resources of the Eastern Shore and Anne Arundel County have been adversely impacted (e.g., water quality, air quality, forest areas, agricultural areas, Chesapeake Bay Critical Areas and buffers, wetlands, land use) by decades of highway expansion projects. According to the Eastern Shore Land Conservancy, developed land on the Eastern Shore surged from 10,000 acres in the 1940s to 173,000 acres today following construction of the Bay Bridge spans.
Similar adverse impacts are likely to result from the proposed Bay Crossing highway capacity expansion Preferred Alternative. The Draft EIS should be revised to document these impacts, including a wider study area as recommended by the Eastern Shore Land Conservancy in its comments.
3. Traffic forecast fails to include induced demand from new suburban sprawl that would result from the Build Alternatives
Decades of academic research of completed highway capacity expansion projects show that induced vehicular travel demand is significant and that land use conversion due to the projects is a major factor.
The Draft EIS Air Quality Technical report forecasts an 8% increase in VMT by the Preferred Alternative over the No Build. However, with a vehicle capacity expansion of 60% (five lanes to eight lanes), the literature (Volker & Handy (2023)) suggests a much larger increase in VMT due to observed long-term induced demand of 8-10% for every 10% increase in capacity.
The RMI SHIFT Calculator, which uses observed induced demand elasticities, likewise estimates a substantial VMT and GHG increase from the Preferred Alternative. Using an approximate total of 17 new lane miles added to U.S. 50/301 by the Preferred Alternative (3 new lanes on the bridge, 2 new lanes on the landings), the expanded bridge and approaches would induce 30 to 71 million new VMT per year and up to 0.7 MMT CO2e cumulative emissions through 2050.
4. VMT & GHG increases due to project are inconsistent with Maryland policies
The state’s Climate Pollution Reduction Plan and MDOT plans have a goal to reduce per capita VMT by 20% by 2050, which is needed in addition to transitioning to electric vehicles for the state to meet its adopted greenhouse gas reduction targets.
In addition, Governor Moore’s executive order #01.01.2024.19 “Implementing Maryland’s Climate Pollution Reduction Plan: Implementing Maryland’s Climate Pollution Reduction Plan” calls on MDOT to “implement…projects to reduce vehicle miles traveled and enhance transportation choices in Maryland.”
The increase in VMT from an expanded Bay Bridge would be directly contrary to the goals set by the Governor, the Climate Pollution Reduction Plan, and MDOT to achieve state-mandated emissions reductions.
5. Bay Bridge alternatives should incorporate a multi-use path
The new Chesapeake Bay Bridge could and should include a safe bike and pedestrian path, but the Maryland Transportation Authority is currently treating it as optional. These facilities have provided significant community benefits, recreation and outdoor tourism, on major bridge projects elsewhere.
The Bay Bridge path would connect to the East Coast Greenway, the 911 National Memorial Trail, the cross-country American Discovery Trail, and budding Maryland Eastern Shore Trail Network, as well as closing the gap in the existing trail systems between Anne Arundel and Queen Anne’s counties. Trail projects across the U.S. have been extremely popular and this major connection among trail networks would generate significant outdoor recreation and related economic activity.
6. Incorporate variable toll pricing to address peak demand
The Draft EIS states that congestion pricing or variable pricing is an “operational management strategy that could be used.” [emphasis added] However, we believe this is critical to effectively managing the highly peaked travel demand by helping shift demand to off-peak periods, and should be a required component of the project.
Further study of congestion pricing, as part of an integrated land use, transit, and TSM/TDM alternative, should also look at how this can help the project reduce lane capacity expansion and project costs.
Recommended revisions to the Draft EIS
We ask that MDTA:
- Revise the alternatives development and screening process to incorporate land use planning elements and an integrated land use, transit, and TSM/TDM alternative.
- Document the anticipated adverse environmental impacts of low-density, scattered suburban development generated by the build alternatives.
- Revise the traffic and air quality analyses to fully account for the anticipated increased vehicular travel demand generated by the build alternatives.
- Incorporate the separated bicycle and pedestrian facility in the Preferred Alternative.
- Incorporate variable congestion pricing as a core component of the build alternatives to address the heavily peaked demand.
Thank you for your consideration,
Bill Pugh, AICP CTP
Transportation & Climate Director
Coalition for Smarter Growth