Author: Elena Sorokina

Maryland: Comments on Frederick draft Climate and Energy Action Plan

Posted on by Elena Sorokina

August 22, 2025
Rayla Bellis
Climate and Energy Manager
Department of Climate and Energy
Frederick County, MD

Jenny Willoughby
Sustainability Manager
City of Frederick

Re: Comments on Frederick draft Climate and Energy Action Plan

Frederick County and City of Frederick officials and staff:

On behalf of the Coalition for Smarter Growth, I am submitting the following comments on the draft Frederick Climate and Energy Action Plan. 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 have been working in the region for over 28 years.

We commend Frederick County and the City of Frederick for preparing this plan and setting targets to reduce greenhouse gas emissions by 50% by 2030 (from 2010 baseline) and 100% by 2050.

1. Set necessary VMT reduction and EV adoption performance benchmarks to achieve transportation and overall emissions reductions

  • Reduce per capita light duty VMT by 20% by the 2030’s and further by 2050
  • Set both ambitious and feasible goals for EV adoption by 2030 and 2035 consistent with State of Maryland and regional targets 

Transportation is the county’s biggest source of emissions, almost half (49% total; 45% on-road), so it is critical to set sufficiently strong benchmarks that reflect what is needed to achieve the plan’s overall GHG reduction targets. 

We are glad to see that the plan sets strategies to both speed up adoption of electric vehicles (EVs) and reduce vehicle miles traveled (VMT) – strategies T1 and T2, and the list of action categories under T2.

The plan should set performance benchmarks for these two metrics so decisionmakers and stakeholders can track progress. 

  • The National Capital Region Transportation Planning Board’s (TPB) 2021 Climate Change Mitigation Study found that the region must more urgently move to walkable, transit-oriented communities and implement more robust travel demand management programs in addition to transitioning to electric vehicles. 
  • The study (similar to national studies) found that the region must reduce per capita VMT of passenger cars by about 20% by 2030, with further reductions of around 25-30% in later decades, for the region to achieve the COG GHG targets, which are similar to Frederick County and City’s targets. (This level of VMT reduction is accompanied by a relatively aggressive shift to EVs, 50% of light duty sales by 2030).  
  • The draft Frederick plan assumes a “reduction in vehicle miles traveled of 7% by 2035 and 9% by 2050, which would result from land use changes, travel demand management strategies, transit enhancement, and bike, pedestrian, and micro-mobility improvements” (p. 58) Note that the plan is unclear if this is per capita VMT, total VMT, and/or specifically light duty VMT; and if the percentage reductions are aspirational goals or assumed based on currently programmed projects. In any case, the plan’s future VMT levels appear to be inadequate to achieve its overall GHG targets.
  • The need to reduce per capita VMT by 20% and further, are why numerous states, including the State of Maryland, have set goals to reduce per capita VMT by 20% or more.
  • Fostering a more walkable, bikeable, transit-friendly Frederick County and City – enabling residents and workers to drive less for daily needs – also increases affordability for families and workers, provides health and safety benefits, and results in cleaner air and water that EVs alone cannot provide. We appreciate that the plan reflects this in the descriptions of strategy T2 and the action categories. 

2. Redirect transportation investment away from highway and arterial expansion to safe, convenient walking, biking and transit, and also to making existing transportation resilient to the impacts of climate change

The Climate and Energy Action Plan should acknowledge the role of induced demand, by which highway and arterial widening causes net increases in driving and emissions, while not solving congestion.

Achieving the plan’s strategy to “Harden Transportation infrastructure to withstand future climate impacts” will require significant financial investment. The high cost of planned highway and arterial widening and new interchanges in Frederick County would take resources away from hardening existing infrastructure, while also worsening the County’s transportation emissions. 

3. Focusing new housing and affordable housing near jobs, transit and services is an important climate and equity action and needs follow-on implementation in planning and zoning

CSG applauds the plan’s action category T2.4 “Support population growth with new housing developed in communities that are walkable, bikeable, transit-supportive, and mixed-use.”

