Feedback + Responses / General
Reference
number
1
2
Comment
Commenter
(if known)
Richard Handfield
I-495 is mislabeled on inside back cover
My heart + mind are cheering - just hope one of these changes happen. If I can help please ask. Emily Jones
Response and Proposed plan revisions
(if applicable)
Revise to I-190
3
MassDOT / GreenDOT is doing a fantastic job if we can only get House of Rep in Washington to
go along with Senate who is all for green energy and biking and Safe Route to School we would
be fine
GreenDOT Open House
Worcester
4
Get the word out by setting up at fairs and festivals
GreenDOT Open House
Thank you for your support.
Worcester
5
I just hope half of these initiatives are actively being implemented by next year! Finally I met the
Emily Johns
head of the Green DOT (or was it just DOT) planning department the other afternoon- lovely
chatting with him for the brief time-- but I met so many people, and forgot to ask for his card. And
I didn't think to suggest this planting initiative, since I was happily thinking about so many of the
other initiatives you want to implement. Please say hello for me. Happy to help in any way! Best of
luck- Thanks for listening
6
Printer friendly version
7
MA GreenDOT should have a 4th primary objective: Reduce the negative impact of our
transportation system on ecosystems and the biodiversity they support in a time of changing
climate.
Berkshire Environmental We will consider the suggestion in the future, but there is
Action Team, Inc.
no proposed revision to the plan at this time.
8
Smart growth should be sustainable development - so far "smart growth" has been anything but
smart in the western part of the state. I wish you would stop using this phrase.
Berkshire Environmental Thank you for your feedback.
Action Team, Inc.
9
2 typos found p. 44 Albedo not albeto. P 72 Maintenance not Maintenance
GreenDOT Open House Revise: Albedo and Maintenance
Amherst
10
Work with towns to help them improve practices and projects, e.g. appropriate width roads - no
more giant impervious cul-de-sacs
GreenDOT Open House Complete Streets workshops will be continued by
Amherst
MassDOT staff as an ongoing element of our Bay State
Roads technical assistance program to municipalities.
11
Example of scorecard was not immediately intuitive. It would be helpful to show a clear example
of a task & its indicators being scored - I agree!
GreenDOT Open House We will evaluate this graphic and potentially clarify the
Amherst
scorecard.
12
Thank you for the comprehensive effort into Greening all aspects of the planning process
GreenDOT Open House Thank you for your support.
Amherst
13
Focus on context-sensitive design would be nice e.g. right sizing projects, not overbuilding, using GreenDOT Open House Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for consideration
reasonable design standards (not overly wide/straight/flat/clear)
Amherst
in the development of their annual GreenDOT Work Plans
Page 1 of 74
The format online was designed to be universally
accessible - we will post a print-friendly version as well.
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
14
We commend MassDOT for its efforts to establish an innovative and nation-leading sustainability Transportation 4
plan following on its June 2010 release of the GreenDOT Policy Directive.
Massachusetts /
Conservation Law
Foundation
15
Overall, the Plan is evidence that MassDOT is moving in a very positive direction; it presents an
innovative, model blueprint for DOT sustainability. For example, it commits MassDOT to improve
the fuel efficiency of the transit fleet (p. 12); reduce building electricity use (p. 20); increase
production of renewable energy at MassDOT facilities (p. 24); increase the percentage of
recycled materials used in paving and concrete installations (p.43); and reduce stormwater
volumes and increase permeable surface areas (p. 72). The Plan reflects a serious, thoughtful
analysis of MassDOT’s diverse responsibilities and activities and how the Agency can reduce the
environmental impacts of those activities. The Commenters applaud and strongly support
MassDOT’s commitment to sustainability at all levels, as evidenced in the detail of the Plan.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Response and Proposed plan revisions
(if applicable)
Thank you for your support.
16
Thank you for the opportunity to comment on the Draft GreenDOT Implementation Plan. We thank Environmental League of Thank you for your support.
MassDOT for the thought and hard work that clearly went into its development. We strongly
Massachusetts
support the agency's efforts to integrate sustainability and environmental stewardship into its work
and decision making.
17
As you know, GreenDOT sets a goal of reducing greenhouse gas emissions by more than 2
Environmental League of
million tons by 2020, a reduction of about 7.3 percent below 1990 transportation sector emission Massachusetts
levels. This is necessary if the Commonwealth is to reach our ambitious GHG reduction target of
25% by 2020 as established pursuant to the Global Warming Solutions Act passed 4 years ago
next week. As you also know GreenDOT has three primary goals: 1) reduce GHG emissions; 2)
promote healthy transportation options; and 3) support smart growth development. What is not
clear from the Implementation Plan is where each of the outlined actions fit in terms of supporting
these three overarching goals and whether or not the suite of actions in the Implementation Plan
will achieve the 7.3% reduction. While environmental stewardship within the agency is laudable,
most important is to determine how GreenDOT will achieve our GHG reduction targets, therefore,
we encourage MassDOT to include more information about expected GHG reductions in the next
iteration of the plan. We understand that each MassDOT Division Chief will be further defining
actions needed, however, there is only a passing reference to that important work in the plan and
it is difficult to evaluate the plan without information about the reductions expected from each
action or set of actions. Of particular concern is what seems to be a lack of action steps that
would advance the third goal of supporting smart growth development given the critical nexus
between transportation, land use, and GHG emissions.
Page 2 of 74
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
18
Mass Audubon has a longstanding interest in the intersection of transportation systems and
Mass Audubon
planning with environmental protection and restoration. In recent years, the many significant links
among transportation, land use, and environmental health have become more apparent and
better understood. Transportation facilities have significant direct and indirect ecological effects
including habitat loss and fragmentation, stormwater pollution, dispersal of invasive species, and
(all too often historically) facilitation of sprawl development. The GreenDOT initiative has
established principles for Massachusetts to be a leader in environmentally sound transportation
planning, including the commitment to “promote sustainable economic development, protect the
natural environment, and enhance the quality of life for all of the Commonwealth’s residents and
visitors.” Mass Audubon supports this goal, and appreciates the efforts DOT is putting into
translating the broad goals and principles of GreenDOT into more specific policies and programs,
organized around seven broad themes across all of DOT’s divisions.
Thank you for your support
19
The overall goal of the plan is stated as: Operate the transportation system in a manner that
Mass Audubon
embraces our stewardship of the Commonwealth’s natural, cultural, and historic resources. We
recommend that this be modified to include design, construct, and maintain as well as operate.
Stewardship is more than embracing a concept – the goal should more explicitly make a
commitment to protecting and restoring the Commonwealth’s resources. The GreenDOT policy
recognizes the connections among transportation, economy, and quality of life. The attractiveness
and health of Massachusetts’ environment is one of its greatest assets, and we appreciate DOT’s
recognition of that in its policy.
Thank you for your feedback no proposed revision to the
plan at this time
20
Establishing the 15 sustainability goals in the Draft GreenDOT Implementation Plan and the
proposed initial tasks to implement are excellent first steps. Follow-up and implementation are
even more critical for MassDOT to reach its objectives of greenhouse gas emission reductions
within the transportation sector, as required under the Commonwealth’s Global Warming
Solutions Act.
While GreenDOT seeks to craft feasible solutions to reach
the various goals, the pathway to implementing all the
GHG and other sustainability targets will depend on
numerous policy and budget decisions over the
upcoming years.
21
Overall, the plan’s Goals and Objectives are comprehensive, easy to understand, and provide
Pioneer Valley Planning
flexibility in implementation and measurement. Our comments are grouped according to the main Commission
themes of this draft plan.
Thank you for your support
22
Introduction - We would suggest modifying MassDOT’s Stewardship Goal to include: “to design,
construct, maintain, and” operate the transportation system in a manner that embraces our
stewardship of the Commonwealth’s natural, cultural, and historic resources.
This stewardship goal is an element of MassDOT's
mission statement, however your suggestion will be
forwarded to the applicable department on MassDOT for
consideration.
Page 3 of 74
Friends of the
Community Path
Pioneer Valley Planning
Commission
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
23
The introduction also should include clear references to GreenDOT’s policy directive on page 10
that are consistent with the three primary goals of the draft plan. Secondary goals should be
clarified and their supportive objectives subdivided into measurable tasks rather than the current
indicators. In addition, it would be helpful to highlight which tasks/indicators will be ongoing past
their suggested completion target date.
Pioneer Valley Planning
Commission
Thank you for your feedback no proposed revision to the
plan at this time
24
It is great to see in this draft plan the thorough detailed process of revising operations and
projects for sustainability at MassDOT. Once these indicators and performance measures
become part of the culture, important lessons could be learned and in turn would spur further
applicable indicators and measures. It would be helpful to understand how decisions about
demonstration projects under this program will be made, especially in terms of geographic
location.
Pioneer Valley Planning
Commission
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for consideration
in the development of their annual GreenDOT Work Plans
25
There appears to be no particular funds attached to any of the GreenDOT recommendations.
However, a significant dedication of resources is required for such a broad and meaningful
change to be achieved. It would be helpful to see the level of agency commitment required to
actually implement this plan. Thus, more information is needed on how funding would be
incorporated into the implementation of GreenDOT.
Pioneer Valley Planning
Commission
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
26
It seems that all MassDOT divisions are expected to follow the guidelines set forth by this plan,
but it is not clear whether it is also mandated for MPO’s and RPA’s. It would be helpful to include
additional detail on who the implementers of this plan would be.
Pioneer Valley Planning
Commission
Language added to introduction clarifying MPO
collaboration
27
First let me say that I applaud MassDOT’s efforts in producing this GreenDOT Implementation
Plan. The document is well organized, visually appealing, and highly pro-active. It is good to see
MassDOT setting goals and actions in the green arena.
Michelle Ciccolo
Town of Hudson
Thank you for your support
Page 4 of 74
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
28
Funding: I see very little mention of how the various programs will be funded in any sections of the
plan. Since the effectiveness of implementation will depend highly on the degree of funding, I
would encourage MassDOT to reference funding streams and make financial commitments to
back up this plan. I also think it highly important for MassDOT to firm up its commitment to
funding for GreenDOT initiatives, especially in light of the shifts made by federal law MAP-21, with
its emphasis away from dedicated funding for Enhancements, bike, ped, SRTS, and other such
programs.
Michelle Ciccolo
Director of Community
Development Town of
Hudson
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
29
Outcomes: While the plan itself is replete with tasks and goals, the larger quantitative outcomes
that MassDOT is hoping to achieve are generally not stated within each section of the plan, nor in
the summary sections. It would be helpful to include the big picture outcome MassDOT hopes to
accomplish so that actual progress can be measured and documented in the future. For instance
you might consider stating how many VMT’s will be avoided through the accomplishment of
mode-shift specific goals; or how many pounds of CO2 will be reduced from both energy
conservation and mode-shift; and how much financial savings the department hopes to achieve;
and total pounds of recycled material that will be diverted away from landfills, etc…
Michelle Ciccolo
Director of Community
Development Town of
Hudson
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
30
Training/Education/Cross jurisdictional: It would be great to see a greater emphasis on training
and educating MassDOT personnel on the goals and objectives of GreenDOT. Also, there seems
to be very little mention of working with the District offices and collaborating with other state
agencies or municipal entities. MassDOT made great strides. recently in expanding awareness
around Complete Streets through its training program which was also offered to municipalities.
This highly successful venture could serve as a model for future initiatives and thus I encourage
you to make reference to how you will provide such trainings and educational opportunities going
forward.
Michelle Ciccolo
Director of Community
Development Town of
Hudson
Indicators on technology transfer to municipalities and
training are added throughout document
Page 5 of 74
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
31
P. 74 – Under “Next Steps,” I recognize the need to be flexible in responding to changing
environmental situations, new opportunities, and funding constraints. However, this section
comes off sounding a bit like a ready-made excuse not to follow the tasks in the plan. In general, I
think the plan is weakest in its discussion of how the plan will be implemented; by whom, under
what organizational structure, etc. While reference is made to the various MassDOT departments
who will participate in implementing the plan, this “Next Steps” section primarily only discusses
measuring progress towards meeting the performance measures… I like the idea of the score
card but would like to see a greater commitment to team building; regular structure for plan
implementation; regular and predictable revising of the plan so that it does not become stale;
assignment of responsibilities to key personnel, etc.
Michelle Ciccolo
Director of Community
Development Town of
Hudson
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for consideration
in the development of their annual GreenDOT Work Plans
32
P. 76 – Good appendix but could use the actual web-links.
Michelle Ciccolo
Revised to add web sites where available
33
The very fact that Massachusetts has such a plan with the laudable goal of becoming “the most Michelle Ciccolo
sustainable transportation department in the country while meeting our organizational mission of
excellent customer service and safety,” makes me proud to live in the Commonwealth. I wish
MassDOT well in making progress towards implementing this plan. I look forward to collaborating
with MassDOT at the municipal level in order to help achieve some of the goals laid out within the
plan.
Thank you for your support
34
ABC applauds the policies of GreenDOT which makes sustainability part of every employee’s job A Better City
and establishes that MassDOT be an innovator in promoting sustainability throughout the
transportation sector. ABC strongly supports GreenDOT’s objectives to 1) Reduce greenhouse
gas emissions; 2) Promote healthy transportation options of walking, biking, and public transit;
and 3) support smart growth development. For many years, ABC has leveraged private sector
commitment to address these objectives. We have a long track record of independent research
and advocacy focused on fostering economic growth through an improved transportation system
that supports a multi-modal approach to moving people and goods throughout the region. In
addition, our Transportation Management Association (TMA), which provides direct commuter
benefits programs and services to more than 80,000 commuters in Boston; directly reducing
mobile source pollution and greenhouse gas emissions. Increasing the energy efficiency of the
state’s transportation system and infrastructure will not only benefit the environment through
reduced greenhouse gas emissions but can potentially save MassDOT and the MBTA millions of
dollars through reduced energy costs. We strongly support MassDOT moving forward as quickly
as possible to realize these savings.
Thank you for your support. Efforts will be made to
quantify potential fiscal savings from fuel and energy
savings as an initial task of the GreenDOT
Implementation Plan.
35
We commend MassDOT on the creation of the GreenDOT Implementation Plan along with your
existing initiatives and future policies towards creating a truly multi-modal and environmentally
friendly transportation system.
Thank you for your support
Page 6 of 74
Livable Streets
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
36
Establishing the 15 sustainability goals in the draft GreenDOT Implementation Plan and the
proposed initial tasks to implement them that are listed in the Draft Plan are excellent first steps.
Obviously, follow-up and implementation are even more critical if MassDOT is going to reach its
objectives of greenhouse gas emission reductions with the transportation sector as required
under the Commonwealth's Global Warming Solutions Act.
Livable Streets
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
37
This implementation will require a top-down approach to change the way projects are designed
Livable Streets
and public comments are incorporated if these GreenDOT policies are really to be realized. How
this "top-down direction" will be accomplished and measured should be presented in the
GreenDOT Implementation Plan.
38
Thank you for this opportunity to submit comments on the excellent first Draft of the GreenDOT
Implementation Plan to: “Operate the transportation system in a manner that embraces our
stewardship of the Commonwealth’s natural, cultural and historic resources”.
I like the 15 sustainability goals and the three main objectives of the GreenDOT program:
• Reduce greenhouse gas (GHG) emissions
• Promote healthy transportation options of walking, bicycling, and public transit
• Support smart growth development
Clearly, follow-up and implementation are even more critical is MassDOT is going to reach it’s
objectives of greenhouse gas emission reductions within the transportation sector as required
under the Commonwealth’s Global Warming Solutions Act.
I’m mostly interested in GreenDOT advancing the following 2 goals:
• Design a multi-modal transportation system
• Promote healthy transportation and livable communities
Alan Moore
39
In conclusion, I believe that the Draft GreenDOT Implementation Plan is well done and
comprehensive, that it should be made more specific with more real commitments (especially to
increasing multi-use paths) and that making the construction of the Community Path with the
Green Line extension a top priority by MassDOT is entirely consistent and supported by
GreenDOT’s policies.
Alan Moore
40
MAPC applauds MassDOT for designing a comprehensive Plan to implement policies and
Metropolitan Area
actions throughout the many divisions and agencies under the MassDOT umbrella that will result Planning Council
in reducing greenhouse gas impacts of the state's transportation sector.
41
Many of the policies and specific indicators in the Plan match with MAPC's regional plan for smart Metropolitan Area
growth development in Greater Boston, MetroFuture
Planning Council
Page 7 of 74
Language will be added to the Next Steps regarding
implementation leadership.
Thank you for your support.
Thank you for your support.
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
42
MAPC recognizes the challenge of identifying how to pay for the Plan, given the limited financial Metropolitan Area
resources and the extreme debt our state transportation system is facing. However, we
Planning Council
recommend that MassDOT use the indicators in the Plan to measure progress and to issue an
annual report on how the tasks and indicators are being accomplished, even if lack of funds must
be cited as an impediment to progress.
43
We also urge MassDOT to develop clear ways of measuring the GHG impacts of the various
recommendations included in the Plan, especially since a lack of funding may require MassDOT
to prioritize those activities and projects that will have the greatest impact on GHG reduction.
Response and Proposed plan revisions
(if applicable)
A regular report will be generated on progress toward
meeting the goals, task, and indicators by each division.
Metropolitan Area
Planning Council
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
44
This Plan has the potential to position Massachusetts as a national leader in advancing
Metropolitan Area
sustainable transportation and reducing the GHG impacts from transportation. This potential will Planning Council
be realized if the various departments and agencies within MassDOT are held accountable to
achieving the Plan’s goals and tracking progress along the way. As you know, the full potential for
the Plan is also dependent upon the achievement of adequate funding for the state’s
transportation infrastructure – not only maintenance and operations, but also expansion of the
transit, bicycle, and pedestrian systems that will encourage mode shift and reduce GHG. We
appreciate the opportunity to provide these comments and look forward to working with you and
MassDOT staff on implementation.
45
General Comments - The plan is not well organized and some cross references should be
incorporated, for example the plan suggests reduction of emissions from Maintenance and
Construction vehicles but biodiesel is not mentioned in this section. Biodiesel as an option is
however mentioned in the Air Section for all diesel vehicles.
Cape Cod Commission
Thank you for your comment.
46
The plan mixes strategies and performance measures under Initiatives. I suggest sections
devoted to both with goals for the three time frames you have selected for open ended
implementation e.g. 3 building retrofits to LEED Existing Buildings Operations + Maintenance
(EBO+M) initiated; this is to be accomplished by 2015, how about 6 (or all) by 2020?
Cape Cod Commission
The plan utilizes the completion of implementing
strategies as an Indicator. This is designed to align with
MassDOT's broader performance management system.
47
Goals/initiatives should be numbered.
Cape Cod Commission
Thank you for your comment.
48
Options for collaboration with non-MassDOT agencies should be considered such as bulk
purchases of alternative fuels.
Cape Cod Commission
49
Appendix: State Initiatives to Promote Sustainability - Include federal initiatives
Page 8 of 74
Cape Cod Commission
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for consideration
in the development of their annual GreenDOT Work Plans.
Feedback + Responses / General
Reference
number
50
51
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
ENE appreciates having the opportunity to provide comments on MassDOT's GreenDOT plan and Emily Norton
looks forward to helping advance this exciting initiative. Overview: Overall we are very pleased
with the comprehensive approach and ambitious goal setting. MassDOT aims to be the most
sustainable transportation department in the nation and to do so by reducing greenhouse gas
emissions; promoting healthy transportation options of walking, biking and public transit; and
supporting smart growth development. ENE would encourage MassDOT to think about how to
communicate progress toward those goals; how will we know that we are the most sustainable
transportation department? How will we know if people are doing more walking and biking? How
will we know that we have smarter growth? What metrics will be used to show where we are now
and to demonstrate progress?
ENE
Need for Metrics - In terms of all the actions under the various categories (Air, Energy, Land,
Materials, etc.), again ENE is extremely pleased with the ambition and comprehensiveness of the
plan but would like to see relevant metrics attached to each action. Examples of metrics would
be tons of GHG reduced, number of alternative fuel vehicles purchased, gallons of petroleum
reduced, etc. Here are just a few examples pulled from the plan but the same kinds of questions
can be asked of all the actions listed in the plan:
- Improve statewide air quality - how will this be measured?
- Efficiency of snow and ice operations increased by 50% how is efficiency of snow and ice
operations currently measured? What is the baseline, and how will you demonstrate 50%
improvement?
- By 2020, Electricity purchased by MassDOT reduced by 35% How? And what are the expected
benefits in terms of GHG reduced?
- By 2020, Peak hour single occupancy vehicle trips by employees reduced by 20% How? And
what are the expected benefits?
- By 2015, Customer electric vehicle charging stations installed along northeast corridor routes
Where? How many? Expected benefits?
- By 2015, Electric Ground Service Equipment (GSE) utilized at airports for grounds crew
operations. What kind of equipment, what airports, how many, expected benefits?
Page 9 of 74
Our goal is to embed GreenDOT programs into the
standard operating procedures of the organization in as
many ways as possible, most notably in both
performance management and asset management
systems along with project design and selection
processes. The Administrators of each MassDOT
division will meet quarterly regarding GreenDOT
Implementation and discussions across divisions will be
promoted to share successes and challenges within each
theme topic area. A regular report will be generated on
progress toward meeting the goals, task, and indicators
by each division.
