Responses To Comments On The Purple Line Functional Plan (M-NCPPC
Responses To Comments On The Purple Line Functional Plan (M-NCPPC
The Purple Line Functional Plan was drafted by the Montgomery County Planning Department
with the stated goal of “identifying the specific alignment and station locations within the County
so that existing and future master, sector, station area, and other plans will have the benefit of
adopted policy as to the location, mode function, and general operational characteristics of the
Purple Line”1.
The Montgomery County Planning Board held a December 10, 2009 public hearing where they
accepted oral and written testimony from anybody who had an interest in the plan. All testimony
will be considered by the Montgomery County Planning Board as it provides direction to
transportation planners during upcoming March work sessions. The Board-approved version of
the plan will go to the County Council for final review and eventual adoption.
In an effort to better inform the Montgomery County Planning Board as you finalize the plan, the
Maryland Transit Administration (MTA) is providing responses to some of the most frequent
comments submitted at either the hearing or subsequently submitted in writing. The following
comments may be used by the staff and Planning Board in written responses or in the decision-
making process during the upcoming working sessions.
Comments concerning loss or lack of access to the Capital Crescent Trail; comments that the
current level of access to the trail needs to be maintained
MTA shares in the desire to provide good access for the surrounding communities to the
permanent Capital Crescent Trail that will be built as part of the Purple Line project. The design
of the trail is being developed to maintain all formal access points and MTA is investigating
additional access points at the suggestion of the County and local community members. MTA
does recognize that the informal access from individual private properties will not be retained in
all areas.
Comments stating the safety will be diminished with transit running along the Capital
Crescent Trail especially for people who will have to cross the tracks to walk to school, work or
for recreation
Safety is a critical concern in the development of the entire 16-mile Purple Line project. Light
rail transit systems are designed to be pedestrian-friendly facilities that fit into urban and
pedestrian environments. This has proven to be the case in a growing number of cities in this
country (such as Portland, OR, Charlotte, NC, Houston, TX, and Phoenix, AZ) and many cities
and towns in Europe. Light rail lines do not travel with the high speeds of Amtrak, Metrorail, or
1
Purple Line Functional Master Plan, November 2009. Montgomery County Planning Department. Pg. 7.
MTA fully recognizes the importance of the Capital Crescent Trail to a variety of users and as a
community asset. The MTA is keenly aware that this trail is used for recreation, commuting and
travel, and every effort is being made to provide for a safe and enjoyable experience for all users
and the greater community.
Included in the Locally Preferred Alternative (LPA) for the Purple Line is the construction of a
permanent trail facility alongside the transitway between Bethesda and the Silver Spring Transit
Center. This trail would be built following Montgomery County standards for trail design; a 10-
foot-wide minimum paved trail with 2-foot shoulders. Between Pearl Street and of the vicinity
of Jones Mill Road the trail would be on the north side of the transitway; elsewhere it would be
on the south side. Access to the trail would be provided at various points along the way, as
would crossings over or under the transitway. The MTA has set a goal of maintaining a
landscaped buffer of approximately 10 feet between the trail and the transitway and, wherever
possible, the trail would be built at a slightly higher elevation than the transitway. A barrier,
either a fence or a wall, would separate the trail and transitway. The trail would continue from
Jones Mill Road to the Silver Spring Transit Center. The trail would cross the CSX right-of-way
on a new pedestrian bridge near the existing Talbot Avenue bridge. After crossing the CSX right-
of-way the trail would continue on the north side to the Silver Spring Transit Center.
The MTA is confident that the plans for the light rail system under development for the
Georgetown Branch Master Plan alignment will ensure the continued viability of the trail.
As requested by Montgomery County, and supported by many trail users, MTA will be working
closely with the County and M-NCPPC, as well as local communities, to assess and consider
widening the trail to 12 feet, and even up to 16 feet in certain locations. However, we are
concerned that a widening of the trail would reduce the amount of buffer and landscaping
between the transitway and trail. Such implications will be a key part of this analysis.
Comments opposing the Functional Master Plan due the loss of trees along the Capital
Crescent Trail
MTA will be following the stringent requirements of the Maryland Forest Conservation Act and
will be replanting trees. Where possible these will be in the Georgetown Branch right-of-way.
MTA believes that the Purple Line will ultimately provide a greater benefit as it is the only major
opportunity to improve east-west transportation inside the Capital Beltway. On an
environmental level, the project will support Smart Growth initiatives and improve regional air
quality by getting people out of cars and onto transit.
