October 15, 2018
To: Annapolis Planning Commission
Dear Chairman Waldman,
In advance of the public hearing scheduled for November 1, 2018 regarding the August 31, 2018 the Forest Drive/Eastport Sector Study Draft (“Sector Study Draft”), we are respectfully requesting that additional information be made available to the public in advance of the meeting in order that it may be a more productive session.
In particular, we are asking that more detailed information be made available as regards the communications and input from both Anne Arundel County and the State Highway Administration with respect to proposed roadway infrastructure improvements which will involve the cooperation of these neighboring public entities. As per MD Land Use Code § 3-203(c), these entities were to be provided with the Sector Study Draft at least 60 days in advance of the public hearing. One can reasonably presume this requirement was to ensure that the critical input from these jurisdictions is available for consideration by the public and the Planning Commission at the required public hearing on the Sector Study Draft.
Please allow us to provide some background on this issue and our request.
Background and Basis of Concerns
On pages C-29 and C-30 of the Sector Study Draft, there is a listing of proposed roadway capacity improvements. Determining whether or not these roadway improvements are viable seems critical to implementation of the visions in the Sector Study Draft. If roadway capacity improvements are not installed, and major shifts from historical commuting patterns are not achieved as contemplated by the Sector Study Draft, then true traffic gridlock is a real possibility.
Annapolis’ Policies and Guidelines For Traffic Impact Analysis for traffic impact studies, page 14, attached, has long required that intersection Levels of Service (LOS) at peak travel times below a “D” are unacceptable. This same standard is applied by Anne Arundel County. This minimum LOS mandate includes an assessment of both the overall intersection, as well as each individual movement at each intersection. If the LOS will be lowered below “D”, improvements are required by the developer to bring the level back at least to “D.”
Despite this long applied mandate in Annapolis, the Sector Study Draft confirms on the table at pages C-10 to C-12 that, as of 2017, with no new development of any kind, many intersections and individual movements are already operating at LOS “E” and “F”. Even if all the recommended roadway capacity improvements are installed, with no new development of any kind, there remains many locations with LOS of “E” and “F” as is reflected the tables on pages C-31 and C-32.
Acknowledging the obvious critical nature of the proposed roadway improvements, one of the main concerns of ANPF and ECA regarding these proposed fixes is that they are “put on the shelf” and nothing ever comes of them.
As justification for this concern we refer to the 2009 Annapolis Comprehensive Plan, Chapter 4 – Transportation, Policy 5, attached, which specifically addresses the continuing growth of congestion in the Forest Drive corridor. This Policy 5 highlighted the need for the City to “preserve and enhance the array of solutions currently at the City’s disposal.”
The Comprehensive Plan Transportation Policy 5 specifically notes as follows:
"The City must keep a broad set of options available for dealing with this congestion in the future. If problems grow as forecasted, these options will become increasingly important in engineering an overall solution. For now, Anne Arundel County is widening Forest Drive from Aris T. Allen (MD 665) to Hilltop Lane, adding a lane in each direction. These are first steps in a phased improvement to the corridor. ...
"To adequately address congestion in the Forest Drive corridor it will be necessary to update the prior studies in order to recommend a comprehensive set of improvements which will document and weigh the potential impacts of a parallel service road and provide a set of improvements to access and circulation within the Forest Drive corridor and the Forest Drive Opportunity Area (see Ch. 3 - Land Use & Economic Development). Based on the new studies, it may be determined that a parallel service road is inappropriate. The goals of the improvements in the Forest Drive Corridor are to:
► reduce peak-period congestion,
► provide some measure of redundancy in the arrangement of streets by expanding connectivity in the existing road system and between neighboring grids, thus enabling short trips to be made without accessing Forest Drive (MD 665),
► advance the City’s commitment to alternative forms of transportation and reduced dependence on the automobile. In determining the future use of the Forest Drive parallel service route, priority should be given to alternative forms of transportation – transit, bicycles, pedestrians.
Furthermore, the City should:
► Aggressively lobby the State and the County to begin and complete the study of the 665/Forest Drive/Chinquapin intersection within the next year; ..."
