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Comment by Peter Samuel 2019-01-11 On transportation the draft Livable Frederick Master Plan says it aims to improve “the ability to easily get where you’re going…” (page 1.) Nice sentiment. But the Plan won’t do that. It proposes priority for going “multimodal” — jargon for transit by which it means buses and trains rather than highways. Also biking and walking. 254 pages of the Plan and they say nothing — nothing!!! — about our major highways, nothing on improvements to US15 or I-270 — the most urgent big transportation problems we have in Frederick County. They say nothing about the east-side highway shown in previous strategic plans. As it stands the Plan would ensure that the ability to “easily get where you’re going” will be seriously degraded, not improved. Without highway upgrades Frederick County will get LESS livable. The Plan is obsessed to the point of fantasy with the potential of ‘multi-modal’ solutions. This at a time when 24-seater County TransIT electric buses costing $500,000 apiece rattle around Frederick with most of their seats empty. And the Frederick MARC trains carry each day the equivalent of hardly five minutes of traffic on I-270. The Plan’s ‘Vision Statement for 2040’ (p29) describes its ideal system 21 years hence: “Our transportation system is MULTI-MODAL (caps in Plan draft) and diverse. It moves people, and goods both locally and regionally, in a timely and safe manner, and provides the ability to enjoy and function in life WITHOUT NEEDING A CAR.” (caps in the Plan draft) Mobility without cars is a fashionable trope with some validity in Manhattan or Brooklyn NY, in downtown San Francisco or even central Washington DC, places with jobs concentrated downtown, with high job and population density, and lots of soaring high-rise buildings and scarce and expensive car-parking. In those dense central areas of a handful of large metro areas transit competes with cars. There, certainly, mobility without cars is necessary, and possible. But in Frederick? The “without cars” trope is simply absurd here. We have no serious base of transit use from which to build. As the draft Plan concedes: "Today, the way we get from one place in our community to another is almost entirely by means of the automobile. Other ways of getting around such as walking, biking, or taking a type of public transit like buses and trains, are a distant second..." (p39) Our population is far too small, and too dispersed and low-density to support serious transit of the kind which would allow the draft Plan’s mobility-without-cars. That can’t change in 20 years. It doesn’t need to. And it shouldn’t. Cars and other small road running vehicles are the key to future mobility for all. The draft Plan fails to recognize that self-driving or autonomous vehicles (AVs) are likely to be in widespread use by 2030, and could be dominant by 2040. They will mostly be electric -- battery powered. Many AVs are envisaged to operate taxxi- or Uber/Lyft-like in hail-by-app format. People unwilling or unable to afford to buy a car will, in 2040 be able to hail one by iPhone app. Call it personalized transit, if you will, but like Uber it promises to be quick-to-arrive at your door and capable of driving you directly to your destination at low cost. True prompt, door-to-door or direct service! Without a driver that needs to be paid such mobility-services by car-sized vehicles – ‘2040-cars’ – will be extraordinarily low cost. The mobility disadvantaged will best be served by cars (AVs) not transit No longer will a physical handicap, old age or youth, poor eyesight, or even disqualification for DUI, deny people car mobility by 2040. AVs will be specially beneficial to low-income people. Automated electric cars should be cheap to buy with mass production by the 2030s if not before. It is difficult to foresee any viable role for transit being ‘mass’ (buses, trains etc) when your 2040-taxi no longer has to support the expense of a human driver. Regardless of propulsion, regardless of whether it runs on road or pavement, regardless of driver automation the transit mode will be handicapped by: — its inability to deliver door-to-door service — the awkwardness of carrying shopping, pets, bicycles, work tools and paraphernalia aboard — the inevitability of less direct travel, compromise routing causing the transit trip to be much longer — delayed arrival versus a car because of the stops along the way — a fixed route and investment in stations/stops — the need for origin-to-transit-stop, transit-stop to destination modes and transfers between transit lines on many transit trips Transit is best suited to servicing suburb-to-central-city travel of hub-&-spoke form whereas most travel in modern cities is is suburb-to-suburb. Downtown Frederick is a weak