The following is a letter the CCCT sent to Governor Ehrlich requesting an expansion of the current Environmental Impact Study (EIS) of the Inner Purple Line (IPL) to include the study of some undergrounding. This request does not represent a change in our neutral position on the IPL - it is simply an indication of our concern for the impact a surface rail line will have on some sections of the CCT. We believe that the CCT can co-exist with a surface IPL between Silver Spring and Bethesda (in the last mile into Silver Spring it will only exist as an off road trail if the IPL is built), but the section between Rock Creek and Bethesda will lose its park like character, and its usage will likely be reduced, primarily, to purposeful trips, We feel that the possibility of losing this setting justifies the expanded study, and we will be closely monitoring this issue as it develops.

January 15, 2003

Governor Robert Ehrlich
State House
Annapolis, MD 21401

Subject: Expanding the scope of the Inner Purple Line Environmental Impact Study

Dear Governor Ehrlich:

The Coalition for the Capital Crescent Trail (CCCT) is writing to ask that the scope of the Inner Purple Line (IPL) Environmental Impact Study (EIS) be expanded to include the option of some undergrounding. We feel that the constraint the Maryland Mass Transit Administration (MTA) is following to only evaluate a transit alignment that is entirely on the surface is too limiting. The feasibility and cost of undergrounding the IPL in especially sensitive areas must be evaluated so that decision makers will have design options available that can preserve the character of the Capital Crescent Trail (CCT).

CCCT is an all-volunteer, non-profit organization with over 1600 members. We are an advocacy group formed in 1986 when the CSX Corporation decided to abandon the Georgetown Branch right of way (ROW), with the purpose of seeing a continuous trail being established within that ROW, between Silver Spring and Georgetown. We were instrumental in getting Montgomery County to acquire the section lying in their jurisdiction under the Federal Rails to Trails Act in the late-1980’s. Our mission is to support a high quality trail, suitable for a variety of users, which links Georgetown and the C&O Canal towpath trail to the CCT along the Georgetown Branch, through Bethesda and on to Silver Spring where it joins the main CSX tracks. It is our goal to continue the CCT into Silver Spring to join with the Metropolitan Branch Trail and the Silver Spring Green Trail. Additionally we support having the CCT provide easy access to a park environment for as many neighborhoods as possible.

The CCT has become the most heavily used trail in Montgomery County. It enjoys tremendous support both in the adjacent neighborhoods, and among the over one million users per year. It is an important recreational and commuter resource for the entire region. The Maryland National Capital Park and Planning Commission took a trail user survey in August and September of 2000. That survey gives insight into the characteristics that have made the CCT so successful. The trail users are a very large group, counting over 500 users/hour during peak periods and 240 users/hour average. The survey found that trail users are very representative of both sexes and of all age groups. Trail uses are diverse, with 41% cyclists, 37% walkers, 15% joggers, and 7% inline skaters. People with disabilities and infants in strollers were among the users (approx. 3%). Peak use periods were during weekday evenings and weekend afternoons, especially among walkers and joggers. Other peak use periods were during weekday commuting hours, especially for adult cyclists. The high traffic counts during commuting periods shows that the CCT has a significant transportation use for purposeful trips. But the even heavier traffic counts in weekend and evening periods demonstrates the very important recreational use the trail has providing access to a park environment.

The CCT is such a successful multi-use trail because it has design characteristics that satisfy the diverse needs of two large user groups - those making purposeful trips and those seeking a recreational experience in a park. The completed portion of the trail has been built to high design standard throughout, with good continuity and with bridges or tunnels eliminating conflicts with motor vehicle traffic at major roadway crossings. These characteristics permit cyclists to commute safely from Bethesda to Georgetown faster than is often possible by automobile. The trail also is built in a wooded corridor, under a tree canopy and in a quiet, park-like setting. People of all ages, including families with young children, can walk, jog, or cycle along the trail and enjoy an escape into a serene, park-like setting. This is an especially scarce and prized retreat in the heart of a dense urban area. It is this combination of a good functional trail design and a quiet park setting that sets the CCT apart from other bike paths or park trails, and accounts for why the number of users on the CCT is twice as great as on any other trail in Montgomery County. If either the high functional design standards or the park setting is lost, the CCT will be greatly diminished.

