Category: Testimony & Letters

Sign-on Letter to the Montgomery Planning Board Re: Thrive 2050 Outreach

August 12th, 2020 

Dear Montgomery Planning Board, 

The coalition of organizations and individuals undersigned request additional outreach activities for the upcoming release of the working draft plan of Thrive Montgomery 2050. Many of our organizations have worked with the planning staff and have seen their diligent and innovative ways of conducting outreach during the COVID-19 pandemic. However, community leaders and organizations working with highly impacted communities see an interest and a need to take additional action in order to fully engage all communities. The communities of color that have been the most affected by COVID-19 in our county are the same communities where more Thrive 2050 outreach is needed, and comments are missing. 

It is our understanding that the Montgomery Planning Department intends to release the working draft plan of Thrive Montgomery 2050 on September 24th, hold a Planning Board review meeting on October 1st, hold a public hearing on November 19th, and maybe allow the public to submit comments until two weeks after the public hearing.1 We propose the following extensions, recommendations, and additional outreach strategies. 

• A working draft in both English and Spanish least 30 days before the November public hearing. 

• We ask for a second public hearing that is scheduled 30 to 45 days after the working draft plan has been released in Spanish. 

• Create more live multi-bilingual / bilingual outreach opportunities to have bilingual discussions between community members and planners on all sections of the working draft plan. 

• Conduct in-person outreach that is safe, outdoors, and physically distant, such as at food distribution centers/ hubs and at parks across the county. 

• Create and simultaneously release one-page multilingual informational fact sheets that highlight key sections and points of the working draft plan. Additionally work closely with community organizers to disseminate information and conduct community outreach on the working draft plan. 

We appreciate and thank the Planning Board for the opportunity to provide feedback on the working draft plan. We look forward to continuing to be partners in the Thrive 2050 conversation and find new and innovative ways to conduct outreach. 

1 Thrive 2050 Public Comment Timeline. (Last Updated on August 4th, 2020). Available from: https://montgomeryplanning.org/planning/master-plan-list/general-plans/thrive-montgomery-2050/ 

Sincerely, 

Denisse Guitarra

Maryland Conservation Advocate

Audubon Naturalist Society 

CSG Letter on Proposed Property Tax Changes

July 27, 2020 

The Honorable Sidney Katz

Montgomery County Council

100 Maryland Avenue

Rockville, MD 20850 

Re: Property Taxes 

Dear Council President Katz and Councilmembers: 

Thank you for the opportunity to provide comments on the proposals to alter the rules for property tax increases. Please accept these comments on behalf of the Coalition for Smarter Growth, the leading organization in the DC region advocating for walkable, inclusive, transit-oriented communities. 

We support a fix to the artificial constraints imposed by the current property tax cap, and want to ensure that the Council and County Executive have the authority to budget in a way that meets the community’s needs, particularly for social services, affordable housing, and public transportation. The county requires improved flexibility to meet unexpected challenges, such as the COVID-19 pandemic and all of the increased need it has created. 

At the same time as needs rise, Montgomery County has not been able to benefit from growth in the tax base, growth which is supported by a history of successful public investments in infrastructure, schools, and transportation. Continuous public investment and services are vital in order to maintain a high quality of life, spur further economic development, and battle external threats, including public health and climate crises. 

Therefore, we support proposals to remove the property tax cap and to require a supermajority of at least two-thirds of the council to raise the general property tax rate, not a unanimous vote as is now the case. We also support setting equal limits on rate increases for owner-occupied residential properties and for residential rental properties, since landlords pass property tax increases onto tenants in the form of higher rents. Homeowners and renters should be treated equally – renters should not face a higher pass-through cost of tax increases than homeowners. 

Thank you for your consideration. 

Sincerely, 

Jane Lyons

Maryland Advocacy Manager

Coalition for Smarter Growth 

CC: Montgomery County Councilmembers County Executive Marc Elrich

CSG Testimony Re: Montgomery County Complete Streets Design Guide

July 21, 2020 

Montgomery County Planning Board

8787 Georgia Ave

Silver Spring, MD 20910 

Item 12 – Complete Streets Design Guide (Support) 

Testimony for July 23, 2020 

Jane Lyons, Maryland Advocacy Manager 

Good evening and thank you to Chair Anderson and Planning Commissioners. My name is Jane Lyons and I’m speaking on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. We enthusiastically support the Complete Streets Design Guide. 

