Giving up on the CCT too easily

(A version of this is also posted on Greater greater Washington)

The Purple Line Final Environmental Impact Statement (FEIS) is out.

The Maryland Transit Administration released the Purple Line FEIS on Sept. 6. Comments will be collected and provided to the FTA, which will then issue a Record of Decision on whether to move the project toward further design development and the right-of-way acquisition process. The 10 Chapter FEIS and information on how to comment is on the Purple Line website: FEIS Document.

Profile of Purple Line and CCT, by MTA as shown in the FEIS
(Source: FEIS Document)

Most of the material in the FEIS follows closely to the issues and concerns we have followed over the years of public meetings, hearings and open houses. But the FEIS raises a major issue about the completion of the CCT into Silver Spring that has not drawn much attention before.

The FEIS has finishing the CCT contingent on CSXT cooperation.

The FEIS describes the plan to complete the CCT into Silver Spring on the preferred trail alignment along the east side of the CSXT corridor.

Planned route of the extended CCT with the
Purple Line “Preferred Alternative”

(Source: FEIS Document)

The preferred alignment will require acquiring CSXT r.o.w. for the trail at several locations. CSXT has a general policy to not allow its r.o.w. to be used for trails, but MTA sent CSXT a letter last November requesting that they make an exception for this project. It is hoped that The State of Maryland can succeed in getting an exception for a Purple Line joint transit/trail project, where a local government seeking an exception for a trail alone would not. But CSXT has still not granted the exception to date.

MTA addresses the CSXT trail r.o.w. issue in the FEIS at Chapter 2 – Alternatives Considered, p. 2-24 (emphasis mine):

“…At the junction with the CSXT Metropolitan Subdivision, the County’s current plan calls for the permanent Capital Crescent Trail to continue on the north side of the CSXT corridor to the SSTC. The Preferred Alternative as shown in the FEIS includes completing the Capital Crescent Trail in CSXT right-of-way in accordance with the County’s plan. The completion of the trail along the CSXT corridor, however, is contingent on agreement between Montgomery County and CSXT on the use of their property on the north side of the CSXT tracks for the trail. If agreement is not reached by the time the Purple Line construction occurs, MTA would construct the trail from Bethesda to Talbot Avenue. From Talbot Avenue to Silver Spring an interim signed bike route on local streets would be used...”

As the FEIS is written, the MTA and State of Maryland appear ready to give up on working with Montgomery County to complete the CCT into downtown Silver Spring if it cannot get CSXT r.o.w. for the trail. This could be devastating to the trail and trail network. There would be no off-road trail connection to downtown Silver Spring, no continuous off-road trail between Silver Spring and Bethesda, no complete off-road MetBranch/CCT “bicycle beltway”. The off-road CCT extension that has been promised in every Georgetown Branch Trolley and Purple Line Light-Rail concept study and planning document for more than two decades would be no more than a broken promise.

The FEIS overlooks the possibility of a good off-road CCT on a “Plan B” alignment.

The FEIS presents a false choice: either get CSXT cooperation for the preferred trail alignment entirely in the corridor, or give up on building any off-road trail and dump the CCT onto local streets at Talbot Avenue. But it is possible to complete an all off-road CCT into downtown Silver Spring without CSXT cooperation. A “Plan B” trail would be as safe and nearly as direct as the trail would be on the preferred alignment, and could be less expensive to build.

The key to understanding “Plan B” is to know that the majority of the preferred trail alignment along the CSXT corridor is already within publicly owned r.o.w., or immediately adjacent to publicly owned r.o.w. This can be seen in the aerial map of the corridor that MTA has shown at its most recent open houses, and is online at CSX Corridor to Silver Spring Transit Center (a large pdf). The aerial map shows that at the north end of this CSXT corridor it is possible to bring the CCT down 4th Avenue and behind the Woodside Mews townhouses to Lyttonsville Road, entirely outside of CSXT r.o.w., if the trail alignment were shifted just a few feet east into the 4th Avenue r.o.w. from the CSXT r.o.w.

To the south of the corridor, the planned CCT alignment is already within the publicly owned 3rd Avenue r.o.w. continuous from 16th Street to Fenwick Place. There is other private and public r.o.w. that can be used for the trail from Fenwick Lane to the Metro Plaza Building at Colesville Road. The trail does appear to need to be in a small amount of CSXT r.o.w. at Metro Plaza, but the Purple Line will be crossing over the CSXT track to be directly above the CCT and the trail is planned to be supported on structure shared with the Purple Line at this location so it is unlikely CSXT would invoke its “no r.o.w. for a trail alone” policy here.

A “Plan B” off-road trail route can bypass the CSXT r.o.w. by using Lyttonsville Road and 16th Street.

A “Plan B” off-road CCT can bypass CSXT r.o.w.