To accommodate a growing population while promoting sustainability, this measure will encourage the development of new housing in communities that are walkable, bikeable, transit-supportive, and mixed-use. Prioritizing these types of communities helps reduce car dependency, lower greenhouse gas emissions, and enhance quality of life for Frederick’s community members. It is imperative that transit-friendly design is incorporated into the planning processes in Frederick as development patterns will be instrumental in influencing the number of community-wide VMT. (p. 66)

It is critical that the County and City establish concrete actions and policies in planning, zoning, and housing that implement this. 

4. Add an action category to strategy T2 for Transportation Demand Management (TDM) and operations programs that both reduce emissions and improve mobility 

Transportation demand management programs should be added to complement the plan’s transit, bike and pedestrian action categories. The TPB’s Long-Range Plan Study showed that more robust travel demand management programs would be one of the top mobility strategies for the region – much more effective than highway expansion. The TPB’s Climate Change Mitigation Study and follow-on Implementation Considerations study also showed that travel demand management and pricing programs will be critical to reducing GHG emissions. 

Operational strategies can complement TDM. The I-270 Innovative Congestion Management program is an example of how even modest operations improvements have travel benefits without highway capacity expansion.

Thank you for your consideration and work on this plan.
Sincerely,
Bill Pugh, AICP CTP
Senior Policy Fellow
CC: Mobilize Frederick

MD Comments: Draft Go Prince George’s

Posted on by Elena Sorokina

August 13, 2025

Ms. Lakisha Hull
Director, Prince George’s County Planning Department
Maryland National Capital Park and Planning Commission
Wayne K. Curry Administration Building
1301 McCormick Drive, Largo MD                             via: gopgc@mncppc.org

Dear Director Hull:

Thank you for your active engagement with the public on the preparation of Go Prince George’s. We wish to provide some initial comments on the draft Go Prince George’s in advance of its formal consideration. First, we wish to express our overall enthusiastic support for the greatly revised Master Plan for Transportation, a welcome move towards a multimodal, complete streets approach to transportation. Here are some highlights of exciting elements of the draft plan: 

  1. Urban Street Design Standards are integrated into Functional Classification of roadways — this is a crucial guide for how road engineers decide how to design a road. This is an important advance to achieving full implementation. 
  2. Urban Street Design Standards are applied to both designated regional and local centers streets, and beyond. We strongly support this approach.
  3. Road diets – roads downsized from 6-8 lanes to 2-4 lanes, per Urban Street Design Standards. This is a major advance for fostering safer streets, connected communities, and economic development. Right-sizing these roads are essential to attracting transit-oriented development, such as along the Central Ave./Blue Line corridor. 
  4. Bicycle facilities are fully integrated into each road designation – this is a significant improvement. Example: Facility Recommendations (section 3).
  5. Bus priority (Transit policy – Policy TR) policy and cross-sections are included, along with 5 high capacity routes identified. Bus priority, however, is not consistently mentioned in section 3. Bus lanes are identified for MD 458 for example which we support, but not for MD 410.

Recommendations for improvements:

  1. Eliminate Vehicle LOS (level of service) for Local and Regional Centers, and other appropriate areas. We recommend the following language:

Policy RH 4: Eliminate vehicular LOS requirements within all Local and Regional Centers. This strategy amends Table 21 of Plan 2035, applicable recommendations of the 2009 Countywide Master Plan of Transportation, and the Transportation Review Guidelines.

The above proposed language will replace the draft’s vague policy – “Policy RH 4: Establish realistic and appropriate traffic level-of-service (LOS) standards for the determination of adequacy of roads and highways within a first-tier suburb.” 

Our Policy RH 4 recommendation is taken from the West Hyattsville-Queen Chapel Sector Plan, which states:  “TM 1.17. Eliminate vehicular LOS requirements within the West Hyattsville Local Transit Center. This strategy amends Table 21 of Plan 2035, applicable recommendations of the 2009 Countywide Master Plan of Transportation, and the Transportation Review Guidelines.”