Comment regarding increases in noise and vibration levels along the alignment; comments
that the previous noise analysis was performed inaccurately
MTA recognizes the potential for increases in noise and vibration levels along the alignment and
has performed detailed analysis of current and future noise and vibration levels in the corridor as
part of the AA/DEIS process. As part of that process and as required by FTA, where projected
noise levels could exceed FTA standards, the MTA will continue further developing noise and
vibration mitigation strategies to eliminate or reduce impacts to acceptable levels.
In response to the comment that noise analysis was performed inaccurately or equipment was not
properly calibrated, the MTA does not agree with these assertions. All noise analysis and
monitoring was performed to FTA requirements and industry accepted standards. All noise
monitoring equipment used in this analysis, whether owned or rented, is calibrated annually by a
certified acoustic laboratory. The calibration certificates for the equipment have been made
available. Furthermore, prior to starting a noise measurement at each noise monitoring site a
manual calibration using a pure tone calibrator (also calibrated annually) is performed to ensure
accurate collection of noise monitoring data at each location.
Along the Georgetown Branch (3.2 miles) portion of the project, MTA’s noise analysis shows
that the project-generated noise levels are estimated to be 5 to 6 dBA below the minimum noise
level that would result in a noise impact. Specifically, the abatement measures integrated into
the design along this alignment ensure a quiet operation with no noise impacts to adjacent
residents. The measures incorporated into the project design include train skirts on the light rail
vehicles and retaining/sound walls.
It should be noted that the MTA will be performing additional noise analysis for the Final
Environmental Impact Statement. This analysis will reflect the refined alignment that results
from the completion of preliminary engineering and will reflect more precise alignment design,
track design and vehicle specifications. In addition these noise impact assessments would reflect
the use of planned mitigation. Noise measurements would also be taken at more locations in the
corridor.
The Dale Drive Station on Wayne Avenue in Silver Spring has been the subject of much
discussion. MTA recognizes that some members of the local community have been opposed to
the station; generally because of fears that the area would be rezoned to permit denser
development. As part of the Purple Line ongoing public outreach efforts and the Purple Line
Functional Master Plan process, there has also been strong community support for the station,
including a letter signed by 177 residents. One of the key reasons explained behind this growing
support is the improved accessibility that a station at Dale Drive will provide to the community.
Further, MTA recently has received emails from over 30 residents of the Silver Spring
community who expressed their strong support for having a Purple Line station at Dale Drive.
The Montgomery County Planning Board has recommended dropping the station, or at least
deferring its construction. The County Council concurred with this, but recommended that the
Purple Line be designed and built so that the station could be added sometime in the future
without having to acquire additional land. This position is currently reflected in Locally
Preferred Alternative (LPA).
Consistent with the Locally Preferred Alternative, the Dale Drive station will continue to be
studied. Should this station be built, it will be important that the planning and environmental
analysis are completed and understood, which MTA is working on in coordination with
Montgomery County. Additional refinements and updates to the regional travel forecasting
model, which are being made as part of MTA’s current studies, may provide more information
regarding anticipated ridership at the Dale Drive station. Once available in the very near future,
MTA will be sharing this information with Montgomery County and the Silver Spring
communities as the possibility of this station is considered further.
It is MTA’s position that concerns about increased development around the station are
unfounded as stated on many occasions by Montgomery County planning staff. In addition, the
benefits to the community of having the Dale Drive station, in the form of local access, increased
ridership, and improved project cost-effectiveness, are substantial. Currently, the area around the
proposed station is largely developed with predominantly single family residential properties.
MTA understands that the Montgomery County has no plans for redevelopment in this area.
MTA strongly supports the construction of the Dale Drive Station, preferably in the initial
construction of the Purple Line.
For a more detailed analysis of the merits of a Dale Drive Station please go to the Purple Line
website at: http://www.purplelinemd.com/additional-studies
The selection of LPA and subsequent Purple Line Functional Master Plan did not address the
impacts of BRAC at the National Naval Medical Center (NNMC)
The potential impacts of BRAC have been fully assessed in the ridership, demand, and traffic
modeling contained in the AA/DEIS. The AA/DEIS used the most current land use forecasts for
employment, households and population available at the time of the analysis. These models have
and will be updated as new modeling rounds are produced by the MPO. However, the MTA did
The Bethesda CBD area exists today, and will continue in the future, as a major employment and
population center exclusive of the BRAC changes. Combined employment around the Medical
Center Metro Station is expected to grow by over 6,000 jobs to 2030 and population is expected
to grow by approximately 700 in that time. The Bethesda CBD is expected to grow by 5,000 jobs
and show a population increase of over 12,000 residences in that same period. The BRAC
changes, while large, are a small percentage of the expected 72,000 jobs in the Bethesda CBD /
Medical Center area in 2030. Projections for daily Purple Line ridership by both Medical Center
employees, and patients and visitors are less than 250.
