Charlotte LYNX light rail. Photo by James Willamor on Flickr.

The Town of Chevy Chase’s official comments (large PDF) on the Purple Line DEIS

take up about 50 pages plus 90 pages of attachments. Citing many sources and statutes, it appears written by lawyers. Presumably that’s the work of their pro bono attorneys from nationally prominent law firm Sidley Austin, whose policy of helping needy organizations seems to extend to DC’s richest towns. The comments basically attack (or should we say, declare war on) Maryland MTA’s analysis.

The entire document tries to poke holes in the MTA’s data, methodology, and statistics. Given the legalistic tone of the document, I’m concerned that the Town and Sidley Austin are trying to build a case for challenging the DEIS in court. They may argue that the MTA broke the law by intentionally rigging the study against the Town’s preferred alternative, Low Investment BRT.

The Action Committee for Transit has a

non-technical analysis of Town’s preferred Jones Bridge Road alternative. Not only would such a route have to fight through heavy automobile traffic, it would run right in front of North Chevy Chase Elementary School. A train

bus would pass the school every 30 seconds to two minutes, at 40 miles per hour. Meanwhile, the Town of Chevy Chase recently voted to lower the speed limit in front of Chevy Chase Elementary School to 15 miles per hour. Won’t someone please think of the children?

Meanwhile, that alternative would also send buses on the Georgetown Branch (future Capital Crescent Trail and Purple Line) east of Jones Mill Road. Apparently they want to “save” the trail only along the border of the Town of Chevy Chase and the Columbia Country Club. Meanwhile, our region will get more sprawl, automobile emissions, and will lose the opportunity to encourage more energy-saving transit-oriented development. All so a handful of people can continue to use public land as their little private park.

The Town included 90 pages of attachments to reinforce the argument that the MTA intentionally rigged the study. However, some of them support the opposite conclusion. On page 52 of the comments, there is a letter from the MTA to the Town responding to a request for more technical information about the light rail alternatives. Maybe a Sidley Austin lawyer can explain how this letter “proves” that the state rigged the study.

On page 59, there is a letter from the Washington Area Bicyclist Association to Montgomery Park and Planning outlining specific technical concerns for the future Capital Crescent Trail. The letter talks about speed limits on the future trail and ways for cyclists and pedestrians to coexist. WABA has endorsed the light rail Purple Line. They know that building the train is the only way to complete the Capital Crescent Trail into Silver Spring.

Page 69 is a letter by Town of Chevy Chase resident Mr. David Saltzman, Ph.D. in physics. I have a B.S. in physics, giving me a particular personal interest in this letter. Saltzman writes, “As a physicist I have to respect the hard data,” then manipulates the data to support his conclusion. He insists that BRT is always “cleaner” or “greener” than light rail. But the initial boundary conditions of the analysis use numbers and assumptions that essentially guarantee that the result will support the author’s thesis. It’s circular reasoning. Saltzman’s analysis ignores the fact that you can hold more people on one rail car than a bus. Nor does it account for the fact that you can put multiple rail cars together to form a train. His analysis does not consider that transit-oriented neighborhoods use less energy, that water lines are much more efficient in a walkable place, and so on.

According to the Action Committee for Transit, “pro-bus think tank” World Research Institute analyzed light rail versus buses. Light rail beat the bus alternatives on five of the six pollutants they analyzed. And:

WRI found that light rail’s performance on CO2 (although still worse than bus) was better than stated in the DEIS — the added emissions would be only half as much. Furthermore, the DEIS and WRI analyses only include direct changes in energy emissions from transportation — they omit the indirect effects of mass transit in changing land use. A recent government-funded study carried out by the American Public Transportation Association finds that the indirect effects of transit on CO2 emissions are four times larger than the direct effects.

Did any of you take your ball and go home when you were losing a pick-up basketball game as a kid? Did you then turn around and accuse everyone else of cheating? I bet the other kids were really glad that you couldn’t secure pro bono legal counsel to block the basketball game. The Town of Chevy Chase, however, is a different story.