Feedback + Responses / General
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
52
Need for Prioritization: As was made clear at the June hearing on GreenDOT for the House
ENE
Committee on Global Warming and Climate Change, close attention will be paid to costs in this
plan. Especially until such time as the commonwealth develops a more reliable method of funding
transportation, it will be necessary to prioritize all new initiatives, including those laid out in the
GreenDOT plan. More data on the costs and expected benefits of each action will help the
agency determine where best to target limited resources.
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
53
Culture: A key objective to embedding sustainability into the agency culture is to make it easier for ENE
MassDOT employees to take pride and contribute to stewardship. Changing organizational
culture is a critical but notoriously challenging task, and especially to do so in a way that is
permanent, rather than dependent on who is leading the agency at a particular juncture. How
does MassDOT plan to achieve this culture change?
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for consideration
in the development of their annual GreenDOT Work Plans.
Page 10 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
1
Issue with battery life running lights/AC without idling
N/A
The task for MassDOT divisions is to develop idling
policies that go beyond the existing state law but have
applicability for specific operational settings. The
MBTA has created such a policy for their buses, and
GreenDOT will require the Highway Division to craft an
idling policy that meets their operations and safety
needs of workers.
2
I also noticed from the national transit database that diesel bus MPG is 20% less since 2005.
Wrong direction. Please explain and justify.
Mark Kaepplein
Thank you for your feedback. While we can not explain
the national trend, GreenDOT set aggressive targets to
improve the fuel efficiency of the MBTA and RTA's diesel
bus fleets.
3
The plan seems to miss the GHG benefit with the large scale replacement of cars, trucks and
other internal combustions engine vehicle with electric vehicles. It also does not incorporate the
community acceptance of the EV infrastructure necessary to promote and sustain electric
commercial and personal transportation. Likewise it does not envision the necessary State wide
governance and oversight for the far reaching affects of changing the way we have done
transportation for more than 100 years.
Jack Gregg
GreenDOT has made commitments to both EV
purchases and providing EV infrastructure, however the
long range GHG benefits of EV is highly industry and
customer dependant. In October of this year we will be
announcing a MassDOT Mode Shift Goal with
implementation strategies.
4
I want to see the South Coast Rail up and running with an electric engine.
GreenDOT Open House Add new Indicator under Air theme: The feasibility of
New Bedford
electric commuter rail locomotives studied within the
Commuter Rail Master Plan
5
Policies to enhance coordination with community transportation services (often state or federally
funded) to decrease duplication, increase ride sharing + decrease gas emissions + congestion
GreenDOT Open House MassDOT is convening a Statewide coordinating
New Bedford
council on community transportation and the comingling paratransit services will be explored.
6
B20 Biodiesel is incompatible with Becket oil burners that are commonly used on MassDOT hot
mix asphalt boxes
GreenDOT Open House Thank you for your comment. Your comment will be
Worcester
forwarded on to the applicable department within
MassDOT's highway division.
7
Connect with local communities and law enforcement. Carrots and Stick. Offer discounts for high GreenDOT Open House Add new indicator in Air theme: Outreach program
public transportation users. Enforce existing fines for those who don't meet emissions idling, etc. Worcester
established in partnership with EEA to increase
standards.
customer education of idling laws.
Page 11 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
8
BEAT supports MassDOT efforts to improve statewide air quality and reduce
greenhouse gas emissions.
Berkshire Environmental Thank you for your support. MassDOT will be working
Action Team
with the leadership of EEA toward measuring GHG
reductions attributable to the relevant policies in
GreenDOT, including efforts to curb VMT growth. Some
of the GHG reduction within the transportation sector
rely on initiatives such as Smart Growth development,
improved driving behavior, and the purchasing more
fuel efficient vehicles by our customers, which MassDOT
can support but does not directly influence.
9
Initiate a Carpool Week / Day similar to Transit Day to encourage employees to try this experience GreenDOT Open House MassDOT through our MassRides program sponsors a
and get out of their SOV
Amherst
Car-free/Car-light Week in September. The car-free
incentive programs track both transit and carpooling as
carfree activities. Visit:
www.mass.gov/MassDOT/CarFree
10
Require a % of employees to telecommute at least once per month
11
Design vegetation buffer zones between crosswalk waiting areas and vehicles cueing at the traffic GreenDOT Open House Thank you for your feedback. Adding vegetation to the
Amherst
complete street design guide is a potential element of
lights to reduce ground level pollution caused by auto tailpipes & inhaled by pedestrians
the Complete Street revisions to be undertaken in 2013.
12
Enforce 5-min idle laws! - or require immediate shut off.
GreenDOT Open House Add new indicator in Air theme: On + off-road antiAmherst
idling policies are included in all construction and
service contracts.
13
Support compact development regulation to reduce commuter distances
GreenDOT Open House On October 9th, Secretary Davey announced
MassDOT's Mode Shift Goal of tripling bicycling, transit,
Amherst
and walking by 2030. We will add the new Mode Shift
goal with tasks and indicators, within the Planning,
Policy and Design theme of the Implementation Plan.
14
Have commuter & subway passes for employee use for work purposes
GreenDOT Open House Thank you for your feedback no proposed revision to
Amherst
the plan at this time
Page 12 of 74
Response and Proposed plan revisions
(if applicable)
GreenDOT Open House Thank you for your feedback. MassDOT will explore
Amherst
methods such as this suggestion to promote the
concept of telecommuting.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
15
2012 has been the hottest year on record in the United States.2 Over 40,000 daily heat records
have been shattered since the start of the year.3 According to the National Oceanic and
Atmospheric Administration (“NOAA”), “[t]he Northern Hemisphere land and ocean average
surface temperature for June 2012 was the all-time warmest June on record, at [ ] 2.34°F above
average.”4,5 Globally-averaged land surface temperature for June 2012 was also the all-time
warmest June on record, at 1.93°F above average. Fifty-five percent of the United States currently
is under moderate to extreme drought conditions, and recent heat waves have led to extensive
crop failures. All of these patterns are consistent with modeled projections of climate change
impacts. The adverse effects of climate change on human health, our economy, the ecosystems
that sustain us, and earth’s biodiversity are accelerating, and the need to reduce greenhouse gas
emissions (“GHG”) is increasingly urgent. The transportation sector in Massachusetts is the
largest and fastest growing source of GHG emissions; it is imperative that the Commonwealth act
now on its plans for a transportation future that emits far fewer emissions.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Add task in the Materials theme: Design new urban
roadways and surface parking lots to maximize shade
coverage of asphalt and concrete surfaces.
16
The Climate Plan emphasizes the GreenDOT requirement that project selection be prioritized on
the basis of GHG emissions analyses, and healthy transportation and smart growth impacts. See
Climate Plan at 66. Neither GreenDOT nor the Climate Plan specify how GHG emissions will be
evaluated by planners, or how transportation plans will now be developed in order to take into
account—and achieve—the Commonwealth’s overall GHG emissions reduction target.
Independent of these state law requirements, federal law governing transportation planning also
provides authority for accounting for GHGs in transportation planning, and is consistent with the
Commonwealth’s climate policy. For example, 23 U.S.C. 134(a) provides that it is in the national
interest to “encourage and promote the safe and efficient management, operation, and
development of surface transportation systems that will serve the mobility needs of people and
freight and foster economic growth and development within and between States and urbanized
areas, while minimizing transportation-related fuel consumption and air pollution through
metropolitan and statewide transportation planning processes. . .” (Emphasis supplied).
Transportation 4
Massachusetts /
Conservation Law
Foundation
Page 13 of 74
For the first time, MassDOT requested this year that
MPOs determine the GHG impact of capital projects as
part of the annual Transportation Improvement Program
(TIP) development process. All of the Commonwealth’s
thirteen regional TIPs have now been adopted for
Federal Fiscal Year 2013-16 and GHG impacts have
been projected where appropriate in each document
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
17
On the whole, however, the Plan is primarily focused on operations and procurement strategies.
GreenDOT projects a reduction of 7.3 percent below 1990 levels by 2020 resulting from a mix of
activities that is broader in scope than operations and procurement. See GreenDOT at Exhibit A.
As set forth above, GreenDOT provides that it “will be driven by three primary goals: reduce
greenhouse gas emissions; promote the healthy transportation options of walking, bicycling, and
public transit; and support smart growth development,” and includes a substantial focus on
transportation planning and project prioritization and selection. See id., at 1; id. at Exhibit B. Yet,
the Plan’s “Planning Policy + Design” section is silent on specifics with respect to how MassDOT
will work with the MPOs to model and account for GHG emissions in the planning process, and
how those data will influence the project selection process. As a result, over two years after
GreenDOT was issued in June 2010, MassDOT has yet to clearly articulate to the public exactly
how “GHG impacts [will be] considered in making project selection + funding priorities,” let alone
integrate GHG emissions data into the project selection process.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Page 14 of 74
Response and Proposed plan revisions
(if applicable)
been projected where appropriate in each document.
Through the weMove Massachusetts multimodal
strategic planning initiative, MassDOT will be using
scenario planning to prioritize the programmatic
investments we make for our transportation system.
GreenDOT Implementation Plan will factor into the
scenario planning effort.
Feedback + Responses
Reference
number
Comment
18
While the 77-page Plan is very ambitious, it is not fiscally constrained, and there are no data
regarding the GHG emissions reductions MassDOT anticipates that the individual activities
described in the Plan will yield, annually or otherwise. Given that MassDOT’s budget may be
insufficient to implement all of these activities, data regarding the relative effectiveness of each of
the strategies in reducing GHG emissions would be helpful in assisting MassDOT to prioritize the
Transportation 4
tasks identified in the Plan.
Massachusetts /
Additionally, without some understanding of the potential GHG emissions reductions potentially
Conservation Law
achieved, MassDOT and the Commonwealth will be unable effectively to gauge whether, in fact, Foundation
MassDOT is on target to accomplish the 7.3 percent reduction by 2020 set forth in GreenDOT. As
it finalizes the Plan, we encourage MassDOT to bring a laser-like focus to implementing those
tasks that have the greatest likelihood of achieving or exceeding the target reduction by 2020 and
that are likely to be funded, or yield a cost savings, to the Agency.
We will be finalizing the GreenDOT Plan using input we
have received during our comment period and then
asking our Administrators to provide work plans
addressing their Division’s responsibilities that are
identified in the Plan. These Division work plans will
provide specific strategies for each task and its
indicators. It will be through the development of these
work plans that we will be able to develop cost
estimates for the Plan.
20
Climate change issues “span boundaries of geography and jurisdiction. Many agencies recognize
that multi-agency action has the greatest potential to incorporate climate change into
transportation planning.”8 As MassDOT endeavors to finalize the Plan, we encourage the Agency
to reach out to other Massachusetts state agencies also engaged in efforts to reduce emissions,
including transportation emissions. For example, the Plan identified a number of activities related
to electric vehicles, including installing electric vehicle charging stations “along northeast corridor
routes.” Plan at 15. Commenters support MassDOT’s efforts to advance electric vehicle
infrastructure; to make those efforts successful over the long term, however, MassDOT should
actively confer with the Executive Office of Energy and Environmental Affairs and the Department
of Environmental Protection. Because there are a number of regulatory issues involved, broad
adoption of electric vehicles turns on coordinated agency action. Massachusetts is one of a
number of Northeast states working hard to identify how best to advance electric vehicles and we
encourage MassDOT to take into account, as well, the opportunities presented by the Northeast
States’ Transportation and Climate Initiative (“TCI”)—and other opportunities—for regional
coordination.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Thank you. We are actively engaged with EEA and DEP
on these matters.
21
The GreenDOT Implementation Plan should make clear how these GHG emissions data will be
used as a criterion for prioritizing and programming projects in future TIPs. To the greatest extent
possible, GHG emissions data should be used now to begin to prioritize and program the TIPs.
Transportation 4
Massachusetts /
Conservation Law
Foundation
See response to comment numbers 16 + 17 above
19
Page 15 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
22
According to the Boston Region MPO, carbon dioxide emissions currently are calculated by
multiplying vehicle miles traveled (“VMT”) “associated with a particular transportation network
(expressed as daily VMT) or project (expressed in annual VMT) by a CO2 emission factor for a
particular travel speed in a particular year. The emission factor is established by running an
emissions model (currently MOBILE 6.2) using various inputs provided by the Massachusetts
Department of Environmental Protection.”
Concerns have been raised by FHWA about the significant drawbacks of the MOBILE6 model for
CO2 emissions modeling, since the CO2 emission factor in that model does not vary for vehicle
speed and driving cycle.16 FHWA has therefore warned that “[f]or this reason, MOBILE6 is
inappropriate for any kind of detailed analysis of transportation plan or project-level emissions,
which are likely to involve changes to congestion levels and speeds.” The Transportation
Research Board has found that the MOVES2010 model “allows for much more sophisticated and
complex analysis of GHGs that attempts to capture effects of both speed and vehicle operating
conditions (acceleration patterns).”Commenters strongly encourage MassDOT to coordinate with
the MPOs, and particularly the large Boston MPO, to ensure that the models used are sufficiently
robust to produce accurate data to reliably inform transportation planning efforts.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Thank you for your detailed comment. MassDOT and
CTPS are currently working with Mass DEP to transition
over to MOVES in 2013. DEP has been working with the
NESCAUM states and EPA to finalize the inputs and
emissions factors that will be used for MOVES.
Page 16 of 74
Feedback + Responses
Reference
number
Comment
23
I would like MassDOT to adopt a policy that all future purchases of new buses used by the MBTA, Joel N. Weber II
Massport, and Regional Transit Agencies will be zero emissions vehicles.
While this will likely increase capital costs, it will also likely lower direct fuel expenses, and these
effects may be magnified by the federal government's tendency to contribute toward capital costs
(such as vehicles) but not directly subsidize operating costs (such as fuel).
http://www.winnipegfreepress.com/local/new-flyer-green-leader-156630045.html discusses New
Flyer's battery powered buses, and reports that Chris Stoddart, a New Flyer vice-president, ``said
when operating savings are factored in, he expects going electric "will definitely make economic
sense" for buyers throughout North America.''
The sidebar in that article mentions batteries up to 120 kilowatt hours, with a biodiesel heater used
in the winter. Given that the Tesla Model S, a 5 or 7 passenger sedan, is available with an 85
kilowatt hour battery pack, I am surprised that New Flyer has been focused on using a biodiesel
heater instead of simply using a larger battery pack. Tesla's biggest battery pack seems to be
more than 2/3 the capacity of New Flyer's biggest battery pack, but the Tesla is an awful lot less
than 2/3 the overall size of the 40 foot bus. I'd like to see MassDOT / Massport / the MBTA push
New Flyer to quote a price on a battery powered bus with a big enough battery pack that it won't
need the biodiesel heater.
http://www.hybridcars.com/news/all-electric-transit-buses-chicago-transit-authority-47680.html is
one of several articles reporting that Chicago will be getting two of New Flyer's battery powered
buses in 2013 for about $2.2 million. http://www.prnewswire.com/news-releases/hertz-first-carrental-company-to-deploy-a-zero-emissions-all-electric-bus-132478153.html describes Hertz's
use of battery powered buses built by BYD to shuttle passengers between the airport terminal and
the car rental desk in Los Angeles. (I do find it strange that all of the press on this seems to have
been just before the electric buses started service, and I have not found any follow-up articles
talking about whether or not it has
been a success.)
Page 17 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Currently the MBTA bus fleet is very diverse using
multiple fuel technologies including trackless trolleys.
GreenDOT policy urges fleet replacement to consider
highly efficient bus models without prescribing
technology. Hybrid buses have been running in the
MBTA system and are now reaching broad use across
the country, including a large investment by Massport.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
24
The draft GreenDOT plan describes "our goal of being the most sustainable transportation
Joel N. Weber II
department in the nation''. I think that's a great goal, and I'd like to see the final version of the
GreenDOT plan explain how a Hertz customer who takes a shuttle bus from the airport terminal to
the car rental desk at both Logan Airport and Los Angeles International Airport will perceive
MassDOT in this area in 2015 or 2020, and how CTA vs MBTA bus riders will see the sustainability
of their local transit agencies.
Response and Proposed plan revisions
(if applicable)
Add indicator in the Air theme: Feasibility analysis of
expanding the use of battery + fuel cell powered buses
completed.
http://www.boston.com/yourtown/news/allston_brighton/2012/07/mbta_receives_15m_federal_gra
n.html describes a $15 million federal grant the MBTA recently received to replace 30 to 35 buses.
I'd like to see MassDOT and the MBTA explore all of the options for using all of this $15 million for
zero emissions buses. Does the T have the option of simply buying fewer buses in order to be
able to afford zero emissions buses under the current terms of the agreement with the federal
government? Given the Obama administration's goal of getting a million plug in vehicles on the
road by 2015, which is unlikely to be achieved, if the current terms of the agreement don't already
allow this, could MassDOT negotiate with the federal government to buy fewer buses with that
money as long as buying fewer buses enables them to all be plug in vehicles? When fuel savings
are factored in, could the MBTA use the fuel savings to cover the cost of borrowing money for the
capital investment? Could federal Congestion Mitigation and Air Quality funding be used to help
fund zero emissions buses, either to cover the cost difference between traditional buses that the T
would have bought otherwise, or to increase the total number of new buses the T can afford?
25
We note that at the GreenDOT hearing held by the House Committee on Global Warming in June, Environmental League of
several legislators asked for more information on the expected emission reductions from the plan Massachusetts
and also some sense of costs associated with each action. As noted, we share the view that we
need to know more about GHG emissions from each action so we can prioritize. We believe the
costs of inaction on climate change so vastly outweigh the costs of action, that we must act. That
being said, given limited resources, we cannot ignore costs and it would be helpful in terms of
prioritizing actions and getting the most GHG reductions per dollar spent, for the plan to include
some sense as to relative costs to help us make choices and perhaps phase in actions.
Page 18 of 74
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT
seeks to craft financially feasible solutions to reach the
various goals, the pathway to implementing all the GHG
and other sustainability targets will depend on
numerous policy and budget decisions over the
upcoming years. Prioritizing investments and
developing cost/benefit and return on investment
analysis will be conducted for a large number of the
major investments described in the plan.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
26
Finally, while we understand the emphasis on actions that MassDOT has direct control over, we
need to understand whether those actions are adequate to reach the 7.3% reduction target
GreenDOT set for itself. If not, then MassDOT should articulate how it will use its influence (e.g.,
dollars, planning, MPO votes, support of legislation or regulations that would require or
incentivize certain actions) to encourage actions by others that will help us meet our target.
Environmental League of MassDOT will be working with the leadership of EEA
Massachusetts
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and
the purchasing of more fuel efficient vehicles by our
customers, which MassDOT can support but does not
directly influence.
In closing, we applaud MassDOT for setting ambitious goals and targets and we stand ready to
work with you to achieve them
27
I would like to see the final GreenDOT and YouMove Massachusetts plans address several
Joel N. Weber II
questions regarding electric vehicle charging stations:
If the driver of a Tesla Model S with an 85 kilowatt hour battery pack, which offers a 300 mile range
at 55 MPH, wants to stop for lunch to refill half their battery pack's capacity while they eat, will the
GreenDOT charging station program provide 90 kW Tesla SuperChargers that can accomplish
this in a half hour?
Likewise, if the driver of a vehicle with a CHAdeMO quick charge connector, such as some
versions of the Nissan Leaf and some Mitsubishi vehicles, wants to charge at the full rate the car
supports through its CHAdeMO connector, will drivers find a suitable charging station at
MassDOT's highway rest areas?
If a typical commuter rail rider drives a typical distance from their home to a commuter rail parking
lot in a battery powered car, are they likely to be driving far enough to need to charge the vehicle
both at home and at the commuter rail parking lot, or are they likely to have enough range to cover
the round trip on a single charge? If a single charge will cover a round trip, would it be better for
the electric grid if charging happens during day at the commuter rail parking lot, or at their home
at night?
If an electric vehicle owner drives their electric vehicle to a commuter rail parking lot and boards a
diesel powered commuter train, will that be better for the environment than simply driving the
electric vehicle all the way into downtown Boston?
If a traveler passing through Massachusetts on their way from Maine to DC spends the night in a
Massachusetts hotel, are they likely to be able to find a 240 volt charging station in the hotel
parking lot that will allow them to fully charge their battery overnight? If not, is it possible that New
Hampshire or Connecticut or Rhode Island will be more progressive in that regard and reduce
that traveler's contributions to the Massachusetts economy?
Page 19 of 74
Response and Proposed plan revisions
(if applicable)
While testing the various scenarios of various vehicle
selection and trip patterns is well beyond the scope of
GreenDOT the Implementation Plan seeks to provide
flexibility of charging technology and an appropriate
density of charging stations to accommodate multiple
trip types.
Feedback + Responses
Reference
number
Comment
28
Transportation, Smart Growth and Climate Change Mitigation and Adaptation Climate change is a Mass Audubon
major threat to people and wildlife. Mass Audubon was very active in the adoption and passage of
the Global Warming Solutions Act (GWSA), and we continue to work actively in support of strong
implementation. Transportation is a significant factor in greenhouse gas emissions (GHG), and
changes need to occur in transportation systems in order to achieve the GHG emission reduction
goals of the GWSA. The plan contains several initiatives to reduce GHG emissions, both by DOT
vehicles and facilities directly, and by the general public in their transportation activities. However,
the majority of the initiatives under GHG emissions and energy reduction are focused on DOT’s
own facilities. More emphasis could be placed on reducing emissions from private vehicular
travel, e.g. through more rapid commitments to providing electric charging stations and strong
commitments to supporting Transit Oriented Development and other smart growth measures and
telecommuting to reduce the demand for highway travel.