This recommendation was also suggested in a draft of the West Hyattsville plan to be considered for application within all Regional Transit Districts and Local Centers. We agree.

  1. Add intersection design guidance as a separate strategy. We appreciate the many mentions of intersection features as important to complete streets, and in notes for specific facilities. However, a policy or strategy devoted to the complexity of intersection design would help advance many of the plan’s goals. Intersections are the most challenging aspect of street design in an urban environment, thus warrant specific attention. 

Regarding “Policy CG 7 Regularly refine and update the County’s adopted Urban Street Design Standards to reflect best street design practices.” We recommend the following additional strategy:

Strategy CG 7.4 Work with DPW&T and MDOT to identify and establish best practices for intersection design guidance.

  1. Design speed of 20-25 mph for Urban Streets should be cited as a specific goal and receive explicit attention. We ask the plan state 20-25 mph design speed be used as a key metric to guide roadway design decisions. Design speed is not mentioned in the draft, even though it states “Intended Functional Operating Speed: (20-25 mph)” and maximum speed limit of 20 or 25 mph. Solving for a 20-25 mph street as an overarching goal provides a framework that is more comprehensive than listing individual tools and practices that help reduce vehicle speeds to intended speeds. 
  2. Use vehicle miles traveled (VMT) per household as a key measure for development review. The draft cites the Plan 2035 identification of VMT as an important measure, but the draft makes no mention of using vehicle miles travel as a part of the development review process to assess the traffic and pollution impacts of each project. Using VMT per household helps create understanding of traffic network impacts, location efficiency, and mitigation needs. CSG has done this kind of analysis here and here. Scoring each new development for its VMT per household performance will help identify developments most beneficial to the county, the transportation network, and the environment. It will also call attention to mitigation needs for less location-efficient projects. 

Thank you for your consideration. 

Sincerely,

Cheryl Cort

Policy Director

CSG primer: Visualize 2050, our region’s 25-year transportation plan

Posted on by Elena Sorokina

The draft Visualize 2050 plan, our region’s long-range transportation plan, has too many highway and arterial road expansions that will increase driving and climate emissions. We will miss our region’s goal of reducing greenhouse gas emissions by 50% by 2030 – even if there’s a rapid switch to electric vehicles.

Get informed so you can take action on key decisions this fall: 

  • Upcoming key vote on flawed 495 Southside Express Lanes project 
  • Comment period on failing status quo Visualize plan

Source: TPB, with annotations by the Coalition for Smarter Growth

Background on Visualize 2050

  • Visualize 2050 is our region’s long-range transportation plan, prepared by the National Capital Region Transportation Planning Board (TPB), a regional body overseen by our local and state officials and transportation agencies. 
  • CSG background article
    • From March 2024, on draft project list that is now being presented for final approval this fall along with its performance results. 
  • 48 organizations criticized the previous plan, Visualize 2045 with very similar projects Letter by 48 regional organizations on Visualize 2045 (May 2022)

495 Southside Express Lanes Project

  • The TPB board will vote in October on whether or not to include the Virginia Department of Transportation’s flawed highway expansion project in the final plan.
  • Background on the project’s flaws, questions that VDOT has not answered, and better alternatives that need to be studied and advanced.

Stay tuned for actions you can take this fall!

  • Be on the lookout for CSG action alerts in September and October ahead of the TPB vote on the 495 Southside Express Lanes project.
  • Formal public comment on the entire draft Visualize 2050 plan will take place in late October through mid-November. CSG will provide a more in-depth overview of the draft plan – stay tuned.

VICTORY! M-83 Highway is Removed from Montgomery County Plans

Posted on by Elena Sorokina
Advocates spanning the generations celebrate our win at the Council Office Building on Tuesday, July 29! 
 

On Tuesday, the County Council voted 10-1 to remove the unbuilt portion of Mid-County Highway Extended (M-83) from county plans.  This was a victory decades in the making! 