In addition, the congested traffic conditions expected along Jones Bridge Road would contribute
to travel delays to trips arriving from the east. Given the travel time savings from using the
Georgetown Branch right-of-way, the most efficient trip would be to use the Georgetown Branch
right-of-way, and then transfer to the Red Line. This trip, which would be provided under the
LPA, would be faster than the travel time for the Low Investment Bus Rapid Transit Alternative
(using a Jones Bridge Road alignment) assessed in the AA/DEIS. Moreover, the attractiveness
of travel to and from the Bethesda CBD from the east would be expected to be significantly
affected with the significant travel delay associated with travel along a slower Jones Bridge Road
alignment.
Therefore, given the access afforded by Purple Line alternatives along the Master Plan alignment
and connecting the Metrorail Red Line to the Medical Center Station, the impacts of BRAC on
travel in the Bethesda area are notable more for the additional delays expected on area roadways
than for the potential contributions to Purple Line ridership.
For a more detailed analysis of the implications of BRAC please go to the Purple Line website
at: http://www.purplelinemd.com/additional-studies
Comments the Functional Master Plan ignores or does not address environmental impacts on
Capital Crescent Trial including loss of greenspace, wildlife habitat, and loss of recreational
opportunity
MTA has fully considered environmental impacts and concerns in the development of the
alternatives. This assessment was part of the Alternatives Analysis/Draft Environmental Impact
Statement (AA/DEIS) and will be further addressed in the Final Environmental Impact
Statement. Every effort to minimize impacts will continue to be included in the alternatives and
mitigation measures for unavoidable impacts will be developed and included in the project.
The construction of the Purple Line has the potential to cause temporary impacts to the
surrounding environment and communities. Typical short-term construction impacts could
Specific to the Georgetown Branch Interim Trail, portions of the trail will need to be closed
during construction. This is due to the construction of the transitway and
reconstruction/relocation of the trail and is needed for the safety of trail users. Detailed
construction phasing will be developed during final design and will determine the extent (limits)
and duration of the trail closures. Every effort will be made to minimize these closures.
Appropriate signing and notices will be used to notify people of the closures and detours.
Comments questioning why and how the decision to place the Capital Crescent Trail on the
north of the transitway in Bethesda-Chevy Chase was made
The Georgetown Branch Master Plan Amendment (1990) called for what would become the
Capital Crescent Trail to be located on the south side of the future transitway. During the
alternatives analysis phase of the Purple Line study, public comments led to an effort to take a
closer look at the trail and transitway to see if locating the trail on the south side was the best
choice.
There were two objectives to MTA analysis which was carried out in early 2007. The first was
to determine the best location for the trail - north side versus south side of the transitway and to
determine if the separation between the trail and transitway could be increased to provide a
larger landscaped buffer to improve the quality of the trail.
Under the first objective, the major factor that influenced the preferred location of the trail was
locating the trail closer to the existing elevation of the surrounding land while keeping it three to
four feet above the transitway, where possible. The intent was to provide a vertical separation
between the trail and the transitway thus resulting in a number of benefits for the trail users
including:
improves aesthetics and places the trail more on the natural lay of the land
minimizes retaining wall heights and thereby reduces construction costs
minimizes environmental and construction impacts
creates a greater comfort level when a vehicle passes trail users
limits pedestrian at-grade crossings to the designated crossings
The analysis determined that the preferred location of the trail is a combination of the north side
and the south side because it provides the desired vertical separation while keeping the trail
closer to the existing elevation of the surrounding land. In the Bethesda-Chevy Chase area the
preferred location is on the north side of the transitway from Pearl Street in Bethesda, east
through Columbia Country Club and across Connecticut Avenue, to a point just south and west
of the Jones Bridge Road/Jones Mill Road intersection where the trail crosses to the south side
before going under Jones Mill Road. From there it then remains on the south side, due to the
location of the maintenance yard in Lyttonsville.
The analysis indicated that we can achieve ideal separation distance for both trail options when
along the 100 foot right of way, where the Columbia County Club abuts the right-of-way. In the
area of the 225 foot right-of-way, the trail and transitway cross over Rock Creek and both trail
options could achieve the ideal separation distance. The alignment after Rock Creek has a right-
of-way of 65 feet that then drops down to 60 feet. The separation along this segment of the
alignment cannot be improved because part of the proposed Yard & Shop Facility lies within this
right-of-way.