2009 Annapolis Comprehensive Plan, Chapter 4, Transportation, P. 55
(underlining emphasis added)
Many of these “fixes” proposed almost ten years ago are simply listed once again in this Sector Study Draft. The urgent need in 2009 to “Aggressively lobby the State and the County to begin and complete the study of the 665/Forest Drive/Chinquapin intersection within the next year” was never commenced or completed. Rather, the Sector Study Draft simply includes this idea of jurisdictional cooperation to fix this troublesome intersection as an item to be completed in the “near term,” meaning in the next 3 years. (See Item 3.3.4 at page E-4 of the Sector Study Draft). In short, critical planning that was to be completed in 2010 is not yet commenced and is recommended for completion in the Sector Study Draft by 2022.
Moreover, there is a formal recommendation in the Sector Study Draft to deal with the past failure to address this intersection “aggressively” as planned in 2009 by simply “retaining the existing bottleneck by electing not to make improvements that move queues further down the corridor.” See Sector Study Draft at page C-30.
What is Needed For the Public Hearing
In the Sector Study Draft, many of the recommended roadway capacity improvements relate to County and State Highways. The County controls Forest Drive from Bywater to the east. The State controls the southern terminus of Chinquapin Round, 665 up to Bywater, Spa Road at the intersection of Forest Drive, and Old Forest Drive. As opposed to simply listing potential capacity improvements yet again, there needs to be more specifics at the public hearing and in the Sector Study Draft outlining the discussions which have been held with County and State representatives with respect to proposed changes to their roadways. Indeed, the applicable regulatory framework for preparing comprehensive plans and amendments thereto contemplates some level of detail in this regards.
As noted above, the 2009 Annapolis Comprehensive Plan highlighted that, with respect to the possible improvements on the Forest drive corridor, more detailed assessment was “increasingly important in engineering an overall solution.” The 2009 Annapolis Comprehensive Plan also noted what should be some of the objectives in the mandated sector studies, including the Sector Study Draft. Among the purposes for the required sector studies was to “identify the necessary role of the City and other public entities in facilitating redevelopment, including, for example, infrastructure improvements…” See 2009 Comprehensive Plan - Land Use and Economic Development, Chapter 3, Policy 1, Page 33.
The Sector Study Draft needs to include more details on the status of discussions with the County and the State who must be involved in implementing many of the proposed roadway capacity improvements. Not only will this information enhance the value of the study as a planning tool, State law suggests that this be done.
MD Land Use Code § 3-203(c) requires that local jurisdictions responsible for financing or constructing public improvements necessary to implement a comprehensive plan, or an amendment to a plan as is the Sector Study Draft, should provide their comments regarding the proposed improvements. Equally important, as required by MD Land Use Code § 3-203(d), comments from the County and the State are to be provided to the City Council when the Planning Commission sends its proposed sector study for approval. As the comments from the County and State regarding proposed infrastructure improvements must be presented to City Council, it seems only reasonable they be made available to the public before a hearing at the Planning Commission level.
Ideally, representatives of these neighboring jurisdictions could be invited and present at a public hearing on the plan to obtain their observations on the proposals. Note that the Planning Commission may hold more than one public hearing on the Sector Study Draft.
We recognize that detailed engineering analysis of each of the proposed infrastructure improvements likely do not exist. However, it seems only reasonable that discussions with these neighboring jurisdictions could include very useful information to increase the value of the Sector Study Draft as a planning tool. For example, some information that would be helpful could include, among others:
Until the feasibility of the proposed infrastructure improvements are confirmed with neighboring jurisdictions, it seems that a recommendation in the Sector Study Draft might include a suggestion to postpone any changes to either the Traffic Adequate Public facilities Ordinance Policies or the Guidelines for Traffic Impact Analysis For Proposed Development as suggested in Appendix D to the Sector Study Draft. Until it becomes clear what, if any, of the proposed infrastructure projects are viable, we suggest that it is much to soon to change or lower Traffic Adequate Public Facilities standards or to allow alternate mitigation options for developers. Good decisions on these matters cannot be made until we know what mitigation options even exist. Feasibility of the proposed roadway projects needs to be completed first we suggest.