The MTA is performing an EIS to develop concepts and to evaluate impacts of a doubletrack IPL that would share the Georgetown Branch Corridor east of downtown Bethesda and part of the CSX/WMATA corridor in Silver Spring with the CCT. Light rail trains, each car a length of 96 feet, would run 19 hours a day, as often as every three minutes at speeds of up to 50 mph. MTA representatives presented early design concepts to the public in workshops in November 2002 and have also walked parts of the corridor with representatives from the neighboring communities and from the CCCT. It is evident from these meetings that MTA is trying to develop designs that retain a trail, but it faces severe design constraints because of the narrowness of the right of way and the need to accommodate a number of safety requirements such as providing better physical separation between transit and trail where possible, better protecting trail users from transit vehicle noise, providing better and more frequent neighborhood cross-rail connections to the trail from adjacent neighborhoods and protecting the crucial trail alignment through the Bethesda tunnel.

The difficulty of completing the final CCT in downtown Silver Spring continues to be of great concern to the CCCT, and we are pleased that MTA has made an especially strong effort to develop a transit/trail design that would provide a trail with good continuity through the very difficult and constrained CSX/WMATA corridor. MTA’s design concept would create a safe and functional trail in the “final mile” that is crucial to complete the trail connection between Montgomery County’s two largest urban centers, Bethesda and Silver Spring. The trail MTA proposes alongside transit in this eastern most section of the corridor would likely be better than any shared use trail we can build in Silver Spring without the assistance of the Purple Line.

But the trail character that is so important to the trail users and to nearby neighborhoods will be lost elsewhere along the corridor for a CCT rebuilt alongside the IPL. The corridor is too narrow in some places for the trail and transit to coexist on the surface without sacrificing virtually all of the park setting and quiet experience trail users now enjoy. This is especially true at the west end of the corridor, where the right-of-way is only 66’ wide. Even if the trail is placed within 10’ of the passing transit vehicles, the entire width of the corridor will be within the limits of construction and no mature trees will remain in the corridor. MTA can design a bike path alongside transit that has a good functional design for purposeful trips in these constrained areas, but MTA has an impossible task in attempting to preserve a pleasant trail environment so important to a majority of trail users, including the elderly, children, families and recreational users, if it is constrained to following a transit alignment that is entirely on the surface.

CCCT is asking that you direct MTA to determine the feasibility, cost and impacts of undergrounding the Purple Line in those areas where the available right-of-way is too constrained to save the park character of the trail. CCCT recognizes that MTA has developed very approximate cost estimates for undergrounding transit over the entire length of the corridor between Bethesda and Silver Spring. We are not asking that underground options be studied for the section of the corridor east of Rock Creek, because trail users seeking a direct connection into, and through, Silver Spring are best served by having the CCT completed alongside transit in the very difficult CSX corridor. But an underground transit system between Rock Creek and Bethesda would provide the trail experience currently enjoyed by the public on the completed section of the CCT west of Bethesda to those who would use the trail to the east.

In sum, the quiet park setting under a tree canopy is an essential part of the trail experience for many of our trail users. An at-grade Purple Line will result in the destruction of many hundreds of mature trees, not to mention thousands of smaller trees, and the beautiful park character that gives the CCT much of its value. The easy access the CCT gives to a serene park environment is essential for maintaining a good quality of life for many close in urban neighborhoods. The CCT will play a decisive role in shaping public opinion, determining whether the Purple Line project succeeds or fails to gain acceptance. Please direct MTA planners to develop information on all reasonable options to protect the park character of the Trail. If options such as partial undergrounding are not given serious examination by decision makers then many trail supporters and much of the public will likely resist conclusions drawn from any IPL EIS as being based on incomplete information.

Sincerely

Ernie Brooks, CCCT Chair