However, the area along the interim trail with the greatest possibility of increasing the separation
occurs within the 66 foot right-of-way at the western end of the alignment. Even though the
north side within the 66 feet right-of-way has a shorter planting length, its planting width has a
consistent and wider width - on the average of 9 to 10 feet.
In reviewing the analysis, MTA has determined that locating the trail on the north side of the
transitway in this section is the preferred location. The advantages of this location include
increased separation distance, presenting the trail in a more naturalistic environment, providing
the opportunity to buffer/screen the trail from the track with vegetation, minimizing retaining
wall heights resulting in reduced construction costs, preventing the trail users from feeling
overwhelmed when a vehicle passes them, and increased safety by preventing trail users from
crossing the transitway except at the designated crossings. MTA has presented our analysis and
findings to the community at many Purple Line meetings, beginning in March 2007.
It is further noted that the placement of the trail along the north side of the transitway would not
affect the analysis and findings of MTA’s noise studies. Some comments submitted expressed
the view that noise impacts to residents of the Town of Chevy Chase would be reduced if the
trail were located along the south side of the transitway, instead of on the north side, along this
portion of the project. As shown in the AA/DEIS Noise and Vibration Technical report and as
explained in the above discussion regarding noise and vibration, no noise impacts along the
Georgetown Branch right-of-way are projected, regardless of whether the trail is located north or
south of the light rail tracks.
Comments that the transitway and trail alignment pass too close to Rosemary Hills
Elementary School
MTA has met with representatives from Rosemary Hills Elementary School to discuss their
concerns and review the current conceptual plans for this portion of the alignment. As a result of
these discussions, MTA is developing options that take the trail across the CSX tracks prior to
Comments that a double tracked alignment was not part of “Master Plan” and there is not
enough right-of-way for a double track alignment.
The Georgetown Branch Master Plan Amendment (1990) called for segments of both single-
track and double-track transit on the former railroad right-of-way. However, as part of their
review of the Purple Line AA/DEIS, the Montgomery County Council and Executive endorsed
and recommended the Medium Investment Light Rail Transit (LRT) alternative, with a double-
track segment running along the Master Plan alignment between Silver Spring and Bethesda, for
the Purple Line locally preferred alternative.
In their LPA endorsement, the County Council and County Executive, asked the MTA to study if
there were opportunities for single-tracked segments in the far western portion of the alignment.
There are several issues outlined below that need to be considered when looking at why the
entire length of the Master Plan alignment is proposed to be double-tracked.
Use of Single-Track in Other Systems: Several LRT systems have been built initially as
single-track systems. All of these systems have eventually been double-tracked at a
greater monetary cost with significant adverse impacts, including disruptions to service,
decreases in ridership and degradation of service reliability.
Service Reliability Impacts: East of Silver Spring, the Purple Line is a mostly at-grade
route within or along existing roadways. Therefore, operations along these portions of
the project would be subject to traffic signal and other traffic-related impacts. Any delay
would have significant impacts on the operations of the single-track segment resulting in
delays that would cascade through system, resulting in poor reliability.
Reduction in Tree Loss: It is expected that to construct the trail and either a single-track
or double-track transitway most of the trees would need to be removed. While new trees
and landscaping would be replanted when construction was completed, the hoped-for
In sum, introducing a single-track segment would significantly compromise travel time savings,
service frequency, passenger carrying capacity, and the maintenance and operating reliability of
the Purple Line. For a more detailed analysis of single tracking along the Georgetown Branch
right-of-way please go to the Purple Line website at: http://www.purplelinemd.com/additional-
studies
Comments that the project is too costly for the benefits it will produce
The Purple Line will be an expensive transportation improvement, but transportation projects are
long-term investments in our communities, and we believe that this project will help to alleviate
long term problems faced by the Washington region and communities within the corridor by
providing a fast, reliable alternative to the private automobile. As our understanding of the
severity of global climate change increases and the need for Smart Growth increases, the benefits
associated with projects like the Purple Line grows.
We believe that effective mass transit is one tool in addressing the worsening congestion and
growing number of residents and jobs in the D.C. metropolitan area.
The Purple Line is the next generation of transit in Maryland and will support a more sustainable
future for our State. Transit provides an alternative to the private automobile; helps reduce auto
emissions; focuses development in our Priority Places; and helps to protect and preserve our
precious natural resources, particularly the Chesapeake Bay.