We thank you in advance for consideration of this request. If the County or State do not feel the 60 days allowed by law for them to review and comment on the Sector Study Draft is sufficient to allow them to prepare their comments, we suggest postponing the public hearing until they can provide some level of comments specifically addressing the proposed roadway infrastructure projects.
s/Anastasia Hopkinson s/Vic Pascoe
Vice President President
Annapolis Neck Peninsula Federation Eastport Civic Association
cc: Annapolis Planning Commission
Annapolis City Council
Attachments to letter
Eastport Civic Association
P.O. Box 3539
Annapolis, MD 21403
Copyright © Eastport Civic Association. All rights Reserved.
ANPF and ECA submitted comments and concerns on the May 31 draft of the Sector Study. Many of
these were not addressed in the July 26 version. We still have a number of issues and unanswered
Firstly, we continue to be concerned that some of the recommendations ignore or do not address the results of Community Survey #1. When asked “What do you not like about the study area?”, respondents indicated, “Traffic when there was an accident”, and “Traffic on a day-to-day basis”. When asked “What is most important to focus on?”, two of the top three items were, transportation and environment. We remain concerned that this community feedback is not adequately addressed by the study. Also, the response rate to Survey #2 was very low and should not be considered representative of community views.
We would like to have a discussion with Planning and Zoning about the traffic and population and growth assumptions and the items below.
1. There can be no failed road intersections. All intersections should have level of service indicators of D or higher. The infrastructure recommendations from the 2009 Comprehensive Plan should be funded and the work completed prior to considering any land use changes. The recommendations remain valid today and are the basis on which many of the Sector Study’s recommendations are made.
2. For projecting future growth and for traffic analysis, the development pipeline (Appendix A) should include those projects within the entire geographic area that impacts Forest Drive. Additional TAZs in the county should be included in the analysis. The pipeline of potential projects is not up to date and should include those with applications approved, submitted for City and County review, and those in the concept stage where the property has been zoned for development and where discussions have been held with the City/County. Projects adjacent to the study area should be included because those potential developments have traffic and other consequences in the corridor.
3. We appreciate the City’s coordination with a County traffic specialist. However, additional coordination, broadening the discussions to the County’s long term land use/zoning and infrastructure funding plans, should be undertaken.
4. Several additional traffic model forecasts should be run, based on a build out of additional City and County pipeline projects that are located in or adjacent to the corridor. Forecasts should include the existing conditions shown in the Study’s Technical Appendices on pages C-9/12 and improved conditions pages C-31/32.
5. Land use changes could have a negative effect on the environment (more traffic, destruction of trees, storm water runoff into the creeks and the Bay, etc.). One of the plan’s three themes is to “promote a Green Annapolis”, which we take in part to mean protect the environment. A Green Annapolis is more than establishing a greenway and planting new trees. It is about protecting the land and existing trees. The plan should include a recommendation for the City to pass the No-Net-Loss Ordinance, 0-27-18, which will provide clear safeguards to prevent canopy trees from being removed (and other protections).
6. The City traffic standards should be the same as or higher than in the county, but should not be addressed until the feasibility of potential infrastructure improvements is confirmed with neighboring jurisdictions.
7. A plan for affordable housing should be formulated, including recommendations for incentives that could be offered. Affordable housing is crucial for attracting middle class workers. This is cited in the Technical Appendices, Section B (US City Economic Trends Memo) “… as a critical driver of business and workforce location decisions.” If an objective of the study is to create more jobs so that residents can work in the corridor, affordable housing is an important component.
8. Metrics should be included to assess whether the plan’s goals are being met and the land use/zoning changes are effective or need adjustments.
9. The character and zoning of properties along Forest Drive should remain suburban. The majority of the surrounding area is suburban. Per the community surveys, there is little community support for the Forest Drive corridor to be urbanized and transformed into a boulevard with four to five story buildings sited close to the roadway. Urbanization means up zoning properties and increasing densities. That will result in increased traffic congestion, require more traffic signals, and slow the movement of vehicles on the arterial.
The City has prepared a plan for development along the Forest Drive Corridor and in Eastport. The plan, called a Sector Study, identifies a significant amount of new residential and commercial development over the next decade. In March 2019, the City Council will vote on whether to approve the Sector Study and accept it as part of the City's long-range Comprehensive Plan.
ECA response to the Sector Study.