Thank you and congratulations to the staff who worked on this project – who has yet again solidified Montgomery Planning as a national leader in creative suburban planning. We are pleased that the Complete Streets Design Guide is clear in prioritizing safety, sustainability, and vitality, and provides a roadmap for how to balance competing needs. When we prioritize street space correctly, streets can become an engine for healthy people, a healthy economy, and a healthy environment. 

The biggest challenge in actualizing safe, green, vibrant streets is reengineering the county’s arterial roads, especially in lower income neighborhoods where traffic fatalities are more common. The vision in Thrive 2050 is for these arterials to become safe, green, multimodal boulevards, and this document will be a critical guide for those changes. 

A few constructive comments: 

• Page 55: We’d like it to be clear that a sidepath is always preferable to bikeable shoulders. 

• Page 57: We recommend that bikeways be listed as a high priority for downtown boulevards, downtown streets, town center boulevards, and town center streets. 

• Page 82: Bus shelters, in addition to BRT stations, should consider opportunities to provide additional passenger amenities such as seating, local area information, wayfinding, and real time traveler information. 

• Page 88: We urge the county to update its policy for snow events. Especially in downtowns and town centers, the county – not the building owners – should be responsible for clearing snow on sidewalks, sidewalk ramps, and sidewalk-level bicycle facilities. 

• Page 232: Public engagement should also include on-the-street direct outreach strategies, as well as strongly encourage paid community focus/advisory groups to ensure diverse input for major decisions. 

• Finally, we ask that the design guide be open to amendment upon the completion of the Pedestrian Master Plan and Vision Zero Action Plan. 

Implementing the Complete Streets Design Guide is key to achieving the county’s Vision Zero goal, as well as improving connectivity and helping shift mode-share away from single occupancy vehicles. We look forward to the comprehensive update of the Master Plan of Highways and Transitways that is necessitated by the guide, along with its implementation throughout new projects, resurfacing, construction, and maintenance. Wherever possible, we encourage the Planning Board, MCDOT, DPS, and the Council to codify the guide into law and regulation. 

Thank you for your consideration.

CSG Testimony Supporting Montgomery County Bill 13-20

July 8, 2020 

Montgomery County Council Council Office Building

100 Maryland Ave.

Rockville, MD 20850 

Bill 13-20, County Property – Disposition – Affordable Housing (Support) 

Public Testimony 

Jane Lyons, Maryland Advocacy Manager 

President Katz and Councilmembers, thank you for the opportunity to submit written testimony on Bill 13-20. Please accept these comments on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. We strongly support any efforts to make better use of our public land for affordable housing. 

Bill 13-20 would require any disposition of property that will be used primarily for housing development must be 30 percent income-restricted, with 15 percent as moderately priced dwelling units (MPDUs) and the other 15 percent for households earning 50 percent of less of the area median income (AMI). 

For too long, the county has not used its public land for its full potential. With many county properties located near high-capacity transit and land being a significant cost of construction, subsidized land costs makes deeper levels of affordability possible. At a time when we need 75 percent of new housing in the region to be affordable for low and middle income households, this legislation is common sense. 

We would like to see this legislation go a step further. If county land dispositions meet certain requirements, such as being a certain distance from transit, it should be required for that land be used for affordable housing. There is nothing under current law prioritizing or requiring certain uses to be considered, or giving preference to experienced affordable housing developers as partners. 

We need to re-imagine how we use public land, when being disposed of and when redeveloping. Libraries, community centers, and other public facilities should all be co-located with housing. Our region already has several examples of housing co-located with public facilities. We hope this legislation will be a first step for better using public land for the public good. 

Therefore, we urge you to support Bill 13-20 and seek provisions to make it even stronger. Thank you for your consideration.

RELEASE: CSG and Montgomery Open Streets Coalition Ask SHA for 19 Miles of Shared Streets

July 1, 2020

Mr. Greg Slater

Maryland Secretary of Transportation

7201 Corporate Center Drive

Hanover, MD 21076

Mr. Tim Smith, Administrator

Maryland State Highway Administration

707 North Calvert Street

Baltimore, MD 21202

RE: Shared Streets Treatments on Maryland State Roads in Montgomery County

To:  Tim Smith MD SHA Administrator

Dear Secretary Slater and Mr. Smith,

On behalf of the undersigned organizations, we would like to offer a list of State Highways that would benefit greatly from a “Shared Streets” approach as is being used by Montgomery County Department of Transportation. Recently, SHA itself coordinated with MCDOT and Councilmember Tom Hucker’s office in the closing of the right northbound lane on MD-97 in downtown Silver Spring to facilitate outdoor dining.

