June 12, 2020
Ms. Holly Arnold
Maryland Transit Administration
6 St. Paul Street
Baltimore MD 21202
RE: Comments regarding the draft Central Maryland Regional Transit Plan
Dear Ms. Arnold,
Thank you for the opportunity to provide comments on the draft Central Maryland Regional Transit Plan
(hereafter, “draft plan”). The Greater Baltimore Committee (GBC) commends you and your team at the Maryland
Transit Administration (MTA) and the members of the Commission for delivering a draft plan with ample time for
public comment during this challenging time. We appreciate your presentation of the draft plan before the GBC’s
Transportation and Mobility Committee on May 18 and have included below our observations and suggestions for
The GBC believes that the draft plan has tremendous potential to build the interconnected, multimodal transit
network in the Greater Baltimore region that will advance efforts to build a stronger, more inclusive regional
economy and support prosperity in our businesses and communities. What the draft plan lacks are detailed
implementation steps with timetables and measurable progress metrics to ensure the plan’s success.
Specifically, the GBC suggests that the draft plan would be strengthened with:
• more specificity and prioritization of strategies and network improvements and identification of the three
to four priority corridors that will advance into the next level of analysis;
• additional clarity regarding the known and anticipated roles of local governments and the private sector
in advancing and implementing the various elements of the plan;
• more attention to current capital needs and growth trajectories that require mitigation; and
• a deeper analysis of funding mechanisms and opportunities.
Additionally, the draft plan references the creation of multiple task forces and committees as next steps in the
planning and implementation process. We respectfully offer that combining some of those entities and more
clearly defining the outcomes that they are intended to achieve is a better approach. Additional detail regarding
these observations is included below.
The GBC recommends that the final plan:
• Include more specificity in the statement of goals and objectives with examples of the clear actions needed
to reach the goals or objectives.
• Quantify more of the objectives with targets that include dates and numeric goals and then prioritize the
objectives relative to time, cost, and feasibility constraints.
• Include numerical goals and dates on identified plan targets, establish interim measures, and include
baseline metrics—either within the report or the accompanying technical appendices.
o For example, some objectives have target goals with dates of 2025, some 2045, and some have no
dates at all. A target with a 2045 goal with no interim measures is destined to fail.
• Disaggregate objectives and targets by mode when possible.
o On page 25, the plan calls to increase system-wide ridership in the region by 10% by 2025. This
metric should be disaggregated with established targets by mode. Additionally, the goal should not
be to increase paratransit use but to increase the accessibility of fixed route services for riders with
disabilities. Lastly, we recognize that this goal may be adjusted to account for the impacts of COVID19 on transit ridership.
Addressing Current Challenges
The draft plan mentions the roughly $2 billion State of Good Repair backlog but contains no measurable goals,
objectives, or strategies to mitigate this financial challenge that will impact the MTA’s ability to provide service at
current levels or implement service enhancements if unaddressed.
The GBC suggests that the final plan include more specific objectives and strategies for addressing State of Good
Repair needs and backlogs simultaneously with advancing network improvements or new projects. For example,
on page 22, the plan outlines the objective to “maintain transit vehicles and facilities in a State of Good Repair,” but
contains no specificity regarding costs, schedules, and how that integrates with the current plan.
The GBC suggests that this section of the final plan:
• Place more priority on comprehensive strategies to connect the transit system to the northeast corridor
and other transit systems in the mid-Atlantic region.
• Provide more specificity regarding the steps towards “pursuing” transit-oriented development (page 26)
and what actions MTA and the Maryland Department of Transportation will take to advance TOD at
identified locations. TOD-related strategies and goals should also explicitly address the role and
involvement of local governments and the private sector.
• Explain the concept of transit hubs more clearly and outline the role that private sector has in developing
and supporting the creation of these hubs.
• Reconsider the creation of two separate task forces to examine ridership on light rail and metro as this
approach is unnecessarily bureaucratic and too narrowly focused.
o We suggest that you form one group that examines challenges and opportunities in increasing
ridership across bus, light rail, metro, and MARC.
o Additionally, we suggest establishing a standing business partner advisory committee to identify
concrete mechanisms for developing partnerships with private companies, developers, nonprofits,
and education/workforce entities to maximize public-private coordination.
This advisory committee would examine the coordination on major new developments,
address issues with existing service, facilitate coordination of shuttle services, and enhance
opportunities for increased public-private partnerships in development and operations.
This group would be an appropriate venue to address many of the recommendations listed
under the “enhance fiscal sustainability” section on page 39 as well as the recommendation
contained in the 5-year plan that suggests convening a group to explore shuttle services
Access to Jobs and Opportunities
The GBC suggests that this section of the final plan:
• Include more near-term targets.
• More explicitly address the anticipated role of local government and the private sector in implementing
strategies around transit supportive development and infrastructure, transit-oriented development, and
land use. The strategies on page 30 include a mix of items that are of state, local, and shared responsibility.