Left on the books since the 1960s but largely unbuilt, M-83 offered false hope that extra road capacity could solve upcounty traffic problems. If built, it would have bulldozed farms, forests, streams, and wildlife in its path.

With this vote, our county leaves behind an outdated and harmful highway plan, and can focus on real, meaningful transportation investments upcounty. 

Thank you for your advocacy!

This win took a village. I am the fourth CSG Montgomery Advocacy Manager to have worked on this campaign (shout out to Kelly Blynn, Pete Tomao, and Jane Lyons-Raeder!) and am proud to have worked alongside dedicated advocates at TAME, ACT, and other partners who have advocated to remove M-83 for decades, as well as a new generation of advocates like Eco MoCo, led by high school and middle school students.

Over the years, CSG joined leading advocates at TAME in forums, walking tours, and research, reports, and testimony that demonstrated the ineffectiveness of the proposed highway, its environmental and community harms, and the benefits of more sustainable alternatives.

And we couldn’t have done it without you, our network of CSG supporters and advocates. In the past year alone, over 200 CSG supporters contacted the Planning Board and the County Council to support the removal of M-83 from county plans. That’s over 1,350 total emails!

What happens next?

Better street connections, safe bicycle and pedestrian infrastructure, and investments in frequent, reliable public transit all can help provide much needed transportation improvements upcounty—and upcounty residents need these changes sooner rather than later. 

When combined with mixed-use walkable neighborhood designs, these solutions will reduce the amount people have to drive, shortening car trips and increasing walking, biking, and transit use. 

As part of their vote on the Master Plan of Highways and Transitways, the Council approved an amendment to fund a comprehensive upcounty transportation study. CSG plans to support the special appropriation for this study at its September 30 hearing (sign-up opens August 1).

Once more, with feeling—THANK YOU, and let’s celebrate this win! 

I am so grateful for your support as we celebrate this victory, and I look forward to continuing to work with you all to win the sustainable transportation solutions upcounty residents need!

CSG in the News: County Council votes to abandon M-83 highway plan

Posted on by Elena Sorokina

July 29, 2025 | Ginny Bixby | Bethesda Magazine

An advocacy group that lobbied against the highway plan praised the council’s decision Tuesday in a press release.

“Plans for M-83 were based on obsolete planning assumptions that are out of sync with what we know today about effectively meeting transportation demand and protecting community and environmental health,” said Carrie Kisicki, Montgomery advocacy manager for the Washington, D.C.-based Coalition for Smarter Growth. “With their vote to remove M-83, the County Council showed we are ready to offer upcounty residents transportation solutions that will offer real relief—not a costly and environmentally harmful false promise.” 

Read the full story here.

RELEASE: Montgomery County Council votes to remove the unbuilt northern portion of the M-83 highway from Master Plan

RELEASE: Montgomery County Council votes to remove the unbuilt northern portion of the M-83 highway from Master Plan

Posted on by Elena Sorokina

The Montgomery County Council voted today to remove the unbuilt northern portion of M-83 from the Master Plan of Highways and Transitways, a move strongly supported by the Coalition for Smarter Growth and local leaders in the TAME Coalition.

CSG in the News: Does D.C. have the worst traffic? Not so fast.

Posted on by Elena Sorokina

July 26, 2025 | Rachel Weiner and John D. Harden | The Washington Post

“It’s not news that a successful metropolitan region like the D.C. region has a lot of traffic,” said Stewart Schwartz of the Coalition for Smarter Growth, a nonprofit that advocates denser urban areas with less need to drive. Concentrating future growth near transit, he said, “is the best way for our region to grow without choking on traffic.”

Read the full story here.

Recommendations to ensure an RFK stadium deal benefits DC, provides affordable housing and sustainable transportation options

Posted on by Elena Sorokina

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 have been working in the District of Columbia for over 28 years. We have been reviewing the proposal and were drafting this letter highlighting our concerns and recommendations when the news came out today that Chair Mendelson has the outlines of an improved deal. Without having the details of Chair Mendelson’s proposal before us, we will share the following in the hope that we can achieve the best deal possible for the District and its residents.