hub, and most of our trips originate and end outside the downtown. There is no serious ‘hub’ for the Plan’s spokes. Egregious cherry picking of data to mislead The general tone of the Plan draft is set by the emphasis on a supposed decline in car driving. A heading on page 76 states: “Nationally, and locally we are driving a little less…” A brief commentary claims young people are avoiding car ownership and looking to non-car modes. Most egregiously the page gives the misleading impression that vehicle-miles-travelled in Frederick County is on the decline. It does this by highlighting a trend 2005 to 2015, years covered by the great recession and slow economic growth. VMT/person declined 7 percent in those ten years, apparently supporting the less-driving theme. But, dear reader, go to the very source cited, the State Highway Administration’s estimates of VMT by counties. Their most recent data is not from 2015. There are 2016 and 2017 estimates also. Why do the authors of this Plan omit 2016 and 2017 data? Because recent years confound their decline-of-car-driving theme. ‘Don’t let the facts get in the way of a good story’ must be their motto. The omitted 2016 and 2017 data show a sharp reversal of the decline 2005-2015 cited and highlighted in the Plan draft. In just two years 2015 to 2017 driving has surged. In Frederick County the State Highway Administration estimate of vehicle-miles-travelled is 3048 million 2015 to 3,260 million 2017 -- up 7 percent. In two years the reduction cited by the Plan draft for 2005 to 2015 has been undone! Statewide the picture is similar. In the same two years total Maryland driving has risen from 57.32 trillion VMT to 59.89 trillion VMT in 2017, up 4.5 percent. Population has risen to 6,052k in 2017 from 6,001k in 2015, or 1 percent. VMT per capita in Maryland has risen from 9,552 in 2015 to 9,896 miles in 2017. State VMT/person has increased by 3.6 percent. At the national level 2013 through 2018 has seen average annual growth in driving of 1.75 percent each year, over twice the 0.7% annual US population increase. Percapita VMT has been growing nationally for several years now. The same is true of car ownership notes transportation expert Bruce Schaller: “From mid-2000 to 2012, transit ridership increased while car ownership grew slowly, if at all. But now car ownership is expanding faster than population.” ‘Cherry picking’ or ‘snipping unwanted new buds’ While the Plan draft engages in egregious professional malpractice in cherrypicking data (in 'snipping unwanted buds' may be the better metaphor) in suggesting an inexorable per-capita decline in driving through 2040 no one can say for sure whether the revival in driving of the past several years will continue. But located as we are with eminently buildable land on the fringe of the steadily growing 9.8 million population Washington-Baltimore metro area it seems likely we'll have more driving in Frederick County -- contrary to the draft Plan suggestion of less driving. And anything less than a continuing decline in percapita driving means that a serious 2040 Plan will focus some attention on the future of the County’s major roads. This Plan draft has almost nothing about improving our highways! In line with the notion that car driving is in inexorable decline it deals with roads with references to ‘road diets’ meaning closing or reducing lanes. Amazingly the draft Plan says nothing about important arteries such as I-270 and US-15 beyond references to proposed new interchanges located for the convenience of transit buses – further emphasizing the authors’ obsessive transit fixation. Forget serving the cars, the Plan draft says in effect, but their roads could be handy as right-of-way for transit. Transit ridership in decline – local TransIT loses one third of bus riders since 2014 The Plan draft fails to note that bus transit ridership in Frederick is in steep decline. Bus trips on County TransIT buses in FY2018 were 520,498 compared to 763,207 as recently as FY2014 a drop of 31.8 percent. Almost a third of bus ridership has disappeared in the past four years! This is probably good news for the former riders – most of whom have probably found better ways than the bus to get around. Maybe they are working from home, maybe walking, or biking. Or maybe they got a car. Or use Uber. If it is good news from former transit riders it is bad news for transit enthusiasts like the authors of the Plan. The bus trip data confirms the view that as people get better jobs and higher incomes they lose the taste for waiting at the bus stop and riding the bus. Frederick’s TransIT has quietly responded to the loss of bus ridership by providing more van service. TransIT vans are doing about 88,000 passenger-trips/year versus 76,000 four years ago. But the 12,000 increase in van passenger trips pales