ANS TESTIMONY TO MARYLAND DEPARTMENT OF TRANSPORTATION STATE HIGHWAY ADMINISTRATION (MDOT SHA)
Audubon Naturalist Society’s testimony to Maryland Department of Transportation State Highway Administration (MDOT SHA) and Federal Highway Administration (FHWA) on the I-495/I-270 Managed Lanes Study Supplemental Draft Environmental Impact Statement.1
Maryland Conservation Advocate, Audubon Naturalist Society (ANS)
November 1, 2021
Dear MDOT SHA and FHWA,
For 124 years, the Audubon Naturalist Society has inspired people to enjoy, learn about and protect nature. ANS demands that last year’s DEIS “No Build” option still remains as the preferred alternative, as the SDEIS still lacks complete studies on environmental justice, climate change, wildlife, and waterways impact, and fails to include transit alternatives. The Managed Lanes highway expansion project pushes far beyond the climate constraints people and the environment are currently experiencing today. The United Nations IPCC report2 released earlier this year makes it clear – we have no time left to get ourselves off of fossil fuels and save as much of our planet as possible. Maryland and Virginia need a more equitable, transit, and climate-friendly solution to solve our traffic congestion problems. We need excellent transit and not an inch more of car-coddling pavement. ANS demands that MDOT SHA and FHWA do not move forward with the project’s “Preferred Alternative” option.
The preferred alternative would negatively impact people’s lives and wellbeing. On Chapter 4 of the SDEIS, it mentions that 501 properties would be impacted by the project, the majority of these being residential properties.3 Even more alarming, the SDEIS does not provide details on how communities, especially POC communities, would be impacted by the new bottlenecks on I-270 beyond its intersection with I-370. Equally disturbing, the SDEIS fails to include a complete study of the overall cumulative impacts the project will have on people. Under our four concurrent public health, climate, economic, and social crises, it does not make sense to add more air-polluting lanes.
Moreover, the preferred alternative listed in the SDEIS does not properly mitigate the negative impacts the highway expansion project will have on air, water, wildlife, and people. The SDEIS, like its predecessor the DEIS, fails to properly account for and provide any solutions and dangerously underestimates the devastating impacts the project will have on people and the environment. The SDEIS fails to consider the mitigation of 1,000,000 sq ft of floodplains and over 186,000 sq ft of wetlands.4 Lacking these critical pieces of information, when climate change is already causing major flooding issues in the region, is completely irresponsible of MDOT SHA and FHWA. In terms of water quality, the SDEIS’s preferred alternative will reduce Montgomery and Prince George’s Counties capacity to reduce and meet its Chesapeake Bay Total Maximum Daily Load (TMDL) goals. Furthermore, the project will impact 500 acres of forests and 26 acres of Parkland.5 In terms of rare, threatened, and endangered (RTE) species, 41 species are in peril due to the project.6 The irreplaceable destruction the “Preferred Alternative” is expected to have on the environment is so extensive that no built infrastructure could ever replace the natural infrastructure this project would take down, placing Maryland and Virginia at a higher climate catastrophe risk for the next 50 years.
ANS and our partners recommend that MDOT SHA and FHWA do not approve the SDEIS’s “Preferred alternative” due to its incomplete, faulty, and deceiving information and instead opt for the “no build alternative” option listed in the DEIS. On behalf of ANS and our 28,000 members and supporters, ANS respectfully requests that MDOT SHA and FHWA to act responsibly and not move forward with the SDEIS’s Managed Lanes Preferred alternative today.
About ANS: Throughout its history, ANS has championed nature for all by playing a pivotal role in conserving our region's iconic natural places from development including the C&O Canal, Dyke Marsh and, most recently, Ten Mile Creek. Past ANS member and board president, Rachel Carson, author of Silent Spring, is credited with launching the now global environmental movement. ANS's nature experts provide hundreds of opportunities each year for children and adults to enjoy, learn about, and protect the environment.