As we face the ever more congested roadways that result from the continued growth of jobs and
population in the Washington metropolitan areas, this project will support the achievement of our
goals for a smarter, greener, more sustainable Maryland. By providing fast reliable transit
services for our residents and employers the Purple Line will enhance the communities it serves,
supporting community revitalization and helping us to grow smarter.
Comments that ridership estimates use speculative and unreliable data; The proposed system
is “bloated” with stations to artificial inflate ridership and the attractiveness of the system
The ridership estimates for the Purple Line AA/DEIS and subsequent analyses were prepared in
accordance with Federal Transit Administration (FTA) guidance by professionals with decades
of experience on similar projects around the country. The tool used for the Purple Line ridership
forecasts is based on the Metropolitan Washington Council of Government’s (COG) regional
travel forecasting model, enhanced for corridor level transit analyses as a key part of the Purple
Line study process. The demographic input to the model, the current and future residential and
employment estimates, which are the primary factor in the model’s travel patterns and ridership
estimates -- are also from COG. These estimates are based on input from local governments.
The Dale Drive Station was included in the Purple Line AA/DEIS Transportation System
Management (TSM) Alternative and all of the BRT and LRT alternatives. The number of
stations for a 16 mile line is comparable to similar light rail transit lines in the country, resulting
in about a ¾-mile station spacing. The station placement and spacing was designed to provide
convenient walk access to the BRT and LRT line alternatives. The light rail alignment selected
as the Locally Preferred Alternative provides substantial travel benefits over the future local bus-
based service.
In response to a request by Montgomery County, MTA developed concept plans which include
locating the trail under Wisconsin Avenue, the Apex Building and the Air Rights Buildings in a
shared tunnel with the Purple Line transitway. While this is challenging from a design
perspective, it would provide trail users with an unimpeded path rather than traveling on local
streets. Many trail users and trail advocacy groups strongly support extending the future Capital
Crescent Trail to be built with the Purple Line, through the existing tunnel in Bethesda.
Current plans include the location of the trail above the transitway through the tunnel. MTA
continues to work with the owners of the structures above the tunnel right-of-way to maximize
the width and vertical clearance for the trail, providing a trail between 16’ to 20’ wide with a
vertical clearance that varies from 8’± to 13’±. The grade for the trail from the west end of the
Apex Building to the east end of the Air Right Building is essentially level, with a maximum
grade at less than 2%. The steeper grades for the trail switch back located at the west end of the
Apex Building were designed as part of the proposed Woodmont East Development.
Comments that the Purple Line alignment should be on I-495 (The Beltway)
The Metrorail Loop alignment was proposed by Montgomery County Executive Duncan in
January 2003. This proposed Metrorail (heavy rail) alignment would have extended from the
existing Medical Center Metrorail Station in Bethesda north via a tunnel under the Capital
Beltway and along the north side of the Beltway, primarily on an aerial structure. It would then
cross back over the Beltway, continuing south along the Metropolitan Branch CSX corridor
either in a retained cut or in a tunnel to the Silver Spring Transit Center (SSTC). This alignment
would be a continuation of the Metrorail Red Line and, as such, it would have been heavy rail
and would not have continued past the Silver Spring Transit Center in the same mode.
Both the MTA and M-NCPPC carried out assessments of this proposed alignment. The MTA
concluded that while the Metrorail Loop could improve operations and provide redundancy for
the Metrorail Red Line; these advantages would not have applied to the Purple Line corridor as a
whole. Implementation of the Metrorail Loop would not have addressed the issues of system
connectivity, mobility, accessibility, and efficiency for the entire corridor that are part of the
Further, substantial natural and human environmental impacts are associated with the Metrorail
Loop option. This alignment would have required acquisition of right-of-way from Rock Creek
Park along the Capital Beltway. This alternative would have also required property from
approximately 25 residences along the CSX right-of-way. The Metrorail Loop would not have
supported economic and community development west of Silver Spring because there would be
no stations at the Chevy Chase and Lyttonsville communities. Moreover, this alignment would
have been a less cost-effective solution to addressing the transportation problems and needs
associated with the Purple Line corridor compared to a BRT or LRT alternative for the entire 16-
mile corridor.
In January 2003, M-NCPPC issued a report recommending that the Metrorail Loop not be
carried forward for further study. While recognizing the benefits to the existing Metrorail
system, M-NCPPC recommended that the proposal not be carried forward due to a number of
considerations. These included: the high cost of the project (estimated at twice that of the Purple
Line), lower cost-effectiveness, greater impacts to the natural environment, the inability to serve
communities between Bethesda and Silver Spring, and impact to the outer Red Line stations
(stations north of Medical Center and Silver Spring).