into insignificance beside the bus loss of 240,000 of bus passengers. Second, vans are twice as expensive to operate as buses at $2.85/passenger-mile versus $1.41. The average TransIT van passenger trip costs $27.64 versus the average bus trip’s $8.20. Fares cover less than 10 percent of TransIT’s operating costs (and none of its capital costs) so the extent of service depends on an annual budget battle within County government and on state and federal grants. Politics, not customer demand, inevitably drives the level of transit service provided. Third, TransIT’s ‘vans’ are directly competing with self-financing services like old-fashioned taxis and new-fangled Urber/Lyft app-hail services. Is that fair or desirable? TransIT also cooperates with commercial taxi service with a Taxi Access Program ($60 worth of taxi rides for $10) for its TransIT-Plus clients (age 60+, or disability required, trip reservation needed 2 days ahead.) Ridership of MARC is in decline too, though not the collapse suffered by TransIT’s bus ridership. MARC’s Brunswick line averaged 8,000 passengers weekdays in 2012/2013, and was down to 6,660 in 2017, a 16.7% decline from the high of six years ago. By anecdotal accounts the decline continued in 2018. TransIT and MARC fit a general national pattern of transit patronage decline. Transit ridership was down in 31 of 35 major metro areas last year, according to one analysis of the data. In the last ten years national transit ridership is down 7 percent, excluding the unique New York City area. The Washington DC metro area has seen a near 5 percent drop in transit ridership since 2008. Given population growth, percapita declines of course are somewhat larger. “Transit crisis” What’s going on? A Congressional Research Service (CRS) paper "Trends in Public Transportation Ridership" reports on the transit numbers around the country: "This downward trend, despite significant investments in light rail, streetcar, and bus rapid transit lines in many communities, has led to warnings that transit service in the United States is in crisis." Contrary to the Frederick Plan draft the share of households without a car is declining, and is now below 9 percent. And the number of cars per household which declined 2006 to 2014 has since been rising again. A decade ago in their early years internet-hail services like Uber and Lyft were championed on the basis that they could supplement transit by providing 'first mlle/last mile' services or origins-to-transit and transit-to-destination trips. But hail services can also compete with transit and beat it by providing the whole trip door to door. Now it is apparent that the hail services are a net loss for transit, their competition outweighing their support for it. Work-at-home has also been on the rise and is likely a factor in transit decline. Bicycle use is growing, both owned bikes and bike rental. The CRS report: "There is some evidence that in larger metropolitan areas major employers are seeking out locations that are well served by transit, but the general trend remains job dispersion across suburbs with low employment density. The combination of relatively low- density residential growth and low-density employment growth may limit the extent to which population growth brings higher transit ridership." Some go as far to say that mass transit's decline will go so far as to make it largely "irrelevant." Thematic Plan Diagram The Thematic Plan Diagram (page 42) emphasizes 'transit spokes' with Frederick as the hub. It shows solid-line spokes out to (1) Point of Rocks, (2) Jefferson & Brunswick, (3) Thurmont and Gettysburg, (4) Walkersville & Woodsboro, and broken-line spokes from Frederick out to to (5) Urbana, (6) Middletown and Myersville, (7) Mount Pleasant and Libertytown (8) New Market & Mount Airy. Two more transit oriented corridors are proposed in the Plan draft, spokes to the Washington DC hub (9) the MARC Rail Corridor, Frederick to Point of Rocks (page 45) and (10) The Interstate I-270 Corridor from MD26 south to the Montgomery Co line at Hyattstown. The I-270 corridor makes the most sense of the ten. But nowhere can transit-dedicated lanes be justified – even 5 or 6 transit buses in an I-270 lane would occupy perhaps 0.5% of the hourly capacity of a single highway lane leaving a dedicated lane 99.5% empty. But Governor Hogan plans to get private financing for toll managed lanes on I-270, and they would provide the perfect infrastructure for transit buses to Shady Grove (for a Metrorail connection to the mass of jobs and stuff-to-do in downtown DC) and to Rockville (for Metrorail and MARC.) The Frederick-Point-of-Rocks MARC corridor (9) serves essentially the same market as transit buses on I-270, but serves it poorly – because the dogleg shape of the rail route which makes it 12 miles longer than