Thank you for your support. MassDOT will be working
with the leadership of EEA toward measuring GHG
reductions attributable to the relevant policies in
GreenDOT, including efforts to curb VMT growth. Some
of the GHG reduction within the transportation sector
rely on initiatives such as Smart Growth development,
improved driving behavior, and the purchasing more
fuel efficient vehicles by our customers, which MassDOT
can support but does not directly influence.
29
Reduce greenhouse gas (GHG) emissions: this can be attained by various shifts in travel
mode, the resulting GHG reduction depending on both the number of “participants” and which
mode is shifted:
• Walking and bicycling instead of driving or transit
• Transit in place of driving
• Cleaner transit replacing “dirtier” transit
• Car pooling instead of single occupancy vehicles
• Electric or hybrid vehicles versus traditional vehicles
• Smaller cars instead of larger cars
• Truck transport to rail travel
• And for longer distance travel (Springfield, Providence, NYC), bus or train versus private
automobile
Thank you for your support of our goals of increasing
healthy transortation choices. Efforts to expand the
capacity of rail passenger and freight travel are
underway at MassDOT. Further Mode Shift strategies
have been developed and added to the Implementation
Plan.
30
In this section on improving air quality, goals pertaining to telecommuting, electric vehicles, and
Pioneer Valley Planning
related items are identified. This goal could be further enhanced with additional goals on mode
Council
shift and getting people to choose cleaner modes of transportation, such as walking and
bicycling. We would also recommend the goal of “Reducing GHG” be elevated to the first goal on
page 12 as this is the first of the three primary goals under GreenDOT.
On October 9th, Secretary Davey announced
MassDOT's Mode Shift Goal of tripling bicycling, transit,
and walking by 2030. We will add the new Mode Shift
goal with tasks and indicators, within the Planning,
Policy and Design theme of the Implementation Plan.
31
The plan refers to the Executive Order 484 goal to reduce GHG emissions 40% by 2020, yet the
only implementing MassDOT division identified as responsible for tracking GHG is “Shared
Services.” We would recommend integrating the GHG emissions tracking and estimation into
each implementing division to increase awareness of the importance of this goal. All regional
planning agencies (RPAs) currently assist MassDOT in performing the required Greenhouse Gas
emissions for transportation improvement projects. We would request that current consultation
procedures between MassDOT and the RPAs remain in place and be enhanced through
GreenDOT.
Thank you for your support
Page 20 of 74
Commenter
(if known)
MassPIRG, Livable
Streets, On the Move
Pioneer Valley Planning
Council
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
32
We would recommend that additional language be added to the plan to support the use of new
Pioneer Valley Planning
technology to monitor greenhouse gas emissions at key locations through the state. PVPC is
Council
currently working with the University of Massachusetts, Amherst to utilize a greenhouse gas
monitor to track emissions in our region. This information could be very useful in the development
of performance measures and assist in the advancement of the goals of GreenDOT.
MassDOT will continue to work with our partners at the
RPA's to monitor GHG emissions throughout the state.
33
Decrease Engine Idling: ABC strongly supports increased initiatives to enforce existing idling laws A Better City
and reduce the air quality impacts associated with idling. ABC recommends that MassDOT work
with the MBTA and RTAs to purchase and install anti-idling signage at all park & ride, commuter
rail, and public transit parking facilities.
Add new indicator in Air theme: Outreach program
established in partnership with EEA to increase
customer education of idling laws.
34
Increase Use of Alternative Fuels: ABC is currently conducting a study of low/no emission fuels for A Better City
public transit vehicles. We recommend MassDOT look beyond bio-fuels for future fleet purchases.
This could include hydrogen fuel cell technology and battery systems.
Add indicator in the Air theme: Feasibility analysis of
expanding the use of battery + fuel cell powered buses
completed
35
Increase Telecommuting: ABC applauds the goal to expand telecommuting and flex time as an
option for employees by 2013. This will enable the state to lead by example as we work to
encourage the private sector to implement and expand their own telecommuting and flex time
policies.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
36
Improve Traffic Controls to Reduce Vehicle Emissions and Support Walking/Biking ABC supports A Better City
the proposed efforts of MassDOT to inventory all traffic signals and grade crossings, optimizing
the operations of the signals, installing pedestrian countdowns, and evaluating and adjusting
signals for optimal operations for all users. However, we encourage MassDOT to move up its time
frames for completion of this work to 2015.
A Better City
Response and Proposed plan revisions
(if applicable)
We will track progress on these indicators as we go but
were unable to committ to evaluating and retrofitting 'all'
intersections and corridors by 2015. Please note that
we have added an interim indicator in Planning theme:
Pedestrian countdowns installed at 50% of MassDOT
intersection with crosswalks to be completed by 2015
37
MAPC also recommends an indicator be added under the task “Track progress toward statewide Metropolitan Area
GHG reduction + other sustainability goals” in the Air chapter. MassDOT should cumulatively
Planning Council
measure the degree to which all projects in the Long Range Transportation Plans and Statewide
Transportation Improvement Plans are contributing toward the GHG reduction goals set out in the
2010 GreenDOT Policy Directive. We believe that such a cumulative measurement of progress is
required not only by GreenDOT, but also by the Massachusetts Clean Energy and Climate Plan
for 2020. It is critical that these planning documents identify how the suite of transportation
projects will or will not position the Commonwealth to attain its goals.
Add indicator in the Air theme: Cumulative progress
toward statewide GHG reduction goals is projected
annually in STIP utilizing the best available tools
38
Decrease volatile organic compound discharge from facilities - In addition to reducing VOCs
consideration of A/C and refrigerant pollution - Chlorofluorocarbons (CFCs)should be added.
Please see Indicator under Waste regarding refrigerants
on page 65
Page 21 of 74
Cape Cod Commission
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
39
Increase telecommuting + meetings by web conference
Cape Cod Commission
Thank you for supporting this goal
40
Reduce emissions from maintenance + construction equipment - Include biodiesel
Cape Cod Commission
Biodiesel is a component of the GHG measures - we
recognize the overlapping nature of this indicator and its
applicability to multiple goals.
41
Increase efficiency of transportation systems operations - Rail efficiency - a study of the run times Cape Cod Commission
was done and significant padding in the schedule was found including outdated speed
restrictions (e.g. Chelsea) the schedule times should be re-evaluated and strategies such as the
suggested reduction in dwell times be considered to reduce travel times and make service more
efficient.
Thank you for your comment. Your concern will be
documented for the Rail and Transit Division for
consideration in the development of their annual
GreenDOT Work Plans.
42
Applications for Diesel Multiple Units (DMUs) should be considered, especially in off peak periods Cape Cod Commission
where running full consists does not make sense.
MassDOT has looked at DMU's in the context of
different projects. We continue to consider them as we
look at commuter rail service for the Commonwealth.
43
Increase use of alternative + renewable fuels - Current state laws prohibit the sale of ethanol
(85%) fuel due to a lack of vapor recovery methods. Massachusetts transportation agencies
should get a waiver (which has been granted to the few ethanol stations operating in
Massachusetts) for their fueling facilities and include more flex fuel vehicles in the fleets.
Cape Cod Commission
44
Provide related incentive programs like TMAs for public employees to carpool, take transit, or
reduce trips.
Cape Cod Commission
45
Electric Vehicle Charging: Lastly, ENE is particularly keen to work with MassDOT to share ideas
ENE
related to electric vehicle charging, in particular the need for public charging vs. support for home
charging and the associated costs and benefits.
Page 22 of 74
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
1
Incentives / contests for biggest energy reduction
GreenDOT Open House
Worcester
Response and Proposed plan revisions
(if applicable)
Add indicator in the Energy Theme on employee
education: Employee education and incentive programs
established to encourage energy use reduction.
2
Incentives for employees for energy savings at work and at home
GreenDOT Open House
Worcester
3
Fuel switching? Biofuels
GreenDOT Open House Thank you for your feedback.
Worcester
4
BEAT supports MassDOT efforts to consume less energy and increase reliance on renewable
energy. We would stress that careful siting of renewable energy facilities is critical. New energy
facilities must not be allowed to further fragment wildlife habitat. Placing them along or near
existing large highways may be a reasonable solution to avoid further fragmentation.
Berkshire Environmental Thank you for your feedback although no revision to the
Action Team
plan are proposed at this time your comments will be
forwarded to the Energy Initiative team.
5
Keep up with European cities that are progressive with their alternative transport systems
GreenDOT Open House Thank you for your feedback.
Amherst
6
Push for electric and solar powered vehicles and other alternative energy vehicles, and transport
systems for middle class and lower income families.
GreenDOT Open House Thank you for your feedback.
Amherst
7
Renovate bldg. to have occupancy lighting
GreenDOT Open House Revise Indicator on motion sensory lighting to also
Amherst
reference Occupancy lighting.
8
My understanding is that the most common form of colorblindness is the inability to distinguish
Joel Weber
red from green. Given that, the colors used in ordinary traffic signals are somewhat unfortunate. I
would like to see MassDOT explore what level of difficulty typical people with red-green
colorblindness have interpreting traffic signals, and whether changes could be made to make
traffic signals more accessible to people with colorblindness. For example, would a blue dot in the
middle of a green light help people with red-green colorblindness, without causing excessive
confusion for those with normal vision not accustomed to the change? Would using an octagon
(the shape of a stop sign) for red traffic lights help people with colorblindness? Do non-standard
layouts cause confusion with interpreting the meaning of signals by their position? Would it be
appropriate to have a standard that traffic lights must be red above yellow above green, always
with three lights in the stack? Should horizontally mounted traffic signals and traffic signals with
green right turn arrows below green circles or green straight arrows phased out?
Given that GreenDOT is proposing to replace many traffic lights with LED fixtures, it would be ideal
to coordinate any colorblindness accommodation efforts with energy efficiency efforts, to avoid
having to replace a single fixture more than once.
Page 23 of 74
The FHWA's Manual on Uniform Traffic Control Devices
(MUTCD) aims to make all traffic signals in all
communities appear uniform, with the red signal above
or to the left of the yellow signage. LED replacement will
follow established lighting levels and colors as set by
ITE. Recently the green has been specified to be a bit
more "blue-green" because this makes it easier for
persons with red-green color vision deficiencies to
distinguish it from red. Further discussion of this issue
can be found at
http://mutcd.fhwa.dot.gov/knowledge/faqs/faq_part4.ht
m#q24 No proposed revision to the plan at this time.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
9
Commenters strongly support MassDOT’s commitment to coordinate with other state agencies on
bulk purchasing of a “green electricity portfolio.” Plan at 25. MassDOT and the agencies should
ensure that such green electricity sources satisfy the eligibility criteria set forth in the
Commonwealth’s renewable energy portfolio standard. See 225 C.M.R. 14.05.
Transportation 4
Massachusetts /
Conservation Law
Foundation
Add references to renewable energy portfolio standard in
into goal description.
10
Specifically, we are pleased to see the actions outlined to reduce greenhouse gas emissions
(pages 14-17) and to consume less energy and increase the use of renewable energy at
MassDOT facilities and in agency operations (pages 20-27). Given the nation-leading role the
Commonwealth is playing in this arena, it is important for the state agencies to actively move in
this direction. The specific targets you include (e.g., 10 new renewable energy projects installed
at MassDOT facilities) are welcome and will help the agency and the public track progress.
Environmental League of Thank you for your feedback.
Massachusetts
11
Recently, MAPC has been working with our member municipalities to establish local clean energy Metropolitan Area
plans. Under Chapter 30B, we have procured the services of Ameresco, Inc. to help 13 cities and Planning Council
towns reduce their energy bills, converse energy, and cut GHG emissions. MAPC is also
cooperating with the Operational Services Division (OSD) to procure a bulk purchase of LED street
and outdoor lighting for municipalities and state agencies. MAPC would be happy to coordinate
these efforts with MassDOT to achieve cost and energy savings under the GreenDOT goal of
consuming less energy.
Thank you for your suggestion. MassDOT will explore
the possibilities for joint procurement between Highway
Districts and municipalities for the purchasing of highefficiency street lights.
12
Is that really all there is to it because that'd be flabbergasting.
Comment via email
Thank you for your feedback.
13
Reduce building electricity use - The building envelope including windows and doors is the most
cost efficient improvement strategy and a short/medium term initiative would be to comply with
ANSI/ASHRAE/IESNA Standard 90.1-2007, Section 5.4 Insulation, Fenestration, and Doors.
Cape Cod Commission
14
Add Indicator in Energy: Envelops of all buildings are
evaluated and prioritized for insulation upgrades
Compliance with ANSI standards (6.4 HVAC; 7.4 Load Calculations, Equipment Efficiency, Service Cape Cod Commission
Hot Water Piping Insulation, Service Controls, Pools, Heat Traps; 9.4 Lighting Control, Tandem
Wiring) should also be considered.
15
Incorporate passive solar design and retrofit, especially for hot water heating systems.
Cape Cod Commission
16
Participate in MassDOT Energy Initiative - No mention of wind energy other than the CCRTA
example however solar is called out specifically.
Cape Cod Commission
Page 24 of 74
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
Add new energy indicator: Feasibility study completed
for additional wind power generation sites on MassDOT
properties
Feedback + Responses
Reference
number
Comment
1
A major concern of mine is grassy highway dividers. Instead of producing a need to mow by
Emily Johns
planting grass, why don't we sow wild flower seeds which will sustain themselves. I didn't see a
plan for this the other afternoon, (and of course, there may well have been such a plan on one of
your charts - I didn't get to three of them, I think. This practice would be a logical Green Dot
initiative, given the *lowered maintenance, *lowered green house gases from power lawnmowers;
*the fact that it facilitates the reintroduction of animal and insect habitats to the landscape; *and
adds incredible beauty!, and life!!! to the concrete desert highway hardscape-; Even planting just
clover would be a big improvement over grass!; I remember driving thru PA twenty years ago and
the plantings were phenomenal in the divider strips. NO mowing needed!
2
There are some actions we would like to see MassDOT take that we don’t think have been
Berkshire Environmental Add new indicator in Land Theme: Wildlife +
mentioned:
Action Team
endangered species training program provided for
applicable employees.
1. Provide training for all staff, but especially field workers, on Massachusetts’ fascinating wildlife!
Have the Massachusetts Natural Heritage and Endangered Species Program(NHESP) staff
and/or Non-Governmental Organizations (NGOs) take MassDOT staff out to find and talk about
wildlife. Get acquainted with interesting species and feel the passion wildlife biologists have for
these really cool animals.
2. Provide similar training about invasive species – what the problems are, how to recognize, how
to remove and dispose of – and what other organizations can help.
3
Federal money is available for projects to prevent wildlife/vehicle collisions. Other states have
Berkshire Environmental Thank you from your comment.
taken advantage of this, and we believe Massachusetts can as well.
Action Team
http://www.azgfd.gov/w_c/StateRoute_260_Elk_Crosswalk.shtml Please see the highlights of the
new transportation bill listed at the end of our comments.
4
Institute washing protocols for machinery to prevent the spread of invasive plants and their seeds.
5
In the short-term, work with the Massachusetts Department of Fish and Game and NGOs to
identify road segments that are important places for wide-ranging mammals (especially the large
ones) to use to cross major highways in the Commonwealth, and then design ways to have these
Thank you for your comment. Your suggestion will be
animals cross safely. In the long-term, allow the full suite of ecological functions across roads by Berkshire Environmental documented for the MassDOT Divisions for
providing regular connections for ecosystem continuity across roads.
consideration in the development of their annual
Action Team
GreenDOT Work Plans.
6
Require reporting by staff of wildlife/vehicle interactions and mortality using gps coordinates to pinpoint locations. This will provide essential data for biologists as well as MassDOT and could be
useful in securing federal funding for road improvements.
Page 25 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
GreenDOT has many measures to implement more
natural highway ROW which could enhance scenic value
and reduce mowing operations. There have been some
questions over the sustainability of some available
wildflower seed mixes, but we will investigate better local
/ native wildflower options for roadside development
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
7
Work with Tom Tyning, herpetologist at Berkshire Community College, to design a way
to keep rare snakes off Route 91 and to improve their habitat along the road.
Berkshire Environmental Thank you for your comment. Your suggestion will be
Action Team
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
8
Maintain airport lands for native grassland species or as early successional habitat where
shrubby and early tree growth would be acceptable.
Berkshire Environmental Various airports have included habitat area on their
Action Team
property. Airports do need to be cautious to avoid
attracting large birds that present a hazard to aircrafts.
9
Mowing practices - Raise mower blades in all turtle habitat (not just for rare species). It would be
great to have staff really excited about protecting turtle habitat. These are such interesting
animals! Time mowing of grassland habitat to allow fledging of young birds.
Berkshire Environmental Add new indicator in Land theme: Mower blades raised
Action Team
in turtle habitat areas + areas contiguous with natural
areas as standard operating procedure
10
Project Forms and databases should be updated to include wildlife accommodation measures,
and Project Development and Design Guide updated to include wildlife accommodation not just
at stream crossings.
Berkshire Environmental Add new indicator in Land theme: Project Forms revised
Action Team
to include wildlife accommodation measures early in
design review.
11
p 34 – Please consider the feasibility of wildlife crossings – or perhaps ecosystem linkages - in
every project. Not only might this help keep common species common ( goal in our state wildlife
action plan), but also it would increase resiliency by helping ecosystem connectivity across our
transportation system. So when a road will be well above a depressed area on either side,
consider adding as large a passage under the road as possible to link the ecosystem on either
side. In the last box concerning wildlife fencing, please add “and maintained” – evaluated,
installed, and maintained
Page 26 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your concern will be
Berkshire Environmental documented for the MassDOT Divisions for
consideration in the development of their annual
Action Team
GreenDOT Work Plans
Feedback + Responses
Reference
number
Comment
12
The New Transportation Bill BEAT is very excited about the 2012 Two-Year Transportation bill.
Berkshire Environmental
Here are some highlights that show how it benefits wildlife and connectivity. ( put together by
Action Team
Conservation Northwest http://www.conservationnw.org/news/updates/transportation-bill-keepswildlife-and-motoristssafe) A new program, Transportation Alternative (replacing the earlier,
Transportation Enhancements program) continues to fund actions to "reduce vehicle-caused
wildlife mortality or to restore and maintain connectivity among terrestrial or aquatic habitats.’’ The
program will receive $800 million in federal fiscal year 2013, nationwide. For the portion reaching
Washington state, half goes to local communities and priorities and the other half to the state for
distribution to projects in a competitive process yet to be defined. For areas of high animalvehicle collisions, this presents an opportunity to fund wildlife crossing structures, fencing, and
signage. The definition of "Highway Safety Improvement Project" – and what projects qualify for
funding – includes the "addition or retrofitting of structures or other measures to eliminate or
reduce crashes involving vehicles and wildlife." That's good news for wildlife crossing structures
like those across Interstate 90, part of the I-90 Project. The Tribal Transportation Program directs
that the use of funds could apply "to mitigate the damage to wildlife, aquatic organism passage,
habitat, and ecosystem connectivity, including the costs of constructing, maintaining, replacing,
or removing culverts and bridges, as appropriate." The Federal Lands Transportation Program
directed that the use of funds could apply "environmental mitigation in or adjacent to Federal land
open to the public" including "to improve public safety and reduce vehicle-caused wildlife
mortality while maintaining habitat connectivity; and to mitigate the damage to wildlife, aquatic
organism passage, habitat, and ecosystem connectivity, including the costs of constructing,
maintaining, replacing, or removing culverts and bridges, as appropriate."
13
Commenter
(if known)
Land and Water - The Land section of the plan has two goals: minimize energy and chemical use Mass Audubon
in maintenance, and enhance ecological performance of MassDOT impacted land. We
recommend that the goals be broader, in particular in relation to ecological impacts of
transportation systems. Transportation facilities have an impact well beyond the direct footprint.
Roads, highways and other linear transportation components fragment habitat, degrading the
ecological health and integrity of bordering land and preventing many plants and animals from
dispersing across and utilizing habitat on either side.
Page 27 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
Feedback + Responses
Reference
number
Comment
14
Roadside Maintenance: The plan also makes several commitments to improvement of wildlife
Mass Audubon
habitat along road rights-of-way including decreasing frequency of mowing and control of
invasive species. These are positive initiatives, which will require substantial changes in
operational procedures as well as training of staff and coordination with contractors. Mowing and
brush cutting regimes should also take into account the life cycles and breeding needs of animals
such as turtles and birds. To the extent feasible, cutting and mowing should be conducted at
times of year when these animals and their nests will not be impacted.
Add new indicator in Land theme: Mowing + brush
cutting jobs are scheduled around animal nesting
seasons to the maximum extent feasible
15
Early Successional Habitat: Mass Audubon’s State of the Birds
Mass Audubon
(www.massaudubon.org/StateoftheBirds) report provides a comprehensive overview of the status
of breeding and wintering bird species across the state. One of the key findings of the report is
that grassland and shrubland birds are declining in Massachusetts and throughout the region.
Loss of habitat is a major factor.
MassDOT’s land management plans can help address this issue, although habitat improvements
along roadways needs to be undertaken in a manner that also takes into account the significant
risk to birds from collisions with vehicles.