We are proposing a similar treatment of longer stretches of some State roads to promote greater connectivity for bicyclists and pedestrians and make it safer for those who do not want to drive or do not have access to a car to make trips throughout Montgomery County walking or by bicycle. These could be commuting to work trips, or shorter ones to go buy groceries, visit the doctor, connect with trails or do other errands. It is vital to provide alternatives to cars that are safe, affordable and are useful in getting people between different parts of the County or even within a short radius of where people live.

The list below amounts to almost 19 miles of state roads. We understand that SHA may want to pilot this concept of partial closures to cars and suggest that the stretch on University Boulevard is a good place to start as it would connect the Wheaton CBD with Sligo Creek Parkway and neighborhoods east of the Parkway as well.

We look forward to your response and hope that you can work with MCDOT and members of the Maryland House and Senate and the Montgomery County Council.

Here is the list of roads we propose as candidates for a Shared Streets approach:

  1. University Blvd/MD-193 from Colesville Road/MD-29 to Viers Mill Road/Md-586 (3.0 mi) (Connects from Four Corners neighborhood to Sligo Creek Parkway and Trail to Wheaton CBD)
  2. Viers Mill Road/MD-586 from MD-193 to Matthew Henson Trail (works best in pairing with no. 1 above (2.7 mi) (Connects Wheaton CBD to Matthew Henson Trail)
  3. Frederick Road/MD-355 from Germantown Road/Md-118 to MIddlebrook Road (.8 mi) (Connects Montgomery College/Germantown Campus and Holy Cross Hospital/Germantown)
  4. Piney Branch Road/MD-320 from Sligo Creek Pkwy to New Hampshire Ave/MD-650 (1.4 mi) (Connects Sligo Creek Parkway and Trail, New Hampshire Elementary School, Flower Ave and Northwest Branch Trails)
  5. Old Georgetown Road/MD-187 from I-495 to Executive Blvd (2.6 mi) (Connects Bethesda Trolley Trail, Ratner Museum, Wildwood Shopping Center, Josiah Henson Museum and White Flint)
  6. Georgia Ave/MD-97 from Norbeck Road/MD-28 to OlneySandy Spring Road/MD-108  (3.5 mi) (Connects Leisure World, ICC Trail and Olney CBD)
  7. Georgia Avenue/MD-97 & 16th Street/MD-390 from I-495 Overpass to Colesville Road (1.5 mi) (Connects Forest Glen Metro and Montgomery Hills Shopping Center)
  8. East-West Highway/MD-410 from Georgia Ave/MD-97 to Connecticut Ave/MD-185  (3.2 mi) (Connects Silver Spring CBD, Rock Creek Trail, and Chevy Chase) 

Paul Goldman, President, Action Committee for Transit

Jane Lyons, Maryland Advocacy Manager, Coalition for Smarter Growth

Alison Gillespie, President, Forest Estates Community Association

Kristy Daphnis, Chair, Pedestrian Bicycle Traffic Safety Advisory Committee

Peter Gray, Vice President, Board of Directors, Washington Area Bicyclist Association

cc: Montgomery County State Delegates and Senators, Montgomery County Council, Director MCDOT

495/270 P3 DEIS Comment Extension Letter

June 30, 2020 

Dear Ms. Mar and Ms. Choplin, 

We are writing on behalf of the undersigned organizations to request an extension of the public comment period. The proposed I-495 & I-270 Public-Private Partnership (P3) Program (Project) is likely to have significant impacts on water quality, air quality, and managed by the Maryland National Capital Planning Commission, and downstream on Rock Creek Park. 

The Maryland Department of Transportation – State Highway Administration (MDOT SHA) and the Federal Highway Administration (Agencies) have indicated they will soon make available for public comment the Draft Environmental Impact Statement (DEIS) for the proposed Project. This DEIS will describe the proposed action’s impacts on the environment as well as the impacts of alternatives and plans to mitigate the impacts. The document also will describe the environmental analysis conducted on the impacts of construction and operation of the new roadway. It is critical that the public have an adequate opportunity to meaningfully review the DEIS and submit comments to ensure that the Agencies’ analysis is complete and fairly considers all the options for the Project. 

We believe that allowing sufficient time for a well-considered review and thorough comments on the DEIS will lead to better evaluations, a more efficient process, and solutions that protect environmental resources, including Rock Creek. Due to the evolving situation with COVID-19, it is even more imperative that the public be given sufficient time to submit comments on the DEIS. Over the last few months, several of the undersigned organizations have submitted Freedom of Information Act and Maryland Public Information Act requests to the Agencies, the 

timely fulfillment of which would have assisted our reviews of the DEIS. These requests were denied, ignored, or delayed. 