The responsibility of each should be clarified in the final report.
While this section of the draft plan contains numerous strategies to address accessibility for individuals with
disabilities, it lacks adequate attention towards addressing racial and socio-economic inequities and fails to set
targets and provide strategies to mitigate these inequities.
The GBC suggests that this section of the final plan:
• Directly address racial inequity and disparities. Create concrete strategies to mitigate these inequities
using geographically disaggregated demographic data to more clearly explain the current status and to
inform specific strategies that include access to transit (disaggregated by mode) by race AND income level.
Include measurable strategies designed to enhance equitable access.
• Explain and restate the strategy to “ensure the benefits and burdens of transit projects are shared equitably,
considering race, gender, and income disparities” which is unclear in its current wording.
o We recommend including a standalone strategy to address environmental justice and equity in land
use and planning decisions that is distinctly separate from measures to increase access across
• Create a more cohesive strategy with measurable targets for reforming the paratransit system and
mitigating the growth that exceeds peer agencies while ensuring that the service meets ADA requirements
and provides safe, reliable, and efficient service to riders with disabilities. Unsustainable growth of
paratransit ridership will result in inadequate service for paratransit users and also constrain the MTA’s
ability to implement system enhancements across modes if left unaddressed.
o The GBC suggests creating measurable targets and timelines for implementation of travel training
and trip-by-trip eligibility to maximize the safe and convenient use of the current fixed route
system by a broader spectrum of users.
o We also recommend more immediate, measurable, and aggressive strategies to increase the
accessibility of current fixed route services and stations. These strategies should include enhanced
coordination with local governments and private developers to accelerate accessibility.
Planning for the Future
The GBC recommends that this section of the report:
• Include more interim goals for greening the fleet to all zero-emission vehicles.
• Include interim targets for increasing transit ridership, disaggregated by mode. Disaggregated, interim
targets will provide greater flexibility to adjust to the impact of COVID-19 on transit as we enter different
phases of recovery.
• Include more specificity regarding the potential jurisdictional and regional funding opportunities. This
segment of the report is insufficiently broad and lacks detailed recommendations.
• More explicitly address the expectations for local government’s participation in the implementation of the
plan, including integration of elements of the plan into local planning documents. As stated in previous
sections, the anticipated role of local governments in advancing these strategies is unclear and understated
throughout the document.
• Expand, explain, and further analyze the strategy to “explore new cost-efficient and value capture practices,
including public-private partnerships, alternative delivery methods, and Tax Increment Financing (TIF)” to
address opportunities, challenges, and explain the role of local government and private participation in
Transit Network Improvements and Priority Transit Corridors
The connection among strategies, network improvements, and priority corridors is disjointed in the draft plan.
While the three initiatives are described as “mutually supportive and symbiotic,” the expectation for how these
initiatives will advance consecutively, concurrently, and relatively is unclear. We recommend considering the use
of graphics to explain the interconnectivity of the initiatives.
The GBC recommends that these sections of the final plan:
• Include more detail and prioritization of the proposed transit network improvements and more clearly
explain how network improvements will be assessed and selected for advancement. This should also more
clearly define the anticipated role of local government and private sector support and participation in
• Identify the three to four corridors that will be selected to advance into further planning. Provide initial
prioritization of the early opportunity corridors with the caveat that there may be adjustments based on
the next phase corridor analyses to be completed by MTA and the Baltimore Metropolitan Council.
• Clarify how strategies, network improvements, and implementation of priority corridors are anticipated
to advance concurrently and relative to each other.
• Explicitly focus on connections to employment centers as a primary criterion for prioritization.
• The GBC strongly recommends the development of two-year action plans to drive the implementation of
the plan, similar to the process used in the implementation of DDOT’s moveDC 25-year plan. A two-year
action plan requires more immediate metrics and target dates, yields greater accountability, allows for
adjustments based on unanticipated fluctuations or disruptions to revenue and operations, and would also
serve as a bridge to connect the legislatively required 5-year plan updates.
• The GBC recommends that the elements listed in the 5-year implementation plan be refined to include
metrics and dates.
Thank you for the opportunity to share these observations and suggestions. Again, we commend you and your
team and the Commission for the extensive work that has gone into the development of the plan and look forward
to working in collaborative partnership with you to move this plan into action. If you have any questions about the
comments shared above or if the GBC can be supportive to you as you work to finalize the plan and move into
implementation, please do not hesitate to reach out.
Donald C. Fry
President & CEO
cc: Mr. Kevin Quinn, Administrator, Maryland Transit Administration
Mr. Greg Slater, Secretary, Maryland Department of Transportation
Mr. Jon Laria, GBC Board Member and Chair of the GBC Transportation & Mobility Committee
Mr. Mike Kelly, Executive Director, Baltimore Metropolitan Council
Members of the Central Maryland Regional Transit Plan Commission