Add new indicator in Land theme: Contiguous areas of
land greater than one acre suitable for natural grassland
and shrubland habitat identified
16
Airfields provide critical habitat for grassland bird species. Several studies suggest that airports in Mass Audubon
general, if properly managed, can be important for maintaining stable breeding populations of
grassland birds (Askins 1993, Vickery et al. 1994, Kirshner and Bollinger 1996). Airports in the
primarily reforested mid Atlantic and northeastern U.S. appear to be especially important for
eastern populations of upland sandpiper (Bartramia longicauda, Osborne and Peterson 1984),
which is listed as threatened or endangered in 10 northeastern/mid Atlantic states (Houston and
Bowen 2001). Grasshopper sparrow (Ammodramus savannarum) is a rapidly declining grasslanddependent species that is also considered of immediate regional concern and is often present on
airfields. Because it is estimated that more than 90% of coastal heathlands and grasslands in the
northeastern United States have been lost since the middle of the 19th century due to
development, cultivation, and shrubland encroachment (Barbour et al. 1999), the role that airfields
play in grassland bird conservation is likely to increase.
Mass Audubon appreciates MassDOT’s commitment to habitat enhancement and improvements,
and we are willing to provide advice and input as the proposed policy and management plans are
developed.
Thank you for your support
17
Stop using round-up and other cancer-causing vegetation management techniques - mechanical Mass Audubon
vegetation management only
Some pesticide application is critical for noxious and
invasive species control. Other applications will be
minimized per the GreenDOT inidicators.
18
Encourage planting shade trees with every project to realize the benefits of improved air quality 2) Mass Audubon
reduced CO2 3)walkable/livable streets w/ shade protection & rain protection 4) extend the urban
forest connectivity to maintain habitat connectivity
Add new indicator in Land theme: Trees + other
landscaping will be emphasized in revised Project
Development + Design Guide
Page 28 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
19
There is no need for herbicide and pesticide. We need to use organic practices - Integrated Pest Mass Audubon
Management Practices
Add new text: Integrated pest management implemented
for all maintenance projects + construction site requiring
pest control
20
Emphasize existing tree protection during project construction. Not enough to just plant new
trees if existing trees are there, you can add to them.
Mass Audubon
Add new indicator in Land theme: Mature, healthy tree
preservation is maximized in maintenance and project
design where feasible
21
Use wildflowers more frequently on MassDOT ROW - esp. on interstates - then make sure
maintenance staff is aware of the change (don't mow the flowers!)
Mass Audubon
Thank you for your feedback, see response to the first
comment above.
22
We would recommend the use of performance measures within indicators wherever possible. A
good example would be after the installation of habitat improvement features, such as peregrine
nesting boxes and wildlife tunnels. This can be done in partnership with scientists as a follow up
to understand the effectiveness of this project and derive lessons that would inform subsequent
projects for habitat improvement.
Pioneer Valley Planning
Commission
Thank you for your comment. Your suggestion will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
23
Under the task of “Require intelligent use of herbicides…” we would recommend including
Pioneer Valley Planning
organic landscape practices training so that employees can be trained in the no-pesticide and no- Commission
herbicide land management strategies. We would also recommend adding “Reduce or eliminate
use of all herbicides wherever possible.” It would be helpful to clarify what is meant by “traditional
herbicide use,” as organic land management strategies become the norm of sustainable
practices.
Add new indicator in Land theme: Ongoing training for
MassDOT employees + technical assistance for
municipalities conducted on organic / IPM landscape
practices established
24
Under the task of “Decrease area, frequency of land mowed,” we would recommend adding the
replacement of mowing equipment to seek no/low petroleum use options and/or no/low
emissions. This would tie into current objectives under Materials as well as Air.
Add new indicator in Air theme: Electric and/or full
exhaust cycle motors replace 2-stroke mowing, cutting,
and blowing equipment
25
In meeting indicators under the task of “Protect, preserve + enhance woodland + urban tree
Pioneer Valley Planning
coverage,” we recommend adding the introduction of opportunities to improve stormwater
Commission
management in the urbanized environment. The planting of 100,000 trees along roadways as part
of Complete Streets practices, for example, could have a positive multiplier effect when combined
with improved stormwater management along roadway right-of-ways.
Add new indicator in Water theme: Stormwater low
impact design integrated into revised Project
Development Design Guide
26
Land - Implement an integrated vegetation management approach for ROWs + facilities - This
management plan should include a strategy that best manages the invasive species on site with
the minimum adverse impacts from control measures.
Cape Cod Commission
Add new indicator in Land theme: Invasive species
control on sites are managed with the minimum adverse
impacts on other species
27
Require intelligent use herbicides + pesticides in construction + maintenance - Should include
fertilizers and nitrogen loading restrictions in this section especially in zones of contribution for
drinking water supplies. Water supply impacts have not been well addressed in this section.
Cape Cod Commission
Add new indicator in Land theme: Soil augmentation
utilize organic landscaping techniques and minimize
nutrient loads to water supplies
Page 29 of 74
Commenter
(if known)
Pioneer Valley Planning
Commission
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
1
I notices on page 36 that our transit center was listed as the Franklin County Transit… it should
read the John W. Olver Transit Center
Franklin Regional
Transit Authority
Substitute: John W. Olver Transit Center
2
Green facilities - define green building standards, coordinate above with DOER
GreenDOT Open House Green building standards are evolving, and while LEED is
Worcester
the most common, there are other standards to be
potentially used by the state. LEED is the current
standard in EO 484 and many city building codes. We
will continue to partner with our sister agencies on this
topic.
3
EPP - what standard will be used for purchasing program?
GreenDOT Open House EO 515 created an office which has set forth standards Worcester
will add reference
4
p 36 – Materials – BEAT supports MassDOT efforts to purchase environmentally preferred
products, improve life-cycle impacts of investments, and build green facilities for MassDOT.
Berkshire Environmental Thank you for your support
Action Team
5
p 47 – We applaud your inclusion of Zero Net Energy Building as a goal, and believe this is much Berkshire Environmental Thank you for your support.
preferable to all LEED Gold and that the LEED reference should be dropped. The state's Zero Net Action Team
Energy standard has not been developed yet.
6
How do these guidelines affect leased offices and facilities? Especially when building manager
GreenDOT Open House To the maximum extent possible MassDOT offices
does not provide green approaches to maintenance and cleaning supplies. It possible to present Amherst
should follow the GreenDOT procurement and recycling
tasks, and work to revise leasing arrangements when
this as a requirement for third parties in this case?
applicable to reflect these goals.
7
I also respectfully request that the DOT consider the increased purchase of recycled rubber
Senator James Eldridge
shingle asphalt for road paving in its final Implementation Plan as a means of smart growth
development. Innovative companies such as Liberty Tire in the Town of Ayer in my district are
beginning to recycle scrap tire and use recycled tires to create asphalt rubber. Use of recycled
rubber shingle asphalt for road paving offers a greener alternative to traditional asphalt concrete,
creating savings in energy and natural resources through the use of waste products. Importantly,
it also increases road safety as the carbon black in the rubber keeps pavement darker longer,
increasing the contrast between pavement markings and the rubber. Finally, recycled rubber
shingle asphalt can be engineered based on climate conditions and has more elasticity and
viscosity that asphalt. It therefore is more durable and cracks less easily, saving the state, towns
and cities in road repair costs. I ask that the Department give thoughtful consideration to
increased purchase of recycled rubber shingle asphalt as it considers the final GreenDOT
Implementation Plan.
Page 30 of 74
MassDOT’s draft GreenDOT Implementation Plan calls
for the application of additional sustainable materials into
our construction projects. MassDOT is undertaking pilot
projects to test out rubber shingle asphalt and have
indentified a project along Interstate 95 in Lexington to
use this material. Once we have applied in the field then
we will be able to determine whether this product is a
long term and viable option here at MassDOT.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
8
It is unclear to what extent the RPA’s will need to follow GreenDOT initiatives in their procurement
procedures. RPA’s who lease their offices have less control over the overall management of the
premises and materials chosen by the building manager for maintenance and grounds upkeep.
Environmentally preferred products and sustainable building maintenance processes may be
negotiated with the building managers up to a certain extent. Additional information for this
strategy would be helpful.
Pioneer Valley Planning Language has been added clarifying the applicability of
Commission
GreenDOT to RPA's. To the extent possible RPA's should
follow the GreenDOT procurement and recycling tasks,
and work to revise leasing arrangements when applicable
to reflect these goals.
9
Materials - Implement an environmentally preferred materials purchasing program
Specify Environmental Protection Agency Consumer Product Guideline (CPG) designated
recycled products.
Cape Cod Commission MassDOT will research the compatibility between
Environmental Protection Agency Consumer Product
Guideline (CPG) + OSD guidelines as they relate to
MassDOT divisions.
10
Reduce water consumption with water-efficient products, such as WaterSense certified products. Cape Cod Commission
11
Use biodegradable hydraulic fluids and lubricants like soy-based lubricants, and other
BioPreferred products.
12
Purchase energy efficient equipment - Replacement of electronic appliances should be based on Cape Cod Commission Add to existing indicator: Add Energy Star or Electronic
the Electronic Product Environmental Assessment Tool (EPEAT) recommendations.
Product Environmental Assessment Tool (EPEAT)
electronic products
13
Reduce energy inputs into paving operations - This may be a new section but there are a lot of
techniques for fuel efficient roadway design e.g. a pavement that remains stiff and resistant to
deformation will be more fuel efficient compared to a pavement that deforms.
14
I am very proud of MA DOT no longer using hot mix asphalt for state projects. The heavy release Emailed comment
of PM2.5 and CO2 from HMA production, and the intensive use of fossil fuels to produce it, are
anathema to your goal of leading the nation in clean air. Thank you for your courage and
dedication!
Page 31 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your concern will be
Cape Cod Commission documented for the MassDOT Divisions for consideration
in the development of their annual GreenDOT Work Plans.
Cape Cod Commission Add to existing indicator: Research to increase the
recycled content, reduce energy input, and improve
vehicle efficiency into paving completed
Thank you for your support.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
1
Plan fails to meet goals. Road projects to encourage cycling and walking have no data to show
fuel and GHG is reduced more than increased via construction, materials, road features which
cause vehicle slow downs and speed ups, and added traffic congestion. I suspect most bicycle
initiatives create more pollution than they could ever save. You have no cost benefit data to
support reducing transportation mobility and increasing economic costs. Please supply.
Mark Kaepplein
FHWA has a collection of reports regarding the
environmental benefit of bicycling and walking:
http://www.fhwa.dot.gov/environment/bicycle_pedestrian
/resources/data/benefits_research.cfm
2
Multi-modal in Mass. has come to mean reduction of vital motor vehicle lanes to shoe-horn in
Donna Janis
bike lanes. MassDOT has been co-opted by bike-centric individuals in leadership positions. I'm
astonished to see motor vehicle lane reductions on key Boston emergency evacuation routes.
Did it occur to you that bicyclists--2% of vehicle traffic at best--can dismount and WALK across a
bridge rather than your decision to surrender travel lanes to add a bike lane? I am shocked to see
bike lanes that leave the curb and cross into traffic with cars then moving on both sides of the
bicyclist as was done on Commonwealth Ave. in Kenmore Square. Did MassDOT what will
happen when it snows, as it does for half the year here? Drivers who can't see a snow covered
bike lane won't be expecting a cyclist to swerve in front of them. Some concepts are better left for
California.
Thank you for your comment. MassDOT values all
modes of travel and aims to advance a safe multi-modal
transportation system.
3
I was at one of the presentation/discussions about Mode Shift goals and was wondering where
Wanen Severe
these goals will be incorporated into GreenDOT policy (since they actually impact so many
things), in the Policy, Planning section? I guess the mode shift goals will be included in a future
version of the GreenDOT Implementation Plan since the draft you're circulating now has comment
deadline of August 2 and does not include Mode Shift goals?
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
4
We need bus racks like the ones at the bus terminal. More bike racks on buses. More places to GreenDOT Open House
serve bikes
New Bedford
GreenDOT includes an indicator to place bike racks on
all buses and increase bike racks installations in all
regions
5
How about a bus pass for Sunday and holidays like years ago? Maybe a dollar or 2 where you
could ride all day.
The need for additional resources for the RTAs was
identified as part of the recently completed Beyond
Boston Statewide Transit Study. Fare policy was one
area discussed as an opportunity for RTAs to generate
additional revenue. Discounted bus passes or free rides
would create an additional revenue burden on the RTAs.
Page 32 of 74
GreenDOT Open House
New Bedford
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
6
Considering the new federal transportation (MAP-21) program has NO dedicated funding for
enhancements - how do we support green projects such as bike paths, etc.
GreenDOT Open House
New Bedford
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
7
Increase transit hours of operation - nights + weekends.
GreenDOT Open House
New Bedford
8
MSAC - expanded services both area inter-connectivity + hours.
GreenDOT Open House
New Bedford
9
Does Smart Growth work with transit systems that are not running on Sundays or in the evenings. GreenDOT Open House
We need more service to do Smart Growth.
New Bedford
10
We need more buses for students; seniors; working people etc. Also to connect with the rail, to
stop pollution
Joan Pingley
MassDOT and the Commwealth's RTAs recently
completed the Beyond Boston Statewide Transit Study.
As part of the study, both MassDOT and the RTAs
agreed to work together to develop service standards,
which could include minimum spans of service.
However, state funding for RTA operations has remained
relatively flat for the past several years, making any
increase in service hours difficult. Another
recommendation from Beyond Boston was for RTAs to
periodically conduct Comprehensive Service Analyses
(CSAs), which can be an important tool in helping RTAs
understand how their service areas are changing and to
identify new services that can better respond to those
changes. See added indicator proposed below in
comment #14.
11
Also please put through the traffic enhancement plan for train service from Hyannis to Lakeville
on weekends during the summers.
GreenDOT Open House
New Bedford
Thank you for your feedback. This suggestion will be
passed along to the Rail and Transit division for review.
12
Yes, Voices for a Healthy South Coast + the YMCA want to help promote Complete Streets
GreenDOT Open House
projects all along the Southcoast. Active transportation increase health & wellness of our citizens New Bedford
Thank you for your support.
13
Expanded service to enable workers to ride bus rather than take a car - a green solution.
GreenDOT Open House
New Bedford
Add new indicator in Planning theme: All RTA's have
conducted comprehensive service analysis to improve
system connectivity + efficiency
14
We need more Complete Street training - especially for cities and towns.
GreenDOT Open House
Worcester
MassDOT will be working to provide more Complete
Street training working with the Bay State Roads
program.
Page 33 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
15
Rail Trail in West Boylston. Runs to Holden - actually. See Wachusett Greenways.
GreenDOT Open House
Worcester
Thank you for your feedback no proposed revision to
plan at this time. We will add this proposed trail
allignment to our database of proposed bicycle facilities.
16
T"Trolley Line" 9 +/- miles Lake St. in Shrewsbury to Northborough/Westborough, Park St. to 495 GreenDOT Open House
to White Bagley Road in Southborough.
Worcester
Thank you for your feedback no proposed revision to
plan at this time. We will add this proposed trail
allignment to our database of proposed bicycle facilities.
17
Worried about new federal legislation & adequate funding for bike & ped. & complete streets.
Thank you for your feedback.
18
Hi, One obvious project missing from your list of bike/ped projects is adding bike underpasses to Karen Molloy
the Charles River bridges slated to be repaired. It's a huge missed opportunity! It's really puzzling
why MassDOT has dismissed citizen advocacy for such underpasses when it obviously satisfies
several points in your list of "Design a multi-modal transportation system" goals in the sub section
: Increase total miles + connectivity of bicycle + pedestrian facilities
http://www.charlesriverconservancy.org/UnderpassAdvocacy.html It's sort of refusal that makes
one wonder whether GreenDOT is simply a PR campaign or whether MassDOT is serious about
"mode shift".
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
19
p 48 – Planning, Policy, and Design – BEAT supports MassDOT efforts to design a multimodal
Berkshire Environmental
transportation system, and to promote healthy transportation and livable communities. We
Action Team
applaud MassDOT for no longer just “accommodating” bicycling and walking, but integrating all
modes of transportation into the planning. We look forward to this way of planning to become the
rule, not the exception, and we hope we are never told again that a bike lane will not be
incorporated because the next stretch of connecting road doesn’t have a bike lane.
Thank you for your support.
20
Please, don't forget that in rural areas, dirt paths can work for many pedestrians. Bike
Berkshire Environmental
accommodations should be on-road or pervious. There should be no new impervious roads for Action Team
bicycles. BEAT would like to be very clear that “bike paths”, at least so far in the Berkshires, are
RECREATIONAL! People drive their SUVs with their bikes to the path, take the bike for a ride, then
put the bikes back on their SUV to go back home. Most bike paths in the Berkshires are really
new paved roads, often in turtle nesting habitat, and in no way meet any of the goals of
GreenDOT.
MassDOT facilities must be ADA compliant, but we have
utilized soft surfaces in many trail designs. Our Bay
State Greenway program expects to invest primarily in
trails that do indeed serve a transportation function along
with recreation.
Page 34 of 74
GreenDOT Open House
Worcester
Feedback + Responses
Reference
number
Comment
21
We believe that several of the indicators that entail research and plan updates and that are very Walk Boston
relevant to improving pedestrian access and safety across the Commonwealth should be
implemented in a timelier manner than the plan calls for. Specifically, we should not wait until
2015 to see an update of the Project Development and Design Guide or research on techniques
for reducing vehicle operating speeds. Neither of these efforts requires substantial funding, and
both of them will help to shape many of MassDOT’s project designs so we would like to see them
begin influencing designs as soon as possible.
Change from 2015 to 2013 but revise indicator to initiate
the revision, it may not get completed by then.
22
The indicators called out for traffic controls are extremely important to pedestrian safety and we Walk Boston
would like to see specific targeted percentages set for each of the three horizon years – for
example 15% to be accomplished by 2012, 50% by 2015 and 100% by 2020. Establishing this
parameter would provide the Department and the public the opportunity to see progress being
made, and will help to build the case for this investment by showing the public how much benefit
can be derived from these measures.
Add new indicator in Planning theme: Pedestrian
countdowns installed at 50% of MassDOT intersection
with crosswalks - 2015.
23
With respect to increasing the total miles and connectivity of pedestrian facilities, we would hope Walk Boston
that the identification of critical pedestrian and bicycle gaps could be shifted from 2015 to 2013.
Given the lead time required for projects to be added to the TIP and be provided with funding,
identifying gaps in 2015 would mean that many of those gaps would remain well beyond 2020.
Change from 2015 to 2013
24
How can we apply Complete Streets to rural communities?
GreenDOT Open House
Amherst
MassDOT is committed to Complete Street design based
on the roadway context - low volume rural roads may
function well as full shared use facilities. Adding
sidewalks or side paths to one side of roads can provide
safe pedestrian facilities off the roadway. Sidewalks and
bike lanes are fully appropriate in town centers and
commercial strips of rural areas.
25
Increase car sharing & car pooling
GreenDOT Open House
Amherst
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
26
Safety should be acknowledged as a goal - for all modes
GreenDOT Open House
Amherst
Safety is a primary tenet of MassDOT's mission
statement.
Page 35 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
27
Increasing transit performance is easy to implement - fund operations sufficient to demand +
provide reliable operation and use more customer info via internet sources
GreenDOT Open House
Amherst
28
Provide better funding for RTA's (forward funding), for bike/ped facilities & programs/promotion.
& support eco-driving initiatives
GreenDOT Open House
Amherst
MassDOT and the Commwealth's RTAs recently
completed the Beyond Boston Statewide Transit Study.
As part of the study, both MassDOT and the RTAs
agreed to work together to develop service standards,
which could include minimum spans of service.
However, state funding for RTA operations has remained
relatively flat for the past several years, making any
expansion in service difficult. Another recommendation
from Beyond Boston was for RTAs to meet minimum
standards in the dissemination of information to
customers. Secretary Davey also recently announced a
new challenge grant program that will award funds on a
competitive basis to RTAs proposing to make innovative
improvements to their websites or other customer
information tools.
29
Love the emphasis on Complete Streets (need more $ for this).
GreenDOT Open House
Amherst
Thank you for your support.
30
Collaboration between MassDOT + ConnDOT would be great. Both states share major trans.
Routes - let's try to get some sustainable practices going in CT!
GreenDOT Open House
Amherst
We would be happy to meet with ConnDOT regarding
GreenDOT.
31
Encourage the streamlining of the transit-commuter benefits for employees of MPO's to
encourage sustainable transport. Currently western MA employees are not able to.
GreenDOT Open House
Amherst
Thank you for your feedback.
32
Support infill and compact development patterns, regulations, reduce curb cuts, reduce parking
requirements
GreenDOT Open House
Amherst
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
33
It would be helpful to have the maps also depict transit routes and multi-use trails.
GreenDOT Open House
Amherst
MassDOT is working to include all modes in its published
materials where/when appropriate.
34
Promoting bicycle transportation / education * teach cyclists good traffic-handling technique
through programs like Cycling Savy * teach motorists to expect cyclists everywhere * teach
police about bicycle law enforcement * teach planners, engineers about good street design for
cycling (get Dan Gutrevez) to teach his course
GreenDOT Open House
Amherst
Thank you for your feedback.
35
Street Design * eliminate dangerous bicycle specific features * design for cyclists as drivers of
vehicles
GreenDOT Open House
Amherst
Thank you for your feedback.
Page 36 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
36
* make streets smaller, simpler * bicycle parking, * traffic light timing
GreenDOT Open House
Amherst
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
37
Affirm / strengthen cyclists' right to the road * remove bike bans of limited access express state
highways * public services announcements * educate police on rights of cyclists * intervene
when cyclists rights challenged
GreenDOT Open House
Amherst
We continue to promote bicycle and pedestrian travel but
also need to maintain safety for all users.