I-270 plus the limitations of trying to run passenger service on a single track freight rail line. There is another silly redundancy, Frederick spoke #(5) on MD355 Frederick to Urbana, which of course parallels 270 hardly a mile away. Other problems are: 1. The Frederick hub-&-spoke transit format could only provide good service for job and other trip destinations located at the hub in downtown Frederick City but these only comprise at most a few percent of trips in the County. The hub-&-spokes do nothing for more than 95% of trips. Of course our ‘visionary’ writers envisage changing all this by centralizing jobs around the hub and nodes which they in their wisdom deem desirable. They underestimate the costs and difficulty of actually doing this centralization, and the resistance. Economists repeatedly find that economic strength comes from the efficiency of very large metro-scale labor markets which are best supported by an interlocking network catering to all directions of trips, not just hubs-&-spoke trips. 2. Three of the Plan’s transit spokes are located for much of their distance on expressways: Point of Rocks (US15 south) Jefferson & Brunswick (MD 340) and Thurmont & Gettysburg (US15 north) while five are located on much slower surface roads: Middletown (Alt 40), Mt Pleasant & Libertytown (MD26), New Market & My Airy (MD144) and Urbana (MD355). The three expressway transit spokes could provide rapid service so long as there are managed express lanes for them to travel in, and few stops. The other five being off expressways would have many grade crossings and therefore be much slower. 3. Given the concentration on just eight spoke routes and a handful of stops the authors of the draft Plan apparently envisage their hub-&-spoke system as some kind of express bus service. They show transit oriented development 'nodes' and 'county growth areas' in small circles around each of the stops on the spokes. 4. Fullsized buses are increasingly unable to provide service competitive with cars, especially since door-to-door and direct service is being provided on demand by mobile phone hail services such as Uber. Bus service on average nationwide costs $1.17 per passenger-mile (Frederck’s TransIT bus ran $1.41/passenger-mile in 2017) versus a car 23c per passenger-mile. Estimates by O'Toole based on 2016 spending by transit agencies of $66.3b to generate 56.5b passenger-miles gives $1.17, and $1.1 trillion spending on cars which ran 4.8 trillion passenger-miles, gives 23c. Only about a quarter of the $1.17 cost of transit America-wide or 28c/passenger-mile is paid in fares, three-quarters of the cost of transit or 89c/passenger-mile being provided by government grants nationwide. (Frederick’s TransIT runs 16c/mile in fares which amounts to government support of $1.27/mile given the operating expenses of $1.41.) Car highway subsidies by way of government support outside gas taxes and motorist fees are around a penny/mile. Hailed cars will get drastically more economical as drivers are replaced by the autonomous vehicle systems. 5. The Plan draft provides no evidence that passenger demand will develop to justify these eight transit ‘spokes’ on which the Plan places so much importance. Part of the Plan’s proposed Spoke #3 Frederick to Thurmont and Emmitsburg already has a morning and evening TransIT shuttle which on US15 can make similar speed to bus rapid transit. That route averages 9 riders a day! An experimental midday service was recently dscontinued by TransIT because most days during a year-long trial it attracted two passengers or fewer. Low transit ridership sends per-passenger-costs sky high. The present bus system in Frederick runs at an operating cost of $7.16/bus-mile. At that rate the 23 mile bus trip to Emmitsburg would cost $165 with two occupants paying $1.50 each in fares, taxpayers left up for $81 for each passenger-trip. This is before any depreciation charge on the small bus deployed for the Thurmont/Emmitsburg run. Innumeracy allows empty fantasizing and posturing Alain Bertaud a longtime urban planner for the World Bank, now scholar at the NYU Marron Institute of Urban Management has written about the lack of measurement in most city plans in a passage that is apt here: “Urban planners use expressions that are often more qualitative than quantitative. They like to use adjectives like ‘sustainable,’ ‘livable,’ ‘compact,’ ‘resilient,’ and ‘equitable’ (also ‘multimodal’: P Sam) to characterize their planning objectives. However, planners seldom feel the need to link these qualitative objectives to measurable indicators. It is therefore impossible to know if the planning strategies used are indeed ‘sustainable’ or ‘livable.’ In the absence of quantitative indicators, one might conclude that these terms are only labels that provide a kind of moral high ground to (impose) whatever urban plan is proposed.” The Frederick Plan draft goes heavy on transit and the need for ‘multimodal’ solutions without there being any demand studies to support the need for any of the hubs and spokes proposed. The County’s TransIT department has never championed the idea, beyond the trial service to Thurmont and Emmitsburg. In the absence of endorsement by the agency that would have a major role in implementing it, why should anyone take the idea – central to the 2040 Plan -- seriously. The draft Plan repeatedly calls for a multimodal transport system. Well we already have a system with a dense bus network covering much of the City of Frederick plus commuter rail to northern Virginia and Washington DC. And the City has been developing bikeways, trails etc. And we have a lot of sidewalks for walkers. Just what split between the modes of car-driving, transit, walking, biking does the Plan envisage as truly ‘multimodal’? By what percentages, please, as compared to now would success be judged for 2040? They don’t tell us. The Plan draft’s first policy statement is under the heading Multi-modal Choices and Active Living: A New Development Model (p12): “Developing a new multi-modal transportation network for Frederick County will improve the overall effectiveness of the system and create conditions which promote active living and improve the health of citizens. The reliance on cars as the only transportation option for people to get from point A to point B has created transportation challenges and led to less active lifestyles. We know that we cannot build our way out of congestion, but we can make our system of transportation more efficient by creating a more robust network of roads, transit services, bicycle lanes and pedestrian options.” This is trite, and misleading. A “new multimodal network” will only be an improvement over the existing network -- multimodal already -- if it realistically accepts the limitations of non-car modes. If it goes too far in providing for non-car modes, if it cannot generate patronage sufficient to justify the investments, it will simply produce waste and neglect of the needs of the dominant car/road mode. Alain Bertaud writes: “Urban strategies that are in obvious conflict with economic reality have little chance of being implemented, and if implemented, are extremely costly to a city’s economy. Poorly conceived urban strategies are not just innocent utopias. They misdirect scarce urban investments toward locations where they are the least needed and, in doing so, greatly reduce the welfare of urban households. These failed strategies make housing less affordable and increase the time spent commuting.” Reliance on the car mode does create challenges to be sure, but there are good reasons why the people of Frederick County, like people outside most dense multi-million population metropolitan centers, make most trips by car. The Plan's trendy trope “We know we cannot build our way out of congestion” needs discussion. To the extent this slogan has truth it should be understood to mean that construction alone cannot eliminate congestion. Construction requires informed design and management including sensible pricing of roads. But to cope with present and future congestion we have to build. Take US15 through Frederick: On this vital artery demand for roadspace grossly exceeds supply, and building additional lanes is the only way to relieve congestion. Expansion of US15 will probably be a one-time affair. If growth continues we may need to to build a north-south expressway on the eastside of the City (Monocacy Battlefield to Biggs Ford Rd) to supplement and relieve US15, as well as to enhance the east side’s connections to the regional network of highways. Construction of an eastside expressway is probably not warranted in the foreseeable future, but the draft Plan should call for County and City action to maintain a right-of-way for this future highway. (It is not even clear that the authors are aware of this road being in the present City strategic plan!) New technologies not seriously addressed Waymo, the Google spinoff currently has a fleet of self-driving cars in the Phoenix AZ area that can be hailed via iPhone app Uber-style by persons unable or unwilling to drive themselves. A whole host of other companies including Uber itself and Intel’s subsidiary Mobileye and most of the big car companies are investing heavily in driverless too. There seems agreement that the first use of such vehicles will be fleet hail services likely to be heavily used by non-car owners. Such services seem likely to spread quite widely in the next few years and it seems realistic to expect they will be on offer here by 2021 or 2022. The draft Plan says nothing about such autonomous vehicles or how they fit into a 2040 scene. Micro-transport – scooters, skates etc The sidewalks of Arlington VA, Washington DC and many other big cites now have large numbers for-hire electric scooters (e-scooters) on offer. A study supported by Bird found that trips of 0.5 to 2 miles represent a ‘sweet spot’ for e-scooters where they do better than transit, walking or biking. They could be here within a year or two? How do our visionary 2040 planners propose they be handled? In bike lanes? On roads? On walking trails? On sidewalks? Battery electric propulsion is also being applied to bikes, to skate boards, and to self-balancing battery electric successors to the Segway. Many such mini- or micro-mobility devices will probably be a flash in the pan like the Segway itself. But it seems realistic to believe that out of the cauldron of innovation some viable new mini-modes will emerge. Why not a serious discussion of how these might be provided for and managed. All these low impact, low cost modes – eScooters can be found on Amazon for should provide some competition with cars and with transit. That’s desirable but city planners will need to show creativity and boldness in working out how to manage the new modes to maximize their value while minimizing conflicts between modes – cars hitting scooters, for example. Sadly the draft Plan provides no guidance here, not even recognition of the issue. Tail shouldn't wag the dog The plan draft contains a fundamental error which we see in this passage: “The ultimate strategy of the Thematic Plan is to...achieve a pattern of growth centered on multi-modal accessibility in Frederick County, taking advantage of the existing transportation systems in place, the future systems and technologies for moving people and products, and the innovative land use patterns that support transportation choices." (page 9) First, the hub & spokes are not yet ‘in place.’ More fundamentally, there’s a tail wagging the dog problem here. The transportation system should support whatever pattern of growth provides the highest quality of life, not dictate that pattern of development. Like the power grid, water & sewer, schools — and for that matter private sector services — the transportation system should be subordinate to the needs of people and should serve the variety of living environments they choose to create. There is no good reason to let the people’s lifestyle choices as reflected in the pattern of development be determined by a transportation network. The transport network needs to be adapted to the development which results from people's choices as home-buyers, as renters, as community and government agencies and as businesses. Transportation is a means to an end, the end being a diverse, good quality way of life. A means, such as transportation, may at times constrain but should never dictate an end. The passage quoted represents a major methodological error and it should be reconsidered. DESERVING OF PRAISE: Pricing for efficient management Under 'What is Multi-modal accessibility' (page 39) there is the statement: "Society could benefit from more efficient management of road space that favors higher 'value' trips and more efficient travel modes in order to reduce traffic congestion, parking costs, accidents, and pollution emissions." This in a nutshell is the case for levying direct charges for road use -- in effect modern non-stop tolls. At variable rates tolls can manage efficient use of new lanes. Consider how traffic flow breaks down from overload. It all starts in dense traffic when a driver slows to maintain their distance from the vehicle ahead, and others behind do the same. For a while there is just a slowing of the fastest vehicles as they are blocked from overtaking and others are comfortable driving rather slower but closer. At this point pretty even flow and throughput (vehicles/lane/hour) are maintained. However as every driver of I-270 knows, this can easily deteriorate into stop-&-go during which throughput (vehicles/lane/hour) collapses and the inefficient condition is extended backwards for miles. “Backups." Federal and state policies now favor toll managed lanes (called HOT lanes or toll express lanes) in order to combat stop-&-go, and many states have implemented them. These tolls are varied by computer algorithms according to the density of traffic and the estimated prospect of stop-&-go. Displayed ahead of entry ramps the toll rates work to keep out drivers who see the toll displayed as more than a free flow ride is worth. That reduces traffic density, allowing free-flow conditions to be provided to those for whom it is most valuable. A freeflow expressway lane of this kind proposed by the Hogan administration for I-270 (as well as the I-495 and I-695 Beltways) will be a boon to regular drivers when they have an important appointment to keep, and also to transit buses