The County Council sent a list of questions to the State Highway Administration (SHA) about the I-270 project and SHA has responded. Here are the questions and answers that caught our attention.
Question:
The Alternative Analysis/Environmental Assessment stipulates that the funding strategy for the I2-70 widening would be a combination of Federal highway funds, State transportation funds, and toll revenue. What are the anticipated funding amounts from each of these revenue sources? (An estimated range for each would suffice.)
Answer:
There are insufficient future federal allocations to the State of Maryland to accommodate a project of the magnitude of the entire I-270 improvements. As the CCT is funded through the next phase and the highway portion is not, the highway portion will be slightly different and proceed at a different pace. The highway portion of this multi-modal study will progress as several breakout projects once we are in a position to look at allocating funding for future phases of the project. At that time, MDOT will assess the appropriate funding sources (Federal, State, bonds, etc.) that are available to fund the various types of breakout projects, including the transit portion.
Our Take:
MDOT does not know how it would fund I-270 widening, but it plans on breaking the project up into smaller pieces. That might make it easier to schedule financing, but it will delay completion of the entire project by years.
Question:
Please identify the Federal aid programs from which funding the I-270 widening is anticipated. Which of these programs currently allow funding to be “flexed” from highways to transit and which do not?
Answer:
The majority of federal highway funds can be flexed either between specific highway programs or from highway to transit. To provide one example, up to 50 percent of the National Highway System (NHS) funds can be transferred to the Surface Transportation Program (STP) category. Up to 100 percent can be transferred to the STP category if approved by the Secretary of USDOT to be in the public interest. NHS funds cannot be flexed directly to transit; however, any amount of STP funds can be flexed from highways to transit. Because of the insufficient future of funding allocations, it would be premature for MDOT to specify the programs from which funding for the project is anticipated.
Question:
Are these statements about the Transportation Trust Fund, from MDOT’s web site, still true? “All funds dedicated to the Department are deposited in the Trust Fund and disbursements for all programs and projects are made from the Trust Fund. Revenues are not earmarked for specific programs…” “The Transportation Trust Fund permits the State tremendous flexibility to meet the needs of a diverse transportation system.”
Answer:
This comment is true for the State funds. Federal funds, however, are disbursed through the FHWA and FTA, independently. On the State level, while the flexibility is there, there is a limit to the funds available for highway and transit projects and how they will be distributed throughout the state. FHWA funds can be used for bus/HOV lanes where they are feasible, or for creating park and ride lots, or other Transportation System Management/Transportation Demand Management (TSM/TDM) measures. FHWA funds cannot be directly used for transit-only capital improvements on new alignments; they come under the purview of the FTA, and funds would need to be shifted at the federal level.
Our Take:
This addresses a key question: can highway money be moved dollar-for-dollar to transit projects? The answer is yes for state money. But there are restrictions on how the state can spend federal money that can only be resolved by the U.S. Secretary of Transportation.
Question:
If toll-backed bonds (i.e. GARVEE bonds) are used for this project, what is the anticipated debt service/interest obligation that the State will incur (expressed either as a range or absolute dollars or as a % of the total principal financed)? Will bond-financing for this project limit the ability of the State to bond-finance transit projects, and if not, what would be the impact on its bond-rating?
Answer:
GARVEE bonds are backed by future federal-aid allocations to the State. State law currently caps the amount of GARVEE bonds that can be issued in Maryland to the $750 million committed to the ICC project. Because of the insufficient future of funding allocations, it would be premature for MDOT to specify the financing from which funding for the project is anticipated.
Our Take:
The General Assembly normally has no control over which transportation projects get built. But if toll-backed bonds are used to finance I-270 – a virtual certainty if the project goes forward – the legislature will have to approve a hike in the state’s debt limit. That guarantees some interesting politicking down the road.
Question:
What is your initial analysis of the cost and benefits of the all-transit alternative offered by the Action Committee for Transit (attached)?
Answer:
The proposal set forth by Action Committee for Transit (ACT) is of such a magnitude as to require considerable time and effort to fully analyze costs and benefits. Our initial preliminary analysis of the all-transit alternative proposed by ACT is such that it would not benefit the full range of transportation-system users within the I-270 Multi-Modal Study project area, such as freight carriers and through route long distance travelers. It also appears that the Vision 270 plan has not been analyzed using a recent transportation and land use model that reflects future conditions, whereas the corridor alternatives in the I-270 study were analyzed using the Metropolitan Washington Council of Governments’ (MWCOG) land use and transportation models which do take into consideration future conditions.
Question:
What would be the time-delay and cost of studying this or other all-transit alternatives in comparison to the I-270 widening options?
Answer:
The study team already performed a preliminary study of an all-transit alternative prior to the issuance of the DEIS. Based on capital costs and proposed ridership, none of the all-transit alternatives, other than the use of express bus on an improved I-270 linked with the Corridor Cities Transitway, provided user benefits that would meet both the cost effectiveness criteria established by the FTA and the purpose and need for the Multi-Modal Study. The results of the all-transit alternatives that were dropped from further study prior to the DEIS only provided a modest decrease in vehicle miles of travel (VMT) on I-270.
Essentially, this would re-start the NEPA process for each project, including the CCT. These projects would need to go through NEPA and each be independently developed using the FTA New Starts project planning and development process in order to receive federal transit funds. The process is time consuming to complete and can require well over a decade to get a project through planning and design, construction and initiation of operation, and would cost several millions of dollars.
Our Take:
MDOT believes ACT’s all-transit plan could not meet federal cost effectiveness criteria. Further, MDOT claims that studying that plan would delay the CCT by restarting the planning process for the entire I-270 corridor. Did anyone tell the state legislators who signed the letter advocating for the all-transit option about this?
This response gives ammunition to both supporters and opponents of the I-270 project. We reprint it in full below.