Prioritize an inclusive, vibrant community at RFK – with or without a stadium

CSG urges the District to prioritize the creation of an inclusive, vibrant community on the RFK Stadium site, including housing options for all, sustainable transportation choices, and community amenities – whether or not there is a professional sports stadium incorporated into the development. 

The administration’s proposal gives away too much, exaggerates economic benefits

Mayor Bowser’s proposed stadium and site development agreement with the Washington Commanders would give unprecedented public subsidies, control of development rights, and tax revenues away to the team. We appreciate the work of Chair Mendelson to reach agreement on an amended deal that directs some revenues and development control back to DC. CSG agrees that a regional sports stadium should be located in an accessible site with good public transit, walking and biking access and that the RFK site can fulfill those prerequisites; however, local and state governments also need to be good stewards of public land and funds. 

Incorporate these critical elements as a modified stadium agreement is considered: 

We ask the DC Council to incorporate these elements to ensure that a deal benefits DC residents and supports adopted District housing, planning and transportation goals:

  1. Ensure housing is built without delay in the Riverfront and Plaza Districts where the team has development rights
    • Establish controls, milestones, and clawbacks to ensure housing, affordable housing and supportive neighborhood retail and services are built in a timely manner.
    • We are glad to see that the amended agreement by Chair Mendelson includes deadlines for completion of nonstadium uses with penalties. We look forward to seeing more details on this and hope that it ensures timely housing and mixed-use development.
    • The Mayor’s deal did not provide any guarantees that the sports team will develop the adjacent sites for mixed-use development that supports city goals. Under that agreement, the Commanders could indefinitely use these as “temporary” surface parking.
  2. Require all residential development at the site follow the affordable housing requirements of DC’s public land disposition law
    • These include a 30% set aside of affordable housing at 30% and 50% median family income (MFI) for rental, and 80% MFI for ownership units in perpetuity (Code of the District of Columbia § 10–801), leveraging the land value as the first source of subsidy.
    • Land should be leased with covenants for affordability requirements.
  3. Replace parking subsidies with expanded public transit, walking and biking
    • The District of Columbia would spend over $350 million to build the largest parking garages in the city under the current deal, structures that would loom over the Kingman Park neighborhood.
    • Most of these funds should instead be used to improve transit, walking and biking access to and within the new neighborhood and stadium.
    • Specific improvements should include:
      • Metrorail station and service improvements. 
      • Bus priority lanes on H Street NE.
      • Improved pedestrian and bicycle facilities on the Benning and East Capital Street bridges to improve access from areas east of the river. 
    • We appreciate the redirection of $600M from the sports facility fee to upgrading the Stadium-Armory Station – and we believe that the District could gain greater savings – and needed investment in its public transportation system – by not subsidizing parking garages that will largely sit empty most of the year.
  4. Redirect more public revenues back to the District through revenue sharing agreement
    • We appreciate Chair Mendelson’s negotiation for some shares of revenues to come back to DC. But we think that the District can do better than receiving $779M spread out over 30 years given the large total subsidy. More revenue should be shared with the District beginning right after the first $500 million in debt is paid off.
  5. Require a strong performance-based Transportation Demand Management Plan
    • The TDM plan should include performance-based metrics to shift more trips to transit, walking, and biking, consistent with the targets of the District’s adopted MoveDC plan.
  1. Protect and improve public recreation access and community amenities 
    • Protect and ensure the continuation of existing community recreational and other uses on the RFK site, both during construction and after. These include parks, recreation, and sports facilities as well as uses such as the farmers market.
    • Expand The Fields recreation facilities, building on their high demand. 
    • Per the Comprehensive Plan, improvements should include the creation and maintenance of a pedestrian and cyclist shoreline access path and well-designed public spaces.

We urge the Council to ensure that DC residents will benefit from an RFK development plan and commitments that include housing options for all, sustainable transportation choices, and community amenities – whether or not there is a professional sports stadium incorporated into the development.