38
Sustainable streets: * make streets, highways smaller, slower, simpler "road diet" * reduce
asphalt width, lane width, # of lanes, turn radii, freeway line features
GreenDOT Open House
Amherst
39
Sustainable Streets : *wider sidewalks * depave or use alternative paving * build closer to street
* remove parking lots
GreenDOT Open House
Amherst
40
Promoting bicycle transportation - Full accommodation of bicycles on buses, trains, planes * no
boxes * no large fees * all days, times * all stations * guaranteed acceptance
GreenDOT Open House
Amherst
41
Whether as GLX Delay Mitigation, as an integral part of GLX, to support GreenDOT Goals or on Form Letter from 100+
the CPX's own merit, I urge you to fully fund the design and construct the CPX from Lowell Street Somerville Residents
all the way to Lechmere/North Point -- and not just Inner Belt. Currently the Inner Belt to Lechmere
CPX design and subsequent construction are not funded in the GLX project budget. This final
link, over the Fitchburg line tracks, to the existing paths at Lechmere/North Point is essential for
the CPX connectivity with Cambridge, Boston, and the Charles River path network. The CPX
meets SIP requirements, along with GreenDOT, Healthy Transportation Compact, and Mode Shift
goals. It is a first rate regional project with enormous environmental justice and economic
benefits that will be enduring. The CPX is in the GreenDOT Implementation Plan as part of the
Bay State Greenway Priority 100 miles, and as such should be funded in full as soon as possible.
Page 37 of 74
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Uncertainty exists about the desired terminus of the
Community Path. MassDOT has always planned to
design the Path to Inner Belt Road in east Somerville, but
some advocates would prefer that the Path travel all the
way to the Lechmere area. Minus the existence of a
North Point Bridge (which does not currently exist and is
not planned for construction), MassDOT would need to
determine an alternate way to connect the Path from
Inner Belt Road to the Lechmere area. This topic is
under consideration as part of the McGrath Highway ‘deelevation’ study currently underway at MassDOT, but no
preferred design solution has been selected.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
42
My commute through Boston is currently over 1 hour, this path (CPX) would cut that by half
Somerville resident
43
I am a Somerville resident and would definitely benefit from the Community path. It would
encourage me and my family to use the path and support local businesses. Not to mention stop
me from driving all the time.
Somerville resident
44
I bike to work everyday, and it is imperative for my financial stability for there to be more paved
Mehmetali Ahmanoly
bike highways in Cambridge/Somerville. Not to mention the fact that it is a great public resource
that enriches every neighborhood it passes through.
MassDOT is aware of the passionate public support for
an extension of the Somerville Community Path, and is
collaborating closely with the City of Somerville and Path
advocates as part of the Green Line Extension project.
MassDOT has committed tens of millions of dollars to
completing the design of the Path extension and to
constructing elements of the Path extension that will be
shared by the Path and MBTA Green Line Extension.
The extension of the Community Path is also part of the
‘Priority 100 Miles’ identified by MassDOT in support of
the Bay State Greenway network. To date, however,
MassDOT has not been able to commit to fully fund the
construction of the Path extension, given the fiscal
pressures facing the agency. MassDOT believes in the
Path extension, however, and will continue to work with
Path stakeholders to try to make the Path extension a
reality.
45
As the Federal Highway Administration (“FHWA”) has noted, “[m]any agencies cite integrated
transportation and land use planning as the most promising long term strategy for reducing GHG
emissions.”7 Developing the capacity to better understand and integrate related land use GHG
impacts into transportation planning and decision making will be critically important, but the
larger point is worth emphasizing—achieving the substantial GHG emissions reductions from the
transportation sector that are necessary is a longer term strategy driven by improved planning.
Page 38 of 74
Transportation for
Massachusetts /
Conservation Law
Foundation
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
46
The Plan should identify the specific measures MassDOT will implement to ensure that statewide
and regional long-range planning documents achieve declining GHG emissions consistent with
the GWSA. As FHWA has observed, “[I]n order to effectively reduce GHG emissions, planners
need to know current and future emissions levels and the potential impacts of various policies
and strategies on emissions.”9 While determining current and future emissions levels and
potential impacts of various strategies on emissions is complex, at bottom, to produce real
reductions, that is what is required. MassDOT needs to have a clear understanding of baseline
emissions, current emissions, and future projected emissions—represented in the same target
metric (e.g., vehicle miles traveled or GHG emissions per mile)—and MassDOT and the MPOs
should be moving toward developing models that can present alternative future emissions
scenarios so that planners can gain a better understanding of the climate impacts of various
planning proposals before making investment decisions. For example, the Southern California
Association of Governments’ Regional Transportation Plan Program Environmental Impact Report
“inventories the region’s current GHG emissions levels, outlines mitigation techniques, and
considers the impact of various planning scenarios on GHG emissions reduction
goals.”Understanding how various investment packages affect an MPO region’s—and, in the
aggregate, the Commonwealth’s—ability to meet GHG reduction targets is necessary to facilitate
smarter investment. Scenario planning is a tool that MassDOT and the MPOs could use to allow
decision makers to have the information needed to analyze the effects of various investments on
GHG emissions before making investment decisions.
Transportation for
Massachusetts /
Conservation Law
Foundation
For the first time, MassDOT requested this year that
MPOs determine the GHG impact of capital projects as
part of the annual Transportation Improvement Program
(TIP) development process. All of the Commonwealth’s
thirteen regional TIPs have now been adopted for Federal
Fiscal Year 2013-16 and GHG impacts have been
projected where appropriate in each document. Also,
through the weMove Massachusetts multimodal strategic
planning initiative, MassDOT will be using scenario
planning to prioritize the programmatic investments we
make for our transportation system. GreenDOT
Implementation Plan will factor into the scenario planning
effort.
Page 39 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
47
As well, it appears that major capacity expansion projects (e.g., the Green Line Extension) which
are included in the RTP will not be modeled independently for purposes of the Transportation
Improvement Program (“TIP”). As we understand, that means that no project level GHG
emissions modeling would be performed for large scale capacity expansions projects. We
strongly encourage MassDOT to conduct individual project-based modeling for all such major
capacity expansion projects so the public and decision makers have a clear understanding of the
emissions increase or reduction associated with each. As discussed above, ideally such
modeling would occur before decisions to invest are made; nevertheless, even where investment
commitments have been made, those data will be useful to educate the public and decision
makers regarding the climate impacts of transportation investments.
We applaud MassDOT’s efforts to monitor and evaluate the GHG emissions impacts of individual
transportation projects included in the TIP. MassDOT has stated that the “principal objective of
this tracking is to enable the MPOs to evaluate expected GHG impacts of different projects and
to use this information as a criterion for prioritizing and programming projects in future TIPs,” and
we strongly support that goal.
With respect to MassDOT’s proposed approach in connection with modeling TIP projects that do
not constitute major capacity expansion projects, we generally support the Agency’s effort to
identify categories of projects for which quantification is possible (increase or decrease
associated with certain project categories) and those for which quantification would yield an
imprecise result and therefore qualitative assumptions of no or nominal increases / decreases will
be used instead. We request more information on how MassDOT and the MPOs intend to apply
these categories; based on the illustrative project list provided in the Draft 2013-2016
Transportation Improvement Program Greenhouse Gas Monitoring and Evaluation, it is not clear
why some projects that appear similar in nature are subject to different types of GHG analysis.
Compare, for example, project 600214 (sidewalk infrastructure) receiving qualitative analysis with
project 605720 (river walk construction) receiving quantitative analysis.
The Plan should provide more specifics on how GreenDOT’s planning objectives are being and
will be implemented.
Transportation for
Massachusetts /
Conservation Law
Foundation
Thank you for your feedback. MassDOT will be working
under the leadership of EEA toward measuring GHG
reductions attributable to the relevant policies in
GreenDOT, including efforts to curb VMT growth. For the
first time, MassDOT requested this year that MPOs
determine the GHG impact of capital projects as part of
the annual Transportation Improvement Program (TIP)
development process. All of the Commonwealth’s
thirteen regional TIPs have now been adopted for Federal
Fiscal Year 2013-16 and GHG impacts have been
projected where appropriate in each document. Through
the weMove Massachusetts multimodal strategic
planning initiative, MassDOT will be using scenario
planning to prioritize the programmatic investments we
make for our transportation system. GreenDOT
Implementation Plan will factor into the scenario planning
effort.
48
Commenter's strongly support the Plan’s commitment to installing transit signal prioritization
(“TSP”) for all new traffic signals, Plan at 53, and encourage MassDOT to continue to press the
City of Boston to deploy TSP for prioritizing bus travel (not solely to eliminate bunching) and to
develop strategies to address the City’s concerns regarding the effects of TSP on traffic patterns.
Transportation for
Massachusetts /
Conservation Law
Foundation
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
Page 40 of 74
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
49
MassDOT has taken a critically important step in its commitment to setting a mode shift target in
2012, Plan at 54, and Commenter's strongly support that goal. Clearly, close coordination with
the MPOs will be necessary to achieve any such goal. A clear VMT reduction target,
complemented by sufficient investment in alternative modes and fair road pricing to encourage
shifts where alternatives exist, will be necessary elements in a successful effort to achieve
meaningful mode shifts over the longer term.
Transportation for
Massachusetts /
Conservation Law
Foundation
50
Commenter's support MassDOT’s efforts to evaluate urban high capacity roadway segments’
ability to accommodate high occupancy vehicle and bus rapid transit lanes, Plan at 55, and we
encourage MassDOT to ensure any such evaluation considers the potential for increased
congestion and associated air quality impacts.
Transportation for
Massachusetts /
Conservation Law
Foundation
51
Commenters strongly support MassDOT’s innovative Pay As You Drive pilot, Plan at 56, and
encourage MassDOT to share pilot results with other states, through the TCI or otherwise, and to
consider how the study may provide useful data regarding user acceptance of technology
necessary to implement a VMT fee system.
Transportation for
Massachusetts /
Conservation Law
Foundation
One of the key goals of the pilot PAYD program is to
develop public data and publish conclusions of the pilot
for national application.
52
Transportation’s impact on the regional economy and the environment are well established, but
the effect of transportation investments on human health is less understood, at least by the
general public. Demonstrating health impacts of projects can be a very important tool for building
support for investing in the types of transportation projects that will facilitate healthier
transportation choices and yield substantial GHG reductions. For that reason, Commenters
strongly support MassDOT’s efforts to develop a policy to analyze public health impacts of major
transportation projects.
Transportation for
Massachusetts /
Conservation Law
Foundation
We are currently piloting a Public Health Impact
Assessment (HIA) tool in the Grounding McGrath study.
The results of the pilot will benefit MassDOT and our
transportation partners.
Page 41 of 74
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Feedback + Responses
Reference
number
Comment
53
We also commend MassDOT for its goals of designing a multi-modal transportation system with Environmental League of
an emphasis on transit, walking and biking and increasing Complete Streets projects,
Massachusetts
establishing a Mode Shift goal and promoting eco-driving (pages 48-57).
54
Of course, support for more transit, walking and biking advances that goal (GHG) as could
Environmental League of
transportation planning and transit oriented development. However, we would suggest that more Massachusetts
specificity in terms of needed actions be identified and included. Some activities to consider
would be to expand the excellent work done along the South Coast rail corridor to other regions
of the state, i.e., working cooperatively with other state agencies, regional planning agencies, nonprofits, and individual communities to ensure that transportation decisions and investments
support smart growth development. Other possible actions might be developing funding criteria
or other incentives/state policies to promote smart growth and expansion of the South Coast Rail
Executive Order 525 to other regions or the entire state. One model for consideration would be
the Executive Office of Housing and Economic Development's MassWorks Program which
includes state goals the agency wants to achieve through a set of its grant programs and targets
and criteria for grant seekers. We understand that EOHED's model may not be transferable given
the source of funding and different agency responsibilities and mandates, but it is a state agency
program that seeks to incentivize and support smart growth outcomes.
55
Commenter
(if known)
While the draft plan is very good as far as it goes, without yet knowing what the mode shift goal is Environmental League of
or fully understanding how MassDOT will work with the MPOs so that decisions on project
Massachusetts
selections will include consideration of GHG emissions, we cannot conclude that the draft plan is
sufficient to reach our GHG targets. We look forward to a public announcement of the mode shift
goal, the Division plans that will go into further detail, and additional information about MPO
decision-making. We urge that each of these be forthcoming as soon as possible given we now
have less than eight years to achieve our 2020 target.
Page 42 of 74
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
56
Transportation and Smart Growth: The draft plan makes several commitments to improving
transportation choices and promoting livable communities. The final plan should more explicitly
acknowledge the nexus between road improvements and secondary development induced by
those improvements, and should include initiatives to reduce the contribution of transportation
improvements to sprawl.
Mass Audubon
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
57
Promote healthy transportation options: This is simply increasing walking and bicycling
MassPIRG, Livable
compared to driving or transit. This would include both walking and bicycling to transit rather than Streets, On the Move
driving to stations.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
58
Support smart growth development: Compact development that can be served by non-auto
modes of transportation can be seen as Smart Growth. The combination of improved bike/
pedestrian/ transit facilities and shorter travel distances are an important tool to encouraging
mode-shift.
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
Page 43 of 74
MassPIRG, Livable
Streets, On the Move
Feedback + Responses
Reference
number
Comment
59
The table below lists several possible metrics to measure mode-shift. Some are more direct than MassPIRG, Livable
others, but as a group they create a montage of information that will clearly show whether State Streets, On the Move
mode shift efforts are succeeding. Some of the metrics are more applicable to urban and
suburban areas that exurban and rural parts of Massachusetts. In fact we hope your data will be
captured at state, regional and local levels, much as census data is. As you may notice, some of
the above metrics only apply to one mode or another. We should not discount a metric, because
it only applies to certain modes. Rather we encourage the state to use as many metrics as
possible. Each metric tells a different story.
It is instructive to look at metrics used in Europe. For example, Holland measures both VMT and
trips per day by mode. Both data points are instructive. Dutch data shows that about 70 percent
of kilometers traveled is by car (as a driver or passenger). Conversely, when trips per day by
mode is measured, auto travel accounts for less than half of trips. If the Dutch used only VMT as
a metric, they would conclude that 70% of the transportation system usage is by automobile and
that arguably 70% of a transportation budget should go towards car-based infrastructure.
Conversely using a trip based measurement would show that less than half of trips are by car. A
far different conclusion would be drawn. Being able to collect meaningful mode-shift data means
moving beyond a VMT paradigm. GreenDOT needs to explicitly budget funds for applying the
latest technology for capturing the mode shift metrics listed above. Technology applications like
opt-in cell phone applications and crowd sourcing can significantly decrease the costs of
gathering data while increasing the reliability of the data captured.
60
Commenter
(if known)
Implementation: GreenDOT mode shift goals should be a part of each and every project at
MassPIRG, Livable
MassDOT. Project managers and engineers should be expected to design walking, bicycling,
Streets, On the Move
and transit facilities in each project that serve as broad of a range of people as possible (young
and old, experienced and inexperienced). The old way of simply meeting minimums should no
longer be seen as adequate. Walking and bicycling facilities should be designed to meet specific
levels of comfort and safety, and should encourage more people to walk and bicycle rather than
solely serving those who are currently doing them. Opportunities to prioritize transit, create a
better rider experience, and entice new riders should be leveraged in all projects. When a road is
redesigned, the design of bus and/or streetcar stops and stations should be evaluated to see if
they meet the needs of transit riders. Opportunities to prioritize transit, through dedicated lanes
and/or signal preemption/priority should be taken advantage of. A new engineering directive
could better communicate what high quality pedestrian, bicycle, and transit facilities should look
like (the current one mainly specifies minimums). A specific list of multi-modal criteria should be
used when designing each project.
Page 44 of 74
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
Feedback + Responses
Reference
number
Comment
61
Accountability: Our experience in advocating for sustainable transportation and place-based
MassPIRG, Livable
improvements to transportation projects in the State receives widely variable responses from
Streets, On the Move
MassDOT project managers. Some project managers fully understand the urban context and the
importance of a fine grained multi-modal transportation system. Others have a laser-like focus on
improving conditions for cars at the expense of pedestrians, transit users and cyclists. Some
project managers easily incorporate best practices for designing to encourage walking, bicycling,
and transit, while others push back over doing any more than the bare minimums (and some
refuse to even do that). MassDOT will need to hold all levels of the organization accountable to
mode shift and complete streets goals. Each project should be evaluated to ensure that it meets
GreenDOT goals and criteria. Furthermore, we recommend that a project manager's annual
review include a measure of the extent that the projects they designed meet GreenDOT criteria.
Our goal is to embed GreenDOT and Complete Street
policies into every level of the organization. Language
has been added to the document clarifying the role of
division leadership in developing GreenDOT work plans
and the development of progress reports to provide
accountability throughout the organization.
62
State should do a better job with mobility management and publicize/advertise known shuttles
and private carriers as another option for people to move around outside scheduled public
transit.
Thank you for your suggestions. MassDOT will explore
methods to provide coordinated information for shuttles
and inter-city bus travel.
63
Massachusetts' rail trails offer safe, scenic places to walk and cycle while creatively using old
Senator James B
infrastructure. Rail trails both promote healthy lifestyles in Massachusetts communities and
Eldridge
support local economies, as pedestrians and cyclists using the trails support restaurants and
other businesses along the trail. The momentum behind projects such as the Bruce Freeman
Trail (BFRT) - which has the potential of following the 25-mile route of the old New Haven Railroad
Framingham and Lowell Line - is indicative of municipalities' support for utilizing old rail road
infrastructure for trails that benefit the entire community. The first phase of the BFRT has proven
successful in Chelmsford and Westford, with expected expansion to Westford, Carlisle, Concord,
and the towns of Acton and Sudbury in my district. Sufficient funding is critical to the expansion
and completion of this and other trails.
64
Through the GreenDOT Initiative, the Department of Transportation has made clear its
Senator James B
commitment to encourage municipalities to create alternative forms of transportation through the Eldridge
renovation and construction of rail and bike trails. Provision of increased funding for rail trails
would be in accordance with all three of GreenDOT's policy objectives, including: promotion of
healthy transportation options; reduction of greenhouse gas emissions; and support smart
growth development. I ask that in crafting the final GreenDOT Implementation Plan, the
Department consider the importance of supporting rail trail expansion in the Commonwealth.
Page 45 of 74
Commenter
(if known)
Southeaster Regional
Planning and Economic
Development District
Response and Proposed plan revisions
(if applicable)
MassDOT strongly supports bicycle infrastructure and
has proposed a 788-mile bicycle network known as the
Bay State Greenway (BSG). We have prioritized one
hundred miles of that network and have called for
completion of the first hundred miles by 2020 in the draft
GreenDOT Implementation plan. The Bruce Freeman
Trail, serving the communities of Lowell, Chelmsford,
Westford, Acton, Concord, Sudbury and Framingham, is
part of the priority one hundred miles. With support and
additional funding, we will continue to work to build out
that network to provide our customers with additional
healthy travel options for commuting and recreation.
Feedback + Responses
Reference
number
Comment
65
We especially thank MassDOT for its support in this Draft Plan for the following programs,
Friends of the Community Thank you for your support
policies and initiatives · Bay State Greenway Priority 100 =100 new miles of path by 2020 ·
Path
Increasing total miles of connectivity of bicycle and pedestrian facilities · Hubway bike share in
the Boston metro area Increased delivery of Complete Streets projects -- which will ideally be an
immediate change to all projects in planning · Improved traffic controls to support walking and
biking · Increase bicycle parking (especially at State facilities) and bicycle access to transit
66
We wish to focus on the first two points above, increasing path length and connectivity, the
principal methods to achieve transportation mode shift from private vehicles to mass transit,
walking and bicycling. On-road bicycle marking, increased safety programs for all users, and
more bicycle parking are also quite significant to this end. Ultimately, we hope that MassDOT’s
Mode Shift goals and implementation tasks promote healthy transportation and livable
communities, aiming for a multi-modal transportation system.
Friends of the Community MassDOT with be working with the Boston MPO on a
Path
study to prioritize projects for improving the connectivity
of the Boston Area bicycle facility network. We have also
created a revised BSG Priority 100 program to advanced
key shared use path projects statewide.
67
Specifically, we urge MassDOT to prioritize the Community Path extension as the Top Priority
multi-use path with respect to use, cost-effectiveness, timeliness and multi-modality; and
therefore to:
· Complete the design and construction of the CPX, from Lowell Street all the way to the existing
paths at Lechmere/North Point -- and not just to Inner Belt. The CPX should be completed
whether as an integral part of the GLX, a lasting Mitigation project for the GLX Delay, or on its
own by virtue of the CPX’s own merits.
· Fund the Inner Belt-to-Lechmere CPX design and subsequent construction, which are not
funded in the GLX project budget. This final link, over the Fitchburg line tracks, to the existing
paths at Lechmere/North Point is essential for CPX connectivity with Cambridge, Boston and the
Charles River path network. [ The remainder of this public comment substantiates the CPX as a
top priority GreenDOT project, including regional significance, benefits, and need for the CPX to
be completed in the next few years. ]
Friends of the Community Many members of the public have requested that the
Path
Community Path be constructed as an interim mitigation
measure for the delays in the implementation of the
Green Line Extension project. Given the
interconnectedness of the construction of the Path and
the GLX project, it would not be possible to construct the
Path in advance of the full Green Line Extension project –
and thus in time to meet the mitigation deadline of
December 31, 2014 – making it not viable as a mitigation
measure.