and future autonomous vehicle services. Such road pricing also makes a lot of sense as a revenue source. As gasoline and diesel vehicles are replaced by electric the per-gallon gas tax revenues will decline. Road-use charges levied on all vehicles promise to be the best way to ensure a revenue stream for supporting investment in quality road networks as well as providing a way of managing them to give priority to high value trips. Need for better connectivity The draft Plan is spot on in advocating greater connectivity in our street networks. Too often our street layout forces people to travel further than should have to go because of lack of direct connections. But why not specify some examples of ways of improving connectivity rather than simply stating the principle? My suggestions: -- study whether some of our downtown one-way streets, perhaps with parking on only one curb, should be converted to 2-way traffic to allow more direct travel -- connections between South Court St and Stadium Drive/New Design Road skirting Mt Olivet Cemetery to reduce blockages on S Market. -- a Westbrook to Waterford connection under US15 somewhere between Rosemont Av and West Patrick -- a Grove Rd to Crestwood Blvd connection under I-270 -- a New Technology Way connection under I-270 to Shockley Drive, MD85 and Crestwood Blvd -- a link between Grove Rd at MD355 and Reichs Ford Rd south of the quarry -- connecting the Jefferson Technology Parkway at the US15/US340 interchange with Ballenger Creek Pike and Corporate Drive -- connecting Linden Av to Himes Av -- a connection between Thomas Johnson Drive and Schifferstadt Blvd at N Market going over US15 -- another connection between Thomas Johnson Drive and Worman’s Mill Rd over US15 -- completion of the Monocacy Blvd/Christopers Crossing circular arterial in the northwest of the City Outside Frederick City: -- Eastern Highway just outside the City limits east of the general line of the Monocacy River and labelled the North-South Road on City strategic plans, this road would greatly improve connections on the eastside of the City of Frederick as well as giving Montgomery County to Central Pennsylvania through traffic an alternate route by the Frederick area. Branching off I-270 just south the Monocacy Battlefield it could have interchanges with Reich’s Ford Rd, I-70, Gas House Pike, M26, then northwest crossing the Monocacy River near Biggs Ford Rd, and joining US15 in that vicinity -- Middletown desperately needs a connection to I-70 west of the Catoctin mountain range, somewhere around Hollow Road, to end its dependence on Alt 40 with its dangerously steep grades via Braddock Heights -- Libertytown and New Market need a modernized MD75 linking them more smoothly and safely to Hyattstown and I-270 Greater connectivity will often be difficult to achieve because of local (NIMBY) opposition. For example present City plans provide for an extension of 7th St eastward of East St to Lindley Rd in the new East Church neighborhood. That would seem to be a big advance for Eastchurch area residents giving them a direct connection to the north end of downtown and US15. But many of these residents recently organized in an attempt to get the City to abandon the planned 7th St-Lindley Rd connection. They want to preserve their present isolation from 7th St and the north end of downtown despite the fact it denies them direct access to spinal US15, adds many minutes to journeys to the emergency room of FM Hospital, and threatens to worsen traffic on Church St and East St downtown. In another manifestation of a desire to be isolated from through traffic, residents of the area south of the Hospital successfully opposed Hospital plans for access to their new parking building from the south, via Park Avenue and Rosemont Av/Elm St. Large padlocked chainlink gates on the south end of the hospital parking building are testimony to popular opposition to connectivity. Maybe there’s a compromise with traffic calming measures like DC’s speed bumps? The problem is bigger than the draft Plan’s simple call for designing street networks for connectivity. People need to be persuaded it’s necessary and good. Graphics The graphical work done for draft Plan document is often beautiful, always excellent. It’s the words and the misconceptions behind them that invite strong criticism. CONCLUSION The 2040 Plan as written in this draft is based almost entirely on old and minor transport modes like buses and passenger rail, modes that have ever-dwindling customer support in ridership and fare revenue and which need ever-growing public subsidies to maintain even their present minor role. Basing any Plan on minor, dying, and mendicant transport modes is, in a word, absurd. NOTE: I have a version available in MS Word format with footnotes for anyone who asks via email@example.com