The Capital Beltway near the I-270 interchange in Bethesda Credit: File photo

As the public comment period winds down for the environmental impact study of the I-495 and I-270 widening, local officials are continuing to voice their concerns about the project, detailing what they claim are “serious deficiencies.”

The Maryland-National Capital Park and Planning Commission (M-NCPPC) — which owns and maintains parkland and open space in Montgomery and Prince George’s counties — on Wednesday discussed its latest comments on the project. The commission plans to oppose approving any joint permit applications that don’t address its concerns.

The commission discussed its extensive comments — some of which were detailed in a staff memo — on the Draft Environmental Impact Statement (DEIS) in a closed meeting. Members then voted in open session to unanimously approve the final comments to the state.

The public comment period for the DEIS, which has more than 19,000 pages, ends on Nov. 9.

The state is proposing widening I-495 and I-270 through a public-private partnership, which would be reimbursed by toll revenues. The project, which is aimed at alleviating traffic bottlenecking on the stretch, is estimated to cost between $9 billion and $11 billion.

Six alternatives for the widening are included in the DEIS, most of which recommend adding two lanes on either side of I-495 and I-270 to accommodate high-occupancy vehicles and those opting to pay tolls.


M-NCPPC and Montgomery County officials have criticized details of the state’s plan for the widening project and have repeatedly called for transit and other alternatives to be considered.

On Sept. 10, Montgomery County Executive Marc Elrich said at a hearing sponsored by the Maryland Department of Transportation that state officials should go back to the “drawing board.”

“The state has structured this as an all-or-nothing project,” he said. “By ruling out transit and other alternatives, it’s left us with either you support toll lanes or you don’t support doing anything. And this sets the project up. … to be in opposition to what most of the public thinks should be done right now.”


Carol Rubin, the special project manager for M-NCPPC, said Wednesday during the briefing that “hundreds of technical comments” will be in the letter to the state.

“Our comments are actually to identify those areas of concern and hopefully it will move the needle a little bit to negotiate with us and discuss what our concerns are and hopefully address those concerns as the project moves forward,” she said.

Under state law, state officials are obligated to address and respond to each of the commission’s comments.


Some of the commission’s major concerns are that the Maryland Department of Transportation’s State Highway Administration and the Federal Highway Administration have eliminated alternatives from the study, including a traffic diversion alternative on Md. 200 and transit options for further detailed study.

The traffic diversion to the Intercounty Connector was proposed by Montgomery County officials to avoid widening I-495 through Bethesda and Silver Spring and to protect federal- and county-owned parkland surrounding the northeastern stretch of I-495 — also known as Capper-Cramton land.

“[These] would be practical and much less damaging to the environment,” Rubin said. “In other words, the whole process of the DEIS. … is that it’s supposed to be a balance test. You’re supposed to look at potential reasonable alternatives and then balance those against environmental impact and we don’t feel that they have really provided enough look at those different alternatives that would provide a way to actually balance or compare.”


The alternatives the state has now are “essentially all the same,” Rubin said, referring to footprints, environmental impacts and effects on community resources.

The commission is also claiming that the state has underestimated the “limit of disturbance,” which includes the boundary of construction, grading and clearing of vegetation.

“The limits of disturbance are based on very rudimentary plans and we just don’t think that they are appropriate,” Rubin said. “We think they’re too narrowly drawn.”


The joint permit application and other project documents also fail to adequately address required mitigation, according to the staff memo.

Rubin said the project is in planning stage now, which means no one understands what the environmental impacts are going to be yet. State officials have also not identified the effect on historic resources on the potentially affected land, which does not comply with the National Historic Preservation Act, she said.

Rock Creek Park and Sligo Creek Parkway, which are officially designated as historic resources, will be hurt if the proposed permits are granted, according to the staff memo.


Another problem with the joint permit application is that it would be seeking water quality certifications before the outcomes of those certifications could be determined.

“How can they complete their application and grant permits to areas of disturbance where you don’t know what the disturbance is going to be?” Rubin said. “Again, it’s a process problem because they’re proposing to issue the Clean Water Act permits for this project to areas that are probably not going to be designed [until] five years from now. … We don’t really know how they can move forward with permit applications when they don’t really know what those applications are going to entail.”

In response to the DEIS, officials laid out its concerns that the Md. 200 diversion alternative for traffic wasn’t studied in more detail since it avoids impact to environmental resources.


The limit of disturbance is “unrealistic to depend on to understand impacts to parkland as it is a preliminary tool,” according to the staff memo.

Other commission concerns include: the DEIS doesn’t meet the stated goal of leveraging other modes of transportation, the storm water management approach is “insufficient,” a lack of financial viability and incomplete project costs.

Basic project costs are omitted from the state’s plans, such as a “lack of consideration to relocate utilities and water and sewer lines, likely project delays due to litigation, design difficulties and land acquisition challenges — similar to what has happened with the Purple Line,” the memo says.


Toll roads on I-495 and I-270 won’t pay for themselves and will require some level of government subsidy, the memo states.

The cost of building and operating the managed lanes is “likely to exceed the toll revenue generated by the project, making the state’s decision to exclude transit and other alternatives that would require sources of funding arbitrary and capricious,” the memo says.

Briana Adhikusuma can be reached at