68
Generally, we request acceleration of the proposed regional bicycle/pedestrian paths and
Friends of the Community Thank you for your feedback.
facilities. The inner core communities are already experiencing significant mode shift to bicycling Path
and walking as alternative transportation throughout the region, and need better connectivity and
infrastructure to support and sustain this mode shift.
Page 46 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
69
We recommend that the Draft Plan have specific goals of increasing miles of multi-use paths
Friends of the Community
throughout the State with some breakdown per region. Prioritization of multi-use paths should be Path
based on the cost-effectiveness of each proposed path, generally choosing those paths that
produce the highest use and connectivity for the least cost.
70
Ideally, the Draft Plan will show multi-use path cost estimates and proposed funding sources, if
any. We stand ready to help the MassDOT Planning find the funding and implement these
GreenDOT plans, especially multi-use paths, in any way we can.
Friends of the Community The GreenDOT Implementation Plan seeks to focus on
Path
broad policies without discussing individual projects
beyond large scale transit projects. The Plan is
intentionally aspirational and practical however not
fiscally constrained. While GreenDOT seeks to craft
financially feasible solutions to reach the various goals,
the pathway to implementing all the GHG and other
sustainability targets will depend on numerous policy and
budget decisions over the upcoming years. Prioritizing
investments and developing cost/benefit and return on
investment analysis will be conducted for a large number
of the major investments described in the plan.
71
We would recommend that MassDOT continue to work with the regional planning agencies to
advance efforts to develop a new project evaluation process that incorporates sustainable
transportation concepts to assist in the prioritization of transportation improvement projects.
Pioneer Valley Planning
Commission
Through the weMove Massachusetts multimodal
strategic planning initiative, MassDOT will be using
scenario planning to prioritize the programmatic
investments we make for our transportation system.
GreenDOT Implementation Plan will factor into the
scenario planning effort.
72
It is not clear who will be performing the signal inventories and evaluations referenced on page 51 Pioneer Valley Planning
and whether the inventories will be conducted for equipment under both state and local
Commission
maintenance jurisdiction. It will be important to consider the locally maintained traffic signal
equipment to maximize the benefits of this strategy. If the assistance of regional planning
agencies is required to complete these inventories, these tasks would need to be incorporated
into their respective Unified Planning Work Programs (UPWP).
We will update UPWP's as needed to allow MPO's to
assist with meeting GreenDOT goals
Page 47 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
MassDOT is primarily focused on completing the Bay
State Greenway, and particularly the BSG 100. There are
many other paths under development by towns and/or
prioritized at the regional level + MassDOT supports the
implementation of those trails that serve key
transportation functions.
Feedback + Responses
Reference
number
Comment
73
It is also unclear which offices will be required to have visible bicycle parking locations for visitors Pioneer Valley Planning
near entrances.
Commission
All MassDOT facilities which serve customers (except
rest areas) or locations holding public meetings should
provide visitor bicycle parking options as well as allowing
for transit access, if possible.
74
Regional planning and transportation agencies in many areas of the United States provide
Pioneer Valley Planning
funding to promote and support Transit Oriented Development. Funds are provided for a variety Commission
of uses including TOD planning, site acquisition and clearance, and project development costs.
Thus we would recommend the addition of a strategy to promote transit-oriented development by
adopting new TOD zoning districts along high-speed rail lines and bus routes, and near existing
centers to reduce reliance on cars and vehicle miles traveled.
75
We also recommend the establishment of a MassDOT funded Livability Program for
Massachusetts. Livability programs are specific funding programs using transportation funding
streams that support community and land use oriented transportation projects, such as
pedestrian, streetscape, mixed-use infill, transit-oriented development and transit improvement
projects. Livability Programs have been established in at least seven Metropolitan Planning
Organizations around the United States. Long-range Regional Transportation Plans (RTPs) and
Transportation Improvement Plans (TIPs) provide the most important opportunities for linkages
between local and regional land use and transportation goals. These linkages can take the form
of evaluation criteria for analyzing potential transportation investments, or targeting of
transportation funds for sustainable development projects.
MassDOT will be working under the leadership of EEA
toward measuring GHG reductions attributable to the
relevant policies in GreenDOT, including efforts to curb
VMT growth. Some of the GHG reduction within the
transportation sector rely on initiatives such as Smart
Growth development, improved driving behavior, and the
purchasing more fuel efficient vehicles by our customers,
which MassDOT can support but does not directly
influence.
76
First we want to applaud you for the first indicator, “Bicycle and pedestrian facilities featured and MassBIKE
prioritized in designs.” This is a crucially important step forward in allowing travelers to choose
non-motorized modes of travel.
Thank you for your support
77
Project Development and Design Guide Update completed to reflect evolution of Complete
Streets - The Project Development and Design Guide can and should be updated sooner than
2015. Delaying to 2015 is unnecessary, and will substantially increase the number of projects in
the pipeline that do not meet current design standards.
Change to 2013
78
Techniques for reducing operating speeds on arterials, connectors and local roads researched - MassBIKE
There is already a great body of research on methods for reducing operating speeds on arterials,
collectors, and local roadways. Rather than researching, these techniques should be
implemented, especially on routes with significant bicycle and pedestrian traffic.
Page 48 of 74
Commenter
(if known)
Pioneer Valley Planning
Commission
MassBIKE
Response and Proposed plan revisions
(if applicable)
Revise research to applied in strategic locations
Feedback + Responses
Reference
number
Comment
79
All 'driveway' approaches to offices, airports + rail stations designed as Complete Streets - It is
MassBIKE
unclear how a “driveway approach” is defined for rail, airports and offices. Would this include all
MBTA stations? And would it also include employee access roads at places like Logan airport? If
so, it should be made explicitly clear that these should be designed for bicycle and pedestrian
access.
Revise: All 'driveway' approaches to MassDOT offices,
airports + rail stations provide bicycle + pedestrian
access
80
Task: Improve Traffic Controls to Reduce Vehicle Emissions and to Support Biking and Walking,
1. All signalized corridors evaluated for optimal operations for all users – This metric should
explicitly include bike-specific traffic signals, especially for areas with cycle tracks, multi-use
trails, and other intersections where appropriate. 2. All signals evaluated and adjusted for
optimal operations for all users – All loop detectors at all signalized intersections should be
evaluated, since they often cannot detect bicycles.
MassBIKE
Revise: ... including bike-specific signage, signals, and
detectors where appropriate.
81
Task: Increase Total Miles and Connectivity of Bicycle and Pedestrian Facilities
We had several notes relating to these indicators:
1. Statewide inventory of bicycle facilities completed – The statewide inventory should include all
facilities, regardless of whether they are state- or locally-owned.
MassBIKE
The current bicycle facility database to be used for the
inventory includes all publicly accessible facilities, state
or locally owned.
82
2. Bike sharing programs added + expanded - Given that Hubway just expanded to three more
communities, it isn’t clear whether the intention for this indicator is for new systems in additional
communities or further expansion of Hubway.
MassBIKE
Both - will clarify: Revise: Bike share programs expanded
within + beyond Boston inner core
83
Critical pedestrian + bicycle network gaps prioritized for project funding - We feel that the critical MassBIKE
network gaps are already well understood, and so prioritizing them for funding should happen by
2013.
Change to 2013
84
Miles of bike facilities doubled across the Commonwealth - We were pleased to see an indicator
of doubling bike facilities statewide by 2020. Our concern is that the term “bike facilities” is too
vague – the metric should be limited to dedicated roadway and off-road bicycle facilities, and
should not include minimal facilities such as signed bike routes.
Revise: Include "dedicated roadway bicycle facilities"
85
Task: Increase Bicycle Parking and Access to Transit We were pleased to see this goal, since
MassBIKE
taking advantage of multiple modes can increase both biking and transit use, while decreasing
single occupant vehicle use. Below are specific questions and comments: 1. Generally speaking,
there are some transit locations with difficult bike access due to the surrounding street network
not being supportive of bicycling. There should be an indicator of “Complete Streets access to all
transit facilities”.
Page 49 of 74
Commenter
(if known)
MassBIKE
Response and Proposed plan revisions
(if applicable)
New Indicator under Design theme: All rail transit stations
are accessed by Complete Streets
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
86
There should be an indicator of performing a study for eliminating all peak hour restrictions of
bikes on transit.
MassBIKE
New indicator: Study + pilot programs completed
evaluating options for eliminating peak hour restrictions
of bikes on transit.
87
Number of bicycle racks doubled in municipalities participating in bike rack program(s) - Bicycle MassBIKE
Parking Programs in the state’s 13 MPOs lack consistent, dedicated funding, which is a major
impediment to doubling the number of bike racks in participating municipalities. A better indicator
is to establish permanent Bike Parking Programs in all 13 MPOs with dedicated funding.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
88
Transit stations with significant customer car parking (>50 spaces) have high-quality bicycle
parking – You should define the features of “high-quality bicycle parking”. Bike parking at any
facility should be of the highest standard appropriate for that facility.
MassBIKE
Revise: Insert covered +/or secure
89
Task: Expand Commuter Options Programs 1. Bicycle parking installed at major park + ride
facilities - We like the inclusion of bike parking at major Park and Ride facilities, though you
should define what kind of bicycle parking is to be installed. Covered, secure bike parking is
preferred.
MassBIKE
Revise: Insert covered +/or secure
90
Task: Encourage Walking, Biking and Transit as Active Transportation
MassBIKE
We are glad to see active transportation take such a prominent role in the GreenDOT Plan. See
below for a few comments: 1.
MassDOT Bay State Bike Week facilitated + promoted
annually - We greatly appreciate the assistance that MassDOT has provided in making Bay State
Bike Week a successful, truly statewide event. However, we do want to point out that Bay State
Bike Week is presented by MassBIKE, in Partnership with MassDOT.
Revise language to include MassBike partnership
91
Information on transit, bicycle + pedestrian travel provided on public meeting announcements - MassBIKE
Beyond only providing information, public meeting locations should be chosen based on the level
of access for those not traveling by car
Add new indicator in planning theme: Selection of public
meetings venues will seek to find locations with transit,
pedestrian + bicycle facilities
92
40% of elementary + middle schools reached through Safe Routes to Schools program - There is MassBIKE
a great deal of variation in the student experience of “Participating Schools.” The indicator should
measure the percentage of students participating in bicycle and pedestrian safety lessons, as we
feel this is a critical element of the program to which most children are not exposed.
Thank you for your feedback.
93
There should be an indicator for the proportion of children biking and walking to school.
94
Task: Establish Transit First Policy and Mode Shift Goals You should define the “Transit First
Policy,” as it would seem to prioritize transit above all other modes of transportation.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Page 50 of 74
MassBIKE
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
95
Section & Page Specific Comments: Under the Healthy Transportation/Livable Communities &
Multi-modal sections, I encourage MassDOT in general to focus on and expand the dialog
around how we as a Commonwealth provide school transportation. From one community to the
next, policies around how busing is paid for varies greatly. Policies on allowing kids to bike or
walk to school vary and in some cases even discourage kids from riding bikes. And, buses which
communities pay for are severely restricted in use, sitting idle during the day while communities
struggle with finding ways to transport senior citizens around. The congestion that is created from
parents driving kids to school is in some cases generating the demand for TIP funding to
upgrade intersections near schools at a significant cost and waste of state and federal resources.
We could use some Planning or CTPS data collection on this issue; policy changes around the
type of buses communities purchase (so that they can be used in a more flexible fashion);
improvements to bike and pedestrian infrastructure within 2 miles of every school, etc.
Michelle Ciccolo
Director of Community
Development Town of
Hudson
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
96
P. 54 – You reference that the mode-shift target goals have not yet been set. This particular goal
is among the higher level overarching goals of greatest importance. Thus, I support and
advocate for an aggressive mode-shift target.
Michelle Ciccolo
Director of Community
Development Town of
Hudson
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
97
P. 54 – Goal of 40% Safe Routes to School is not adequate. While it might be unrealistic to have
100% participation, why wouldn’t we want to strive for something higher than 40%? It is after all,
the safety, physical health, and well being of our youngest and most vulnerable populations
which get the benefit of the SRTS program. At a minimum, we should consider setting the target
at 75%.
Michelle Ciccolo
Town of Hudson
Thank you for your feedback.
98
P. 56 – I think the reference to “health impact” assessments for major transportation projects is
tremendous and very important. The more we as a commonwealth understand the critical link
between the infrastructure we build and public health, the more likely we are to fund the right
thing…
Michelle Ciccolo
Town of Hudson
Thank you for your support.
99
Increase Bicycle Parking and Access to Transit: Bicycling as a mode of choice has rapidly
A Better City
increased over the last few years. This is in part due to the support of MassDOT and other
agencies to implement programs to support bicycling, including complete streets, bike sharing,
bike weeks, and other initiatives. It is imperative that MassDOT continue to support new initiatives
and equip existing infrastructure to support increased levels of bicycling in the state. We are
looking forward to MassDOT implementing the initiatives it has detailed to improve bicycle
parking and access to transit.
Page 51 of 74
Thank you for your support.
Feedback + Responses
Reference
number
Comment
100
Improve Transit Performance Statewide
A Better City
We strongly support MassDOT’s goal of expanding and developing new public transit services
throughout the state. ABC recently co-sponsored a report by the Urban Land Institute and the
Dukakis Center at Northeastern University, which identified capacity constraints within the MBTA
system that could choke off planned real estate development around transit. Failing to address
these bottlenecks could have serious greenhouse gas implications for the region, as commuters
opt to drive instead and developers opt for less sustainable land use patterns. Similarly, investing
in the state’s 15 Regional Transit Authorities so that they can operate bus service will greater
frequency and longer hours will make transit a more viable option for residents outside the MBTA
service district.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
101
However, the key to these investments is funding. The state must act quickly to develop a longA Better City
term fix for the state’s transportation infrastructure that enables us to both maintain our existing
infrastructure and invest in expansions that are necessary to support continued economic growth.
At the same time, MassDOT should introduce performance metrics, including greenhouse gas
measurements, that enable enhanced system performance.
The Plan is intentionally aspirational and practical
however not fiscally constrained. While GreenDOT seeks
to craft financially feasible solutions to reach the various
goals, the pathway to implementing all the GHG and
other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
102
Expand Commuter Options Programs
A Better City
ABC has been leading the development of successful commuter options programs to businesses
in Boston for more than 15 years through our Transportation Management Association. The ABC
TMA, along with the 10 other TMAs located throughout Eastern Massachusetts, are shining
examples of successful public/private partnerships that have leveraged millions of private dollars
towards the provision of commuter options programs at nearly 300 member sites. The TMAs
currently collaborate with MassDOT in developing and supporting commuter programs and
employer recognition. ABC encourages MassDOT to include a specific task related to this
collaboration: Collaborate with Transportation Management Associations. Specific indicators
could include: Develop at least two new TMAs in regions that do not have them; Increase
membership in TMAs to 400 businesses, institutions, and buildings; and Recognize 250
businesses in Massachusetts in the Excellence in Commuter Options (ECO) Awards.
Thank you for your support. MassDOT will continue to
work with its partners and constituencies to increase
participation in commuter option programs as part of our
Mode Shift goal.
Page 52 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
103
Mode Shift Policy
A Better City
ABC received a briefing from MassDOT on its Mode Shift Policy Initiative, which is currently
included in GreenDOT but may be elevated to a higher importance within the overall plan. While
the policy goal of mode shift is very much consistent with ABC’s work on transportation policy, we
have some concerns about how the policy is being developed. For example, the metric being
used to measure mode split does not differentiate between single-occupancy car trips and
multiple-occupancy car trips (ie, carpools or vanpools). We believe that adjusting this metric to
distinguish between these two forms of automobile use would help encourage more sustainable
car commuting. We hope that the MassDOT will make use of the extensive resources and
research available in setting its mode shift goal for the Commonwealth, so that it is a figure that is
ambitious but still attainable. We support integrated this close tightly into the GreenDOT
implementation plan.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
104
Implement physically separated bike lanes (by 2013). The Boston Cyclists Union has already
Boston Cyclists Union
identified streets in the MassDOT portfolio, such as Beacon Street in Somerville and Morton
Street in Jamaica Plain, Dorchester and Mattapan, that will require a greater level of safety for
cyclists than bike lanes can provide. The Beacon Street corridor has very high rate of bike
commuters who should be accommodated in the safest way possible, and a safer Morton Street
would give Dorchester and Mattapan residents safe access to the ultra-safe SW Corridor bike
path. These are EJ communities which have few physical activity options. In many complete
streets guidelines, including that of the City of Boston, the preferred treatment of streets with
motor vehicle traffic with recorded speeds of 35MPH and above is a physically separated bike
lane (a.k.a. cycletrack). These facilities are rapidly gaining popularity in the U.S. and are currently
in use in Chicago, New York City, Washington D.C. and are also included in the NACTO Urban
Bikeway Design Guide. This type of facility we feel should be specifically mentioned in the plan as
well as part of the complete streets implementation and a benchmark set for installing a certain
number of miles of them in urban areas as part of the goals to increase the total number of miles
of bicycle facilities.
New Indicator under Design theme: Contemporary
bicycle facility designs such as painted lanes,
cycletracks, and bicycle signals are considered as part
of Complete Street accommodations.
Page 53 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
105
Focus on Hubway’s complementary role with transit, and take advantage of it to implement full, Boston Cyclists Union
all-hour access for bicycles (with practical limitations) to heavy and light rail MBTA vehicles (by
2013). For some communities, such as East Boston, the MBTA provides the only non-car link to
and from their work places. And for some individuals, walking is not a fast enough mode to
complete their trip within a reasonable commuting time. The Hubway bike share system has
offered a new solution to this problem. As such, the installation of Hubway in East Boston and
similarly “cut-off” communities could be prioritized in the future and thus reduce demand for
bikes on the Blue Line. The more convenient Hubway + MBTA combination would likely reduce
demand for cyclists wanting to bring bicycles aboard transit habitually (instead the T would serve
primarily as emergency transportation for cyclists with flat tires and the like).
106
Our recommendation is to allow bikes on the T at all times but with certain rules and restrictions. Boston Cyclists Union
Generally speaking, cyclists prefer to ride. But the MBTA system becomes vital when a bicycle
breaks down or when certain types of cyclists are travelling long distances. When unexpected
inclement weather hits, a set of rules to put reasonable limitations on bikes on the T could prevent
any potential pitfalls. Full bike access to light rail is allowed in Cleveland, Minneapolis, and
Austin—all with special limitations that guarantee success. Cleveland uses the same Ansaldo
Breda light rail vehicles as the MBTA with no special bike accommodation. Below is an example
of bicycle rules from Cleveland, which could be implemented on the MBTA: - No tandems,
recumbents, mopeds, or tri-cycles - No more than two bicycles are permitted per car, with space
available on a first come, first-served basis. - Cyclists must board the train after other
passengers, and must stay with their bicycles for the entire ride. - Bikes must not block aisles or
doorways on RTA trains, and must be securely held or tied in place.
Page 54 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your suggestion will be
forwarded to the City of Boston as part of our ongoing
partnership with the city in implementing the bike sharing
program.
These suggestions will be passed along to the MBTA for
discussion as part of their work plan Also note: Note the
new Indicator to study + pilot completed evaluating
options for eliminating peak hours restrictions of bikes on
transit.
Feedback + Responses
Reference
number
Comment
107
Encourage municipalities to run their own Safe Routes To School funded programs (by 2014)
Boston Cyclists Union
Without help from SRTS funding, the City of Boston has created a Youth Cycling program in
Boston Public Schools that offers more than the state’s Safe Routes to School programming. The
state’s SRTS program offers presentations on bike safety for students, but Boston’s program
uses the classroom to teach bike safety and then also brings the children outside to actually ride
a bicycle and learn the skills needed to be safe on the road. This hands-on training is by all
appearances far more effective in getting key safety techniques across to young people, and also
connects them to other city and community programs regarding safe cycling. If the
Commonwealth’s larger municipalities (and some of its smaller ones) had the capability to
leverage SRTS funding, they would be well suited to take advantage of existing partnerships with
local groups and volunteers to amplify what SRTS funds can accomplish, and to customize
programs for their unique populations.
108
Create a goal for improving the accuracy of traffic growth predictions (by 2013) MassDOT’s new Boston Cyclists Union
design and construction projects all rely on traffic projections from the Central Transportation
Planning Staff which are based on the traffic growth measured between 1990 and 2000. In
today’s environment, it is well known that traffic growth in the Commonwealth has been largely nil
since 2002. A revised model for traffic growth prediction based on growth between 2000 and
2010 is overdue and if put on a fast track could significantly change the nature of projects across
the state. Given GreenDOT’s goals of encouraging active transportation and transit, special care
should also be taken to
ensure that the model is not overly “conservative” or over-adjusted for the economic downturn. A
recent study by Sivak and Schoettle indicates that significantly fewer young people are obtaining
drivers licenses, with 20-29 year olds showing an over 9% decrease in licensing between 1983
and 2008, this could indicate that there is something more that a bad economy bringing our
traffic numbers down. It is always possible that a real mode shift, of the kind that GreenDOT aims
for, is actually occurring.
109
Commenter
(if known)
Officially accept Level Of Service F in urban areas, and create a Level of Service for bicycles and Boston Cyclists Union
pedestrians to be balanced with that of motor vehicles (2013). Many states, including the state of
Florida, have explicitly accepted a Level Of Service of F as acceptable in roadway design
projects in the urban context, and in practice this has been accepted many times on specific
projects in Massachusetts. In urban areas in particular, it is undesirable to prioritize moving motor
vehicle traffic quickly over meeting the needs of pedestrians, bicyclists and transit. Streets
optimized for cars tend to have less social connectivity and civic life. Officially accepting Level Of
Service F in certain types of situations would help give MassDOT’s engineers more flexibility in
meeting the goals of GreenDOT.
Page 55 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment, your suggestion has been
shared for consideration by the Safe Routes to Schools'
team.
In October of this year we will be announcing a
MassDOT Mode Shift Goal with implementation
strategies, and will add the new Mode Shift Goal within
the Planning, Policy and Design theme of the
Implementation Plan. Adjustments to traffic analysis and
modelling methods are included in the Mode Shift
strategies. MassDOT must also balance these
objectives with operational safety concerns.
Feedback + Responses
Reference
number
Comment
110
Install trolley track warning signs and other safety improvements for cyclists wherever light rail
Boston Cyclists Union
tracks or at-grade crossings exist on roadways or paths (2013). These simple signs, showing a
cyclist tripping over trolley tracks on a yellow diamond, may be effective in reducing the frequent
bike-related crashes, injuries and deaths along light rail tracks and rail crossings. They are used
in Portland, Oregon and several other cities where light rail exists. On light rail tracks as well as at
grade crossings, investigate options for non-slip treatments for rails and rubber flanges that will
not interfere with light rail trains. Also prioritize maintenance of roadways under the tracks.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
111
Streamline the process for creating new bike and pedestrian paths, create a process for making Boston Cyclists Union
additions to the Bay State Greenway 100, and emphasize separation, maintenance and snow
removal (2013). We applaud prioritizing critical bicycle network gaps, but would encourage the
DOT to create a set of criteria to determine which paths are the most critical. Criteria could
include population density, destinations on route, and proximity of EJ communities. Within and
without the BSG 100, this criteria could be used to ensure the newest paths have the most impact
on daily ridership. In busy areas, a separation between pedestrian and cyclists users becomes
critical. Bicycle commuters who are consistently slowed by pedestrians choose other, potentially
more dangerous routes. Pedestrians feel threatened by cyclists, and often act to ban bicycles
from bike paths. Separation (not shared use) will create a strong constituency from both
pedestrians and cyclists to help maintain, promote, and build upon
future linear parks.
MassDOT is focused on advancing the Bay State
Greenway and the Priority 100. We continue to work to
improve our design and contracting process to advance
this bicycle network.
112
Repaving and snow removal are also key to making paths useful. Emphasizing snow removal of
paths over other facilities (such as parking lots) would help create all-year cyclists.
Boston Cyclists Union
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
113
Create a specific, measurable mode shift goal.
Boston Cyclists Union
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
114
Eliminate free parking in business areas
Boston Cyclists Union
Thank you for your comment.
115
Emphasize active transportation over electric vehicles and other fuel alternatives.
Boston Cyclists Union
Thank you for your comment.
Page 56 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
116
Prioritize indoor bike parking with rack installations at MBTA Stations that have available floor
space
Boston Cyclists Union
117
Add bicycle wheel ramps/gutters to aid bicyclists using stairs in all new station
construction/retrofitting.
Boston Cyclists Union
118
Use caution when planning to improve traffic controls to reduce vehicle emissions. When used to Boston Cyclists Union
create faster motor vehicle traffic flow, these kinds of signalization improvements can induce
more traffic along a street over time.
Thank you for your feedback.
119
Hubway bike share in the Boston metro area - the GreenDOT Plan should include goals and
strategies to further expand the program
Livable Streets
Revise: Bike share programs expanded within + beyond
Boston inner core
120
Bay State Greenway, the Priority 100 miles - identifying interim goals prior to the 2020 objection
would be very useful for staying on track
Livable Streets
Add new indicator under Planning: At least 45 new miles
of the Bay State Greenway completed or advertised for
construction (2015)
121
Increased delivery of Complete Streets projects - MassDOT should revisit existing projects to
ensure that pedestrian, bicycle and transit facilities have been included and designed with the
best practices
Livable Streets
122
Improved traffic controls to support walking and bicycling - it would be good to specifically
mention examples and best practices
Livable Streets
123
Increase bicycle parking (especially at state-owned facilities) and bicycle access to transit
Livable Streets
124
Increase total miles of connectivity of bicycle and pedestrian facilities - there should be specific
goals of so many miles by when, with a particular focus on multi-use paths and cycle tracks
Livable Streets
125
We … request acceleration of the proposed regional bicycle/pedestrian paths and facilities. The Livable Streets
inner core communities of the Boston region are already experiencing significant mode shift to
walking and bicycling, and need better connectivity and infrastructure to support and sustain this
mode shift. In addition, cities who are not themselves taking the initiative to encourage and
prioritize walking and bicycling through infrastructure changes would benefit from a nudge by
MassDOT to do so, particularly outside the Boston region.
Page 57 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Please see the revisions to
bike parking indicators above. Your concerns will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
Thank you for your comment. Your concern has been
passed along to the MassDOT Highway Division for their
consideration.
Thank you for your feedback.
The GreenDOT Plan includes multiple indicators
regarding bike parking and access to transit in the Plan
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Feedback + Responses
Reference
number
Comment
126
The draft plan should have specific goals of increasing miles of multi-use paths throughout the
Livable Streets
State with some breakdown per region. In particular, creating connections between existing multiuse paths should be prioritized. For example, the Boston area has the Charles River Paths,
Emerald Necklace Paths, Southwest Corridor Path, South Bay Harbor Trail, Minuteman Bikeway,
and Somerville Community Path. However, with the exception of the Minuteman Bikeway and
Somerville Community Path, none of these facilities connect to each other, even though they run
within a few hundred feet of each other at key locations. The Springfield are has some pieces of
the much greater Connecticut Riverwalk and Bikeway already built, yet they do not connect (for
example the Agawam and Springfield sections do not connect across the South End Bridge, nor
has funding or a design been created to do so). This lack of connections act as a deterrent to
many who would otherwise choose to use these paths instead of driving but who are not
comfortable with making the on-road connections needed to get where they are going.
127
The Draft Plan should have specific funding amounts identified and a better system (possibly
Livable Streets
separate from existing Highway Division programs) to identify and allocate specific funding for
more multi-use paths. LivableStreets stands ready to help the MassDOT Office of Transportation
Planning to identify funding and implement these GreenDOT plans.
128
Obviously, increased miles and connectivity of our multi-use paths is only one program to realize Livable Streets
mode shift away from private, single occupancy vehicle use. Many other programs, some of
which are discussed in the Draft GreenDOT plan will need to be implemented, not only to
improve transit, bicycling and walking conditions but to actually make these modes significantly
more attractive than driving. This will take considering some “radical” changes in conventional
thinking, such as dedicating more roadway space to walking, bicycling, and transit, focusing less
on motor vehicle level of service (LOS) projections, reducing public transit fares, and increasing
tolls or introducing new roadway pricing schemes. We encourage you to use the GreenDOT
program to take on this challenge.
Page 58 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
MassDOT strongly supports bicycle infrastructure and
has proposed a 788-mile bicycle network known as the
Bay State Greenway (BSG). We have prioritized one
hundred miles of that network and have called for
completion of the first hundred miles by 2020 in the draft
GreenDOT Implementation plan. MassDOT with be
working with CTPS and MAPC to prioritize projects for
improving the connectivity of the Boston Area bicycle
facility network. We have for the first time tracked bike
facilities statewide in an Annual Bicycle Facility Report,
and will prepare an update for 2012.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
129
We’ve submitted a separate letter thanking the Department of Planning for looking at travel mode Livable Streets
shift and we’ve suggested numerous metrics for you to consider collecting data on and
analyzing. One thing to consider would be setting different mode shift goals for rural/exurban
areas (where travel distances are longer and transit is not typically available) and one set for
urban/suburban areas (which due to their land use patterns and street network allows for more
transportation options). Also, consider that while mode percentage changes (such as bicycling
from 1.5% to 5%) are one way to state mode shift goals, another way is to state them in relation to
the mode in question, for example a 100% increase in bicycling rates, a 50% increase in walking,
and a 10% increase in transit within the next 7 years. Perhaps there should also be a mode shift
goal for longer distance trips like Boston to Springfield or Boston to NYC (fewer driving trips and
more via bus or train).
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
130
Lastly, it was acknowledged during the mode shift discussion that changes in terminology would Livable Streets
also help to further the goal of improving the perception of walking, bicycling, and transit, for
example: Use "prioritize" instead of "accommodate" when referring to designing for pedestrians
and bicyclists. Refer to pedestrian and bicycle “facilities” instead of merely “accommodations”.
Use "people who walk" or “people who bike” instead of “pedestrians” or “bicyclists” Stop referring
to walking, bicycling, and transit as “alternative” modes
Thank you for your comment.
131
I was happy to see the following programs, policies and initiatives: • Hubway bike share in the
Allan Moore
Boston metro area • Bay State Greenway (the Priority 100 miles) • Increased delivery of
Complete Streets projects • Increase bicycle parking (especially at State facilities) and bicycle
access to transit • Increase total miles of connectivity of bicycle and pedestrian facilities For this
last initiative, there need to be specific goals of so many miles and by when. This is the principal
method to shift the transportation mode share from private vehicles to transit, walking and
bicycling. MassDOT needs to accelerate the expansion of the proposed regional
bicycle/pedestrian paths and facilities. The inner core communities are already experiencing
significant mode shift to bicycling and walking as alternative transportation throughout the region,
and need better connectivity and infrastructure to support and sustain this mode shift. To
prioritize which proposed multi-use path should be built and when, there needs to be a
procedure that evaluates the cost-effectiveness of each proposed path, generally choosing those
paths that produce the most use for the least cost.
Obviously, reaching this above multi-use path goals will cost money. Therefore the Draft Plan
should have specific funding amounts identified and a proposed route to get this multi-use paths
funding committed.
The Plan is intentionally aspirational and practical,
however, not fiscally constrained. While GreenDOT
seeks to craft financially feasible solutions to reach the
various goals, the pathway to implementing all the GHG
and other sustainability targets will depend on numerous
policy and budget decisions over the upcoming years.
Prioritizing investments and developing cost/benefit and
return on investment analysis will be conducted for a
large number of the major investments described in the
plan.
Page 59 of 74
Feedback + Responses
Reference
number
Comment
132
Regarding “Mode Shift”, it will be important when choosing mode shift policy changes to
Allan Moore
estimate the number of likely “participants” that can be “assisted” to change travel mode choices
in order to get the most impact for the costs involved in making the policy and/or infrastructure
changes. It would seem that the mode shift program needs: • A few specific quantifiable mode
shift goals that have consequences if not met • Additional semi-quantitative secondary mode
shift goals that will help achieve the principal goals • Additional metrics to follow that may not be
actual goals in themselves.
133
The metrics could become actual mode shift goals or just metrics that are just followed in order
to judge how various policy changes are having an impact. Analysis of these options shows that
some may be more applicable to urban and suburban area that exurban and rural parts of
Massachusetts. Some of the metrics are more applicable to some mode shift changes than
others.
We strongly urge MassDOT to look at Mode Shift objectives and metrics used in Europe for
examples to consider adopting here. In this way, we can learn from what others have already
done and we’ll hopefully have data that can be compared to other advanced countries.
Commenter
(if known)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Allan Moore
134
To me, the mode shift metric purpose is to shift transportation choices to those that emit less
Allan Moore
greenhouse gas (GHG) emissions: this can attained by various shifts in travel mode, the resulting
GHG reduction depending on both the number of “participants” and which mode is shifted: •
Walking and bicycling instead of driving or transit • Transit in place of driving • Cleaner transit
replacing “dirtier” transit • Car pooling instead of single occupancy vehicles • Electric or hybrid
vehicles versus traditional vehicles • Smaller cars than larger cars.• Truck transport to rail travel
And for longer distance travel (Springfield, Providence, NYC), bus or train versus private
automobile.
135
Last but not least, with regard to selection of overall GreenDOT projects to advance these
Allan Moore
GreenDOT goals, I strongly urge MassDOT to prioritize the Community Path extension as the Top
Priority multi-use path with respect to use, cost-effectiveness, timeliness and multi-modelness;
and therefore to: 1) Complete the design and construction of the CPX, from Lowell Street all the
way to the existing paths at Lechmere/North Point -- and not just to Inner Belt. The CPX should
be completed whether as an integral part of the GLX, a lasting Mitigation project for the GLX
Delay, or on its own by virtue of the CPX’s own merits. Currently, the Inner Belt-to-Lechmere CPX
design and subsequent construction are not funded in the GLX project budget. This final link,
over the Fitchburg line tracks, to the existing paths at Lechmere/North Point is essential for CPX
connectivity with Cambridge, Boston and the Charles River path network.
The CPX is already implicitly in the GreenDOT Implementation Plan as part of the BayState
Greenway Priority 100 miles for the year 2020. But 2020 is too late as the Path must (technically
speaking) be constructed with the Green Line extension which is happening before 2020.
Page 60 of 74
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
It is worth noting that uncertainty exists about the desired
terminus of the Community Path. MassDOT has always
planned to design the Path to Inner Belt Road in east
Somerville, but some advocates would prefer that the
Path travel all the way to the Lechmere area. Minus the
existence of a NorthPoint Bridge (which does not
currently exist and is not planned for construction),
MassDOT would need to determine an alternate way to
connect the Path from Inner Belt Road to the Lechmere
area. This topic is under consideration as part of the
McGrath Highway ‘de-elevation’ study currently
underway at MassDOT, but no preferred design solution
has been selected.
Feedback + Responses
Reference
number
Comment
136
As a result of the land use changes and other policies to promote transit, biking and walking that MAPC
will occur according to the MetroFuture plan, MAPC estimates a 15% reduction in per-capita
vehicle miles traveled by automobiles registered in Greater Boston by 2030, and regional mode
share for public transit would increase from 6.3% to 13.9%. Overall, MetroFuture has a goal of
reducing the region wide automobile mode share from 77% in 2000 to 61% in 2030. We therefore
are happy that the GreenDOT Plan includes a task to “Establish Transit First Policy and Mode
Shift Goals.” We hope that the mode shift goal MassDOT develops as part of this chapter reflects
the MetroFuture mode shift goal for Greater Boston.
In October of this year we will be announcing a
MassDOT Mode Shift Goal with implementation
strategies, and will add the new Mode Shift Goal within
the Planning, Policy and Design theme of the
Implementation Plan.
137
MAPC appreciates the specific tasks and indicators identified in the Planning, Policy and Design Metropolitan Area
chapter of the Plan, which seek to increase biking and walking, such as “Bicycle + pedestrian
Planning Council
facilities featured + prioritized in designs; rather than simply accommodated” and “Project
Development + Design Guide update completed to reflect evolution of Complete Streets.” In fact,
all the indicators under the task to “Increase total miles + connectivity of bicycle + pedestrian
facilities” are impressive, and MAPC looks forward to working with MassDOT and the Boston
MPO to achieve these goals and measure their progress.
Thank you for your support.
138
An additional indicator that MAPC recommends adding to this section is to specifically support
Metropolitan Area
advancing cycle-tracks, or other buffered or traffic-separated bike facilities, where they can be
Planning Council
accommodated. To achieve an increase in the bicycling mode share across the Commonwealth,
we need to continue advancing the infrastructure that will encourage more cycling. Many people
do not cycle on busy streets, even streets with dedicated bike lanes, because of perceived safety
concerns. Cycle-tracks can dramatically increase bicycle usage.
New Indicator under Design theme: Contemporary
bicycle facility designs such as painted lanes,
cycletracks, and bicycle signals are considered as part
of Complete Street accommodations.
139
MAPC also applauds MassDOT’s commitment to encouraging transit oriented development
Metropolitan Area
(TOD) under the task “Utilize surplus land, parking lots + air rights for transit-oriented
Planning Council
developments.” We encourage you to explicitly indicate that TOD should involve mixed-use
development including housing, especially affordable housing, as well as commercial space. In
the long run, we cannot seriously reduce VMT if we don’t enable more people to live near their
jobs and schools. Locating new homes as well as new jobs near transit is one way to accomplish
this goal. One area MAPC recommends for consideration are the MBTA owned parking lots
around Sullivan Square Station on the Orange Line. MAPC will be working with the Boston
Redevelopment Authority in the Fall of 2012 to conduct a community visioning process, with the
goal of creating a mixed-use TOD and beginning the land disposition process of Boston owned
parcels. We look forward to coordinating this effort with MassDOT and the MBTA, as well as the
neighboring cities of Somerville and Everett.
Thank you for your comment.
Page 61 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
140
MAPC supports the indicator: “Policy to analyze public health impacts of major transportation
Metropolitan Area
projects instituted.” MAPC has recently established a new Public Health Division, which is
Planning Council
conducting health impact assessments (HIAs) of transportation infrastructure and policies, as
well as other developments. MAPC also collaborated with the Massachusetts Department of
Public Health to secure a $1.5 million grant from the Centers for Disease Control and Prevention
(CDC), to help municipalities in Middlesex County tackle the root causes of chronic disease,
including lack of physical activity. MAPC has recently used planning funds from this effort to work
with the Metropolitan Water Resources Authority (MWRA) and communities in Metro West to open
un-used MWRA aqueducts for public trail access.
Thank you for your support.
141
The Plan also needs a clearer explanation of how MassDOT and the Metropolitan Planning
Metropolitan Area
Organizations (MPOs) will work together to accomplish the Plan’s goals, not only through the
Planning Council
operation of existing MassDOT programs, but also through the selection of projects that
specifically reduce or minimize GHG reduction. We recognize that the exact process may differ in
various parts of the state, but each MPO should adjust its criteria and project selection process
to explicitly prioritize projects that will help to achieve the Commonwealth’s GHG goals. Modeling
the impact of projects that are being considered for inclusion in the Long-Range Transportation
Plans and well as the Transportation Improvement Programs, whether these projects are major
capacity-adding projects or not, will be important to help both MassDOT and the MPOs select
projects with a consistent eye on their GHG impacts.
Through the weMove MA multimodal strategic planning
initiative, MassDOT will be using scenario planning to
prioritize the programmatic investments we make for our
transportation system. GreenDOT Implementation Plan
will factor into the scenario planning effort.
142
Thank you for the opportunity to comment on the GreenDOT.
Jim McCarthy
I agreed and support the goals of the program 100%. I have seen first hand the transformation
and positive results the rail trail has had in Newburyport. I support a much healthier mix of
transport not centered on the automobile. Constructive Point #1: The evaluation criteria that
dominates any transit oriented project that involves any road improvement is level of service and
safety. Evaluation criteria for complete streets and emission goals needs to be at least on par
with level of service. In addition, the aesthetic of the design needs to be evaluated. To you it may
be a highway, but to us it's our neighborhood. If you don't measure it, it won't happen.
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
143
Constructive point #2: Sustainability includes ongoing maintenance of the project years later. If Jim McCarthy
signage and markings are not absolutely required for safety, they should be omitted. Engineers
have a tendency to over-specify, with no future consideration for maintenance costs. Mass DOT
needs to develop an internal culture, from the top down, of sign minimalism.
144
Commenter
(if known)
Constructive Point #3: I can see how the objectives will be carried out through large new
Jim McCarthy
projects, but there is plenty to be done at the district level just to reconfigure the 50 years of
cumulative hodge-podge construction. With minimal cost most, of our roadways would be much
better off with more time spent in the engineering/planning end versus the installation end. Again
we need to design for safe and minimal.
Page 62 of 74
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
Feedback + Responses
Reference
number
Comment
145
Hubway Bike Sharing, Boston
Solomon Mezgebu
One of the most innovative, visionary, simple and long-term projects MASSDOT implemented.
Everyday I witness the ever increasing number of people using these bikes out of North Station. I
hope you will expedite the scaling and expanded access to nearby communities in the short
term.
Thank you for your support.
146
Planning, Policy + Design: Increase total miles + connectivity of bicycle + pedestrian facilities
Cape Cod Commission
Develop bicycle shuttles for areas where accommodations are not practical e.g. across the Tobin
Bridge.
The suggestion of a bike bike shuttle will be forwarded to
the Rail and Transit Division.
147
Encourage walking, biking, + transit as active transportation - Safe Routes to Schools has been
combined with other programs and is now Transportation Alternatives.
Cape Cod Commission
MassDOT expects to continue funding SRTS under the
MAP21 formula.
148
The 2020 bike and ped goals seem too far in the future. 2015 seems feasible.
Jen Boudrie
Thank you for your comment, we have adjusted some of
the timelines in response to this and other comments
above.
149
It's good to see that the Community Path extension (CPX) is among the BSG 100 in the Draft
GreenDOT Plan. But it's still not fully funded and it's in the plan all the way to Lechmere. Please
fund the CPX fully, all the way to Lechmere. This is an essential part of the mitigation for GLX
delays.
W Messenger
Many members of the public have requested that the
Community Path be constructed as an interim mitigation
measure for the delays in the implementation of the
Green Line Extension project. Given the
interconnectedness of the construction of the Path and
the GLX project, it would not be possible to construct the
Path in advance of the full Green Line Extension project –
and thus in time to meet the mitigation deadline of
December 31, 2014 – making it not viable as a mitigation
measure.