A trail route along Lyttonsville Road and 16th Street would be only a few hundred feet longer than the preferred route in the CSXT r.o.w. It can be more inviting – more visible and accessible over most of its length. In contrast the preferred CCT route in the CSXT r.o.w. would be relatively isolated behind the Park Sutten building, and built between a high retaining wall and a CSXT crash wall. The cost to build the bypass route should be lower than the cost of the preferred trail route, because less retaining wall would be needed and the CSXT crash wall would be eliminated.

Looking down Lyttonsville Road from the Woodside Mews Townhomes toward 16th Street.

Lyttonsville Road is extra-wide, and can easily have a “road diet” width reduction to free the space needed for an off-road CCT while still leaving room for traffic lanes and on-street parking. The trail can go on the west-side shoulder of 16th Street to the CSXT corridor, as shown in the sketch above, then go under the 16th Street Bridge in the same manner as the preferred trail alignment. This would give us the much desired grade-separated crossing under 16th Street, but will require “taking” approx. 12′ of r.o.w. from the Park Sutton Condominiums to supplement the existing r.o.w. on the west side 16th Street shoulder. It might also require getting just a few feet of r.o.w. from CSXT on the west shoulder of the 16th Street Bridge, although the drawings are not clear on this. The 16th Street Bridge must be rebuilt for the Purple Line, so the state must engage CSXT in r.o.w. and construction issues at this location regardless of the trail.

If CSXT or Park Sutton r.o.w. difficulties were to block this trail route on the west side of 16th Street, then we can still make a bypass work. Another option is to cross 16th Street at a new light at Lyttonsville Road, then go down the east side of 16th Street to the CSXT. This would stay well clear of any CSXT r.o.w. at the 16th Street Bridge, and would require little or no additional r.o.w. along 16th Street. An at-grade trail crossing of 16th Street would be much safer at Lyttonsville Road than the existing on-road trail crossing at Second Avenue, because this crossing would be shorter, would have very little turning traffic, and could use the wide median for a “safety refuge”.

“Plan B” has already won community support.

I would love to take credit for discovering this CSXT bypass route, but it is so obvious that anyone can see it. And besides, it is a key part of the off-road “interim” trail planned years ago and described in the M-NCPPC report “Facility Plan for the Capital Cresent & Metropolitan Branch Trails”, approved by the Planning Board January 2001 and available online on the CCCT website at CCT Archives. It was developed and supported by a team of representatives from the nearby communities, trail user groups, planning staff at M-NCPPC, and the professional trail design group Lardner and Klein. This Interim CCT was recommended to be built at a time when the single-track Georgetown Branch trolley, proposed to run from Bethesda to Silver Spring, had fallen by the wayside and with no clear successor in sight. Investment in a “long term interim trail” made sense when transit appeared to be going nowhere soon. But shortly after this study was approved the movement for transit came to life again as the Purple Line. The “long term” part of “interim trail” went away, and with it the support for spending millions to build it.

M-NCPPC trail planner David Anspacher has recently begun to examine the “Plan B” bypass concept. He has circulated this and other alternative CCT route ideas among M-NCPPC staff for comments, and has asked trail design consultants Toole Design to include this in an evaluation of CCT alternatives they are doing for M-NCPPC. This work becomes ever more important as CSXT continues to withhold cooperation on trail r.o.w. issues.

We need to act to keep “Plan B” alive as a feasible option.

The FEIS presents a depressing false choice: We either complete the preferred alignment CCT into Silver Spring with CSXT cooperation for the trail r.o.w., or else we just give up and dump the CCT onto local roads. If we allow MTA to give up so easily on the CCT, then this could be self fulfilling. The “Plan B” version of the trail could be blocked from being built with the Purple Line if MTA proceeds to build the Purple Line with no consideration for compatibility with a possible “Plan B” trail.

What we can do:

1 – Submit comments on the Purple Line FEIS that respond to the “false choice” that is presented for completing the CCT. Point out there are options for an off-road CCT that bypasses the CSXT r.o.w. should CSXT refuse to cooperate on the trail. Ask MTA to commit to designing and building the best feasible off-road CCT extension into downtown Silver Spring, in coordination with Montgomery County, consistant with the promises it has made to the community for over two decades. Comments can be submitted online at FEIS Comment Form or by sending an email to with “FEIS COMMENT” as the subject heading.

2 – Contact the Montgomery County Executive, Council, and Planning Board and let them know there are options for completing a good off-road CCT that do not require CSXT r.o.w. Ask them to accelerate study of “Plan B” options, to be ready in case the preferred CCT alignment is blocked by CSXT refusal to grant r.o.w. for the trail. Tell them that we expect them to keep the promises they have given to us for many years to complete the CCT, and this trail is much too important for them to give up so easily.


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