The Project is one of the largest of its type ever proposed, expected to cost billions of dollars, and have significant environmental impacts. We expect the DEIS and its dozens of appendices and corresponding data to be thousands of pages. In regular times, for a proposed action such as this, the Agencies should reach an agreement to provide a longer time period and if not, the lead agency should easily find good cause to provide an extended comment period beyond 60 days from publication in the federal register. See 23 U.S.C. § 139(g)(2)(A); 42 U.S.C. § 4370m–4(d). Not doing so would not allow for meaningful public review and comment. 

These are not normal times. The emergency COVID-19 pandemic, and corresponding mandatory and voluntary restrictions, necessitate a longer public comment period. Like your agencies and other interested parties, our groups are working remotely while dealing with other responsibilities, generally without the use of office equipment such as printers for large files. Communications within our organizations, with members, and with others in the public that are interested in participating in the process are also delayed. The public’s ability to review and comment on the DEIS is currently hampered and requires more time than normal. Both of your agencies have recognized the difficulties caused by the pandemic. Both agencies have delayed providing electronic records in response to our public records requests (beyond statutory deadlines) based on asserted difficulties caused to the Agencies by the pandemic.1 It would be arbitrary for the Agencies to now deny the pandemic does not present good cause for a longer comment period. 

We appreciate the Agencies’ commitment that the public comment period will extend beyond the minimum-required 45 days and that the Agencies desire to allow full participation by the public and interested stakeholders. Forty-five days, or anything close to that, is clearly not sufficient. The undersigned organizations therefore request that the Agencies provide at least 120 days for public comment on the DEIS. This amount of time is necessary with increased uncertainty over the ability to re-open safely in a way that will allow the public to view documents in a timely manner. This time frame is also consistent with other Environmental Impact Statement comment periods such as the Washington Union Station Expansion Project and the Farmington Resource Management Plan. 

We look forward to your affirmative response to this request. 

Respectfully submitted, 

As an example, despite previously agreeing to provide non-exempt responsive records to one of our February 18 requests by April 30, MDOT SHA then requested that we “extend the 10-day period for providing a time and cost estimate, as well as the 30-day period for responding to your request, until 10 days after the date that [Maryland’s] state of emergency is lifted.” MDOT SHA stated: “Complying with the statutory timeframes of your PIA request at this time is not feasible given the state of emergency and recognized health risk that the coronavirus poses to all Marylanders, including State employees responsible for identifying, retrieving, and reviewing documents and responding to your request.” We still have not received any responsive records. 

Signed by, 

Jeanne Braha, Executive Director, Rock Creek Conservancy Josh Tulkin, Director, Sierra Club, Maryland Chapter 

On behalf of the following organizations: 

350 Montgomery County 

Audubon Naturalist Society – Woodend, Chevy Chase, MD 

Baltimore Tree Trust 

Beaverdam Creek Watershed Watch Group 

Cedar Lane Unitarian Universalist Church Environmental Justice Ministry 

Central Maryland Transportation Alliance 

Chesapeake Bay Foundation 

Chesapeake Physicians for Social Responsibility 

Citizens Against Beltway Expansion [CABE] 

Cleanwater Linganore Inc 

Climate Parents of Prince George’s County 

Coalition for Smarter Growth 

Conservation Montgomery 

DontWiden270.org 

DoTheMostGood Montgomery County 

Forest Glen Citizens Association 

Friends of Sligo Creek 

Greenbelt Advocates for Environmental and Social Justice 

Greenbelt Climate Action Network 

Indian Spring Citizens Association 

Indivisible Howard County 

League of Women Voters of Maryland 

Maryland Campaign for Environmental Human Rights 

Maryland Legislative Coalition 

National Parks Conservation Association 

Neighbors of the Northwest Branch 

North Hills of Sligo Creek Civic Association (NHSCCA) 

Our Revolution Maryland 

Parkwood 

Preservation Maryland 

Prince George’s County (MD) Peace & Justice Coalition 

Rapid Shift 

Regents Square Condominium (Rockville) 

Rock Creek Conservancy 

Rogue Tulips Consulting & Association Management 

Sierra Club, Maryland Chapter 

Takoma Park Mobilization 

The Ocean Foundation 

University Park Community Solar LLC 

Washington Area Bicyclist Association 

Wicomici Environmental Trust, Ltd. 

West Montgomery County Citizens Association (WMCCA) 

Woodside Forest Civic Association 

cc: Linda Strozyk DeVuono, Office of the Attorney General, LDeVuono@mdot.maryland.gov