Page 63 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
150
My theme will be around the institutional problems surrounding the preservation of former railroad Craig Della Penna
corridor in the state and its subsequent conversion to non-motorized pathways that create a
renaissance in former industrial communities. 1. First, we'll take a look at the 161C and 40/54A
programs. These govern the sale of and construction near former railroad corridors. These
programs are broken and need to be looked into. Thesy have not been reviewed since their
inception many years ago and there is scant evidence that they have ever saved an inch of
corridor. In fact, these programs are little more than speed bumps in the path of bad
development across the state. For example, the poster-child of the poor performance of this
program can be found in Springfield where almost $100,000 of MassHighway Dept. planning and
design money was being spent to develop the proposed Highland Division Rail Trail, a nonmotorized transportation trail a rail trail in an urban area. During the extensive trail planning
process, the railroad reported as was required by the 161C program that a sale of a short stretch
of the corridor was imminent and asked whether the state had any interest in using their first right
of refusal to buy the corridor, thus blocking the sale to the adjacent landowner and preserving the
integrity of the corridor. During their standard canvassing process, the DOT rail office heard cries
of anguish from the city, the regional planning agency and several other state agencies to not
allow the sale. But the state allowed a piece of the corridor to be sold off. Amazingly, this
happened not once, but twice over the period of a couple of years. Yes, we had a situation where
agencies were working against one another. One arm of the transportation secretariat allowed the
sale of a corridor that another arm of the same agency was spending money to assist the
community in developing as a non-motorized trail. This now leaves the City of Springfield with the
odious task of reassembling the corridor through draconian means like Eminent Domain. Here's
another example of the broken program. More recently DOT sat and quietly watched as a high
school principal, who lives in Hardwick, Mass. purchased a section of former railroad corridor
that ran behind his house. This effectively blocked a future trail that would have connected a
village center to the town's elementary school this would have been the ultimate Safe Route to
School. If the state was serious in developing a network of pathways that allow people to traverse
neighborhoods and access transportation related nodes, like schools, in both origin and
destinations, this would not be happening. Period. What makes this example even more
egregious is that this corridor is the alignment of the Mass Central Rail Trail as this corridor that
shows up in several state planning documents as the most important corridor to protect in the
state. These, and other, examples of tolerance for this negligent wasting of the cultural heritage
of the Commonwealth led to me to create a private-sector, last stop entity, specifically set up to
block the sale of corridors to adjacent landowners. The Central Highlands Conservancy, LLC,
partnering with local land trusts, was created to fill the vacuum where the state lacked the
courage and/or competence to do the right thing. This model has a protected either directly or
indirectly 12.5 miles of the MCRT.
Page 64 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
Feedback + Responses
Reference
number
Comment
151
2. Another problem in the 161C program. The premise of this program is to preserve this railroad Craig Della Penna
network for future generations. It has been compromised because the utility industry actually now
owns more miles of former railroad corridor in the state, than the private railroads themselves and
the utilities are exempt from the program! This is a key flaw because, putting it gently, the utility
industry does not have an exemplary track record in defending these valuable corridors or even
making them available for public use. The utilities just need to be integrated into the 161C
program. Simple and clean, if it was a former railroad corridor, it needs to be protected.
Thank you for your comment.
152
3. Having to repeatedly call in the cavalry (so to speak) Over the past few years, there were
Craig Della Penna
several of instances of behind the scenes impasses between state agencies and state vs. federal
agencies that have required various members of the Massachusetts congressional delegation to
referee and tear down absurd paper barriers. These barriers, candidly, do not exist in the 49 other
states. It is apparent to several groups building inter-city, transportation themed trails, that either
getting their congressman or congresswoman to host a meeting and broker a solution, or to get
a high-profile letter-writing campaign underway, is the only way to move these projects forward.
Simply put, this process is diabolical illustrating that the transportation delivery in Massachusetts
is broken.
In October of this year we will be announcing a
MassDOT Mode Shift Goal with implementation
strategies, and will add the new Mode Shift Goal within
the Planning, Policy and Design theme of the
Implementation Plan.
Page 65 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
153
6. Another couple of examples of institutional cowardice in Massachusetts. Since the Rowley vs. Craig Della Penna
Mass. Electric case a few years ago, there were at least a couple of suits that are me too in
nature. The towns of East Bridgewater and Newton both have suits filed by adjacent land owners
against the MBTA using the premise of the Rowley case as a rationale. This doesn't have to be.
The T is failing to defend their land in a successful way. If the state transit agency can't defend
their own land in urban core areas, then all the talk of smart growth is merely talking the talk and
not walking the walk. A similar theme demonstrating the lack institutional courage involves DEP's
Environmental Crime Strike Force. One of the most egregious environmental crimes in western
Mass in the past few years took place in Williamsburg, Massachusetts. Here you'll find that the
litigants in the Rowley case, who received parts of the former railroad corridor from the utility
thought it meant they could cut down the forest right to the edge of the Mill River. This crime, in
clear violation of the Rivers Act, has not been really addressed by DEP. Since that Rowley vs.
Mass. Electric case was promoted by radical property rights activists one might think that DEP is
afraid of them and only writes huff and puff letters, but there has been no real follow up as yet.
This is a poor example of the DEP protecting the environment. Here's the flurry of letters. http://norevisionist-history.org/envirocrimeinwburg.html Given that bicycles and pedestrians are the
indicator species of life in a community, and given that this administration has set the
Commonwealth on a new and sustainable course for the new century, one can only hope that
MassDOT will commit to making certain that wider, faster, straighter roads are not the only recipe
on the horizon for the residents of Massachusetts. As mentioned said earlier, there are more rail
trail projects underway in Mass than anywhere else in the U.S. The majority of these projects
connect village centers, schools, and residential neighborhoods. They are an important key to
any talk about smart growth, yet these projects seem to be a poor step-child in the grand scheme
of things. Thanks for the opportunity to comment.
154
I urge MassDOT to include the Somerville-Cambridge Community path as a top priority in the
GreenDOT plan. Providing direct bike-pedestrian access along this corridor will take cars off the
road, reduce congestion and pollution, and improve public health
Ethan Contini-Field
I'd like to see GreenDOT put its money where its mouth is and build the Community Path
extension in Somerville. PR about being "green" just does not cut it. The Community Path is not
only a Somerville project that meets SIP requirements, but is a great regional project that would
provide the missing link to connect the MinuteMan Bikeway to Boston and to the Boston Metro
network of paths. This project is a poster child for the MassDOT GreenDOT goals including the
newly announced GreenDOT Mode Shift goals.
Karen Molloy
155
Page 66 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
Thank you for your comment.
MassDOT is aware of the passionate public support for
an extension of the Somerville Community Path, and is
collaborating closely with the City of Somerville and Path
advocates as part of the Green Line Extension project.
MassDOT has committed tens of millions of dollars to
completing the design of the Path extension and to
constructing elements of the Path extension that will be
shared by the Path and MBTA Green Line Extension.
Feedback + Responses
Reference
number
Comment
156
I wish to commend MassDOT on its GreenDOT initiative and implementation plan. Both are solid Ken Krause
blueprints for an improved and sustainable region. I particularly support the additional emphasis
on improving access to and conditions for transit, bicycling and walking. The recent Boston
Globe article about how auto traffic in the Kendall Square area of Cambridge actually went down
despite a significant increase in development there is testament to the GreenDOT principles -- the
improvements in bicycling accommodations was cited as a major reason auto traffic has
decreased.
In particular, I wish to register strong support for the completion of the Green Line Extension to
Somerville/Medford, including the permanent terminus at Route 16 as is the MassDOT Preferred
Full Build Alternative.
I also feel that high priority should be given to completing the crucial missing links in the Boston
area bicycle path network, in particular, the Minuteman to the Mystic Path in Medford as mapped
out in the new Mystic River Reservation Master Plan, and the extension of the Community Path in
Somerville. Both of these paths will allow two of the "Bedford to Boston" routes to be essentially
completed, providing a fabulous opportunity to shift auto trips to bicycling. Thank you, and I look
forward to the rapid implementation of all the GreenDOT initiatives.
Page 67 of 74
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
On October 9th, Secretary Davey announced MassDOT's
Mode Shift Goal of tripling bicycling, transit, and walking
by 2030. We will add the new Mode Shift goal with tasks
and indicators, within the Planning, Policy and Design
theme of the Implementation Plan.
Feedback + Responses
Reference
number
Comment
157
First allow me to identify myself as a long-time bicycling advocate, and utility and recreational
John S. Allen
cyclist. I am pleased to see the increased attention to bicycling through the GreenDOT plan, and
particularly, better interfacing with public transit, better parking, and the plan for cross-state
bicycle routes. However, I am very concerned about the quality of much infrastructure being
promoted as appropriate for bicycling. Contrary to the spirit of GreenDOT, much is unsafe or
could be much simpler and more cost-effective. I ask that you review the following examples:
Kenmore Square reconstruction -- bumpy block pavers, ill-considered "bike box" etc. Simpler
alternative would be possible on a parallel street one block away. Please see this article and
linked video: http://john-s-allen.com/blog/?p=4456 Concord Avenue, Cambridge -- Sidewalktype bikeway crossing 24 driveways and 8 streets into an industrial area in 3000 feet, a known
hazardous design. This project replaced functional bike lanes. A two-way path on the south side
of Concord Avenue, which has only one crossing, at a signalized intersection, would have been
desirable. See http://john-s-allen.com/blog/?p=859 Also please see my recent comments about
the recently proposed improvements to the River Street and Western Avenue bridges and
connecting roadways. The proposed pillar-to-post bicycle routes not only require bicyclists
repeatedly to cross streams of motor traffic, incurring long delays, but will be blocked much if not
most of the time by queued motor vehicles at this very overstressed intersection. Success of the
proposed design rests on the assumption that motor traffic entering from the Turnpike will
somehow be replaced by bicyclists traveling a mile or two between Allston and Cambridge.
Perhaps a large percentage of Turnpike users are to move to Allston and become bicyclists?
Perhaps bicyclists are to shoo motorists away by increasing congestion even further? It doesn't
happen: bicyclists get only a tiny fraction of the signal cycle, and won't put up with the delays. A
bolder and more imaginative approach is needed, as I suggest in my comments, to reduce rather
than increase conflicts. River Street-Western Avenue project description: See especially the 25%
project plans here:
http://massdot.state.ma.us/charlesriverbridges/WesternAveRiverStBridgeDocuments.html My
comments: http://john-s-allen.com/reports/riverandwestern.doc I travel to cities all around the
USA and ride bicycles there as part of my work. I have seen none where design for bicycling is as
mindless as it is in these projects. If the bicycling phase of the GreenDOT plan is to succeed, it
must gain control of planning and design at the municipal level, and lead it out of the fantasy
world which it currently inhabits.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
158
I'd like to see MassDOT look to the next steps in helping cities and towns implement Complete
Streets. The training just offered by MassDOT was great. Now, where do we go next? Can the
Commonwealth collaborate with the RPAs, DPH, and A&F to develop programs? Is there a way
we can provide incentives, not punitive, relative to using Chapter 90 and other municipal
resources to make our streets more bike/ped/handicapped/baby carriage friendly...Maybe we
need a best practices toolkit? I like the reference in this plan to updating the MDOT Design
guidebook for recent changes in complete streets...
MassDOT will be working to provide more Complete
Street training, including working with the Bay State
Roads program to offer such services to municipalities.
Page 68 of 74
Commenter
(if known)
Michelle Ciccolo
Director of Community
Development Town of
Hudson
Response and Proposed plan revisions
(if applicable)
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
1
Recommend add recycle bins in all MassDOT offices and facilities.
Catherine Hong Chen, D6 Thank you for your feedback. We are working to
implement this indicator as soon as possible for all
MassDOT offices.
2
Blue bins for each staff member, blue bins in lunch rooms, common areas
GreenDOT Open House
Amherst
3
Would be nice to see recycle bins in train stations (indoor/outdoor) as well as pedestrian
greenways instead of just trash cans
GreenDOT Open House
Amherst
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
4
Improve the district solid waste / recycling contracts - make sure recycling is provided as part of GreenDOT Open House
the solid waste contract
Amherst
5
Track progress of recycling + other efforts make public-online!
GreenDOT Open House
Worcester
Thank you for your support.
6
p 58 – Waste – Thank you for adopting a goal of achieving zero solid waste disposal. BEAT
believes strongly that zero is the right goal. We also applaud efforts to reduce all exposure to
hazardous waste.
Berkshire Environmental
Action Team
Thank you for your support.
7
We applaud your “cradle to cradle” thinking of using readily reusable materials so they may be
reused, repurposed, or recycled into other products at the end of their original purpose.
Berkshire Environmental
Action Team
Thank you for your support.
8
Do more outreach to district staff to encourage recycling - there's always lots of paper in the trash GreenDOT Open House
barrels
Amherst
Page 69 of 74
Add new indicator in Waste theme: Employee education
program on recycling and waste reduction underway.
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
1
Increase use of grey water, as applicable, vs. potable water
GreenDOT Open House
Worcester
GreenDOT includes tasks regarding both recycled
water and dual plumbing systems
2
My understanding is that the draft GreenDOT plan focuses simply on reducing MassDOT/MBTA Joel Weber
water consumption, without especially thinking about combined sewer overflow discharges. This
surprises me; I had been under the impression that significantly more water is available from the
Quabbin Reservoir than has been used in the last two decades, but untreated or partially treated
sewage mixed with stormwater being discharged into rivers seems to be a significant concern.
(There are parts of California where converting desert to farmland requires enough water that
cities need to carefully conserve water for the farming to continue to work, but Massachusetts
does not have that particular issue. I would be interested in learning more if there are other issues
that Massachusetts is concerned about with respect to the current amount of water which is taken
from the Quabbin Reservoir each year.
Thank you for your feedback.
3
With the combined sewer overflow issues, I wonder if a policy of not washing buses or other
vehicles on days when sewers are likely to overflow would be appropriate, and whether there are
other measures that could be taken to move water usage towards days when the sewer system
has plenty of excess capacity.
Joel Weber
4
If there are storm drains controlled by MassDOT which drain into combined sewer systems,
MassDOT investment in storm drain separation might also be appropriate.
Joel Weber
5
When commuter rail toilets are emptied into the sewer system, could that be done on days when Joel Weber
storm drains are not collecting significant runoff? If there are storm drains controlled by MassDOT
which drain into combined sewer systems, MassDOT investment in storm drain separation might
also be appropriate.
6
I love all the 'green' ways the DOT is visioning, especially about using permeable pavementshopefully it is not too late to incorporate use of these in the remodeling of RT 18 in New Bedford.
Can you facilitate their possible use in this project?
Emily Jones
Thank you for your support.
7
pg 71 – BEAT would like to see the wording of the last box changed to: “All projects will meet
state Stream Crossing Standards unless there is an overriding reason that it is not feasible.” Our
goal would be that the state will lead by example and work with municipalities, endeavoring to
make every stream crossing meet the Standards.
Berkshire Environmental
Action Team
All indicators regarding stream crossing standards
relocated to Minimize Impacts of ROW task to avoid
confusion
8
p 72 – "At minimum 5 culverts resized for improved fish migration". Rather than “resized”, this
Berkshire Environmental
should read “redesigned”. Bigger crossings can cause all sorts of problems as well. The crossing Action Team
needs to allow natural flows of the stream at all water levels - too big can spread the water out and
make it too shallow for fish to pass in low water.
Page 70 of 74
For the Highway division, only the Central Artery
tunnels discharge into the MWRA combined sewer
system. All other roadways are disconnected, but still
may require stormwater treatment intervention as
described.
Thank you for your feedback.
Revise Indicator: "Resized" change to "Redesigned"
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
9
p 72 – We would hope you could increase the number of crossings that should be required to
meet the stream crossing standards – 5 is too few.
Berkshire Environmental
Action Team
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans.
10
p 72 – BEAT would like to see the box about post peak discharge rates changed to “Post peak
Berkshire Environmental
discharge rates will match discharge rate calculated as if the land were forested to the maximum Action Team
extent possible.” We believe in this time of a rapidly changing climate, we need to use best
practices to be as resilient as possible. Rather than aiming at incremental improvement over our
past mistakes, BEAT believes we should be aiming at restoring stormwater flow to a regime
similar to what it was before any development took place. Thus, post peak flows should resemble
what they would have been from a forested landscape.
New Water Indicator to be added: Revised extreme
precipitation data utilized for rainfall, flood flow, and
stormwater calculations
11
We believe all pipes and paved conveyances should be disconnected from our wetlands and
waterways.
Thank you for your feedback.
12
p 72 – We believe the timeline for permeable paving in parking lot reconstruction should be 2015, Berkshire Environmental
not 2020.
Action Team
Thank you for your feedback. The long term durability
of permeable paving in freeze thaw cycles will be
evaluated in pilot conditions before moving forward
with permeable paving in all parking lot projects.
13
BEAT would like to work with MassDOT to help federal, state, and municipal agencies to work
Berkshire Environmental
together to ensure that after a disaster, all levels of government will pull together to ensure efficient Action Team
replacement of destroyed infrastructure with a replacement that will prevent future disastrous
results. We are specifically thinking that it would be helpful to have MassDOT work with FEMA, the
Massachusetts Department of Environmental Protection, Regional Planning Agencies, and
municipalities to ensure that everyone is all prepared to replace those crossings that have washed
out repeatedly or that require constant maintenance, with crossings that will not only allow
ecosystem processes to proceed naturally, but also will not wash out or require constant
maintenance.
Thank you for your feedback . We would be happy to
participate in such a conversation.
14
A further suggestion, first raised by MassDOT staff, would be to have available temporary bridges Berkshire Environmental
of varying lengths, so if there is storm damage, towns could quickly make the road serviceable
Action Team
while planning a permanent solution that will meet the Massachusetts River and Stream Crossing
Standards and prevent future wash outs. We believe this would require working ahead of time with
FEMA to ensure they will pay for a permanent solution rather than paying over and over again for
inadequate fixes thereby wasting taxpayer dollars.
MassDOT tries to be innovative to address challenges,
and will bring this suggestion into disaster recovery
planning.
Page 71 of 74
Berkshire Environmental
Action Team
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
15
Use LID concepts where applicable - bioswales for drainage + stormwater reduction along
highways - rain gardens for smaller scales - use appropriate-sized vegetation to slow and absorb
runoff
use vegetation and green design to address surface drainage issues and alleviate sewage backup problems by using swails and rain gardens as design elements along streets/hwys and
sidewalks
GreenDOT Open House
Amherst
16
GreenDOT Open House
Amherst
17
Design new and replacement culverts + storm management facilities to revised historic
precipitation forecast estimates (Cornell University) need to be more robust
GreenDOT Open House
Amherst
18
Stream Crossings: The habitat fragmentation issue is particularly problematic for aquatic life and Mass Audubon
species associated with riparian habitats, such as fish and turtles, but it also impacts a wide
range of species. Tens of thousands of road and rail crossings across the state divide rivers and
streams into discontinuous segments with culverts that most native species cannot traverse. The
effective length of rivers has been reduced from the natural extent of hundreds or even thousands
of miles to distinct segments only a couple of miles or even less in length.
19
The habitat fragmentation impacts of transportation networks are of even greater concern in the
Mass Audubon
face of climate change, as these facilities present impassable barriers preventing plants and
animals from migrating to suitable habitats as the conditions in their present location change. The
UMass Conservation Assessment and Prioritization System (CAPS) has mapped the ecological
integrity of each location across the entire state, and is conducting an analysis of stream
crossings to prioritize locations where improvements would have the greatest benefit.
20
Furthermore, many of the inadequately sized stream crossings are also at high risk of wash-outs Mass Audubon
during storm events. With high intensity storms anticipated to increase in frequency due to climate
change, improvements to stream crossings is of benefit to the integrity of the infrastructure and
protects public safety, in addition to the ecological benefits.
Response and Proposed plan revisions
(if applicable)
Add new indicator in Water theme: Environmentally
sensitive design / Low Impact Design (LID) in new
construction projects utilized
New Water Indicator to be added: Revised extreme
precipitation data utilized for rainfall, flood flow, and
stormwater calculations
Thank you for your feedback.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
Thank you for your support of the GreenDOT goals
21
The GreenDOT plan makes a commitment to have all new and replacement road and railroad
projects conform to the state Stream Crossing Standards. Mass Audubon supports strong
implementation of this initiative.
Mass Audubon
22
Wetlands Restoration: The plan includes a commitment to undertake 5 wetlands restoration
projects (voluntary projects not required as mitigation for wetland alterations), by 2015. We
encourage MassDOT to set a higher goal for 2015, and to include a specific goal for numbers of
wetlands restoration projects by 2020.
Mass Audubon
Page 72 of 74
Thank you for your feedback no proposed revision to
the plan at this time
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
23
Stormwater: Stormwater is the largest source of pollution in the Commonwealth. Many existing
transportation facilities were built before stormwater management standards were in place. The
plan provisions for stormwater improvements are positive but should go further, with a
commitment to incorporate stormwater improvements including Low Impact Development and
Green Infrastructure techniques wherever feasible on all new and reconstruction projects.
Mass Audubon
Thank you for your feedback.
24
The reference to rainwater harvesting provisions in this draft is excellent. We would recommend
Pioneer Valley Planning
that MassDOT help overcome shortcomings of permitting for this approach in the state plumbing Commission
code.
We will work with other state agencies through Leading
by Example to address the challenges in the plumbing
code
25
We would also recommend that all projects explore the use of right-of-ways for improving
stormwater management, as an additional indicator.
Revised to: All projects design to include measures
for increased infiltration and reduced stormwater
volumes
26
It is unclear which stream crossing standards will be used under the tasks of “Adapt facilities for Pioneer Valley Planning
climate change resilience” and “Minimize impacts of ROWs + bridges on fluvial processes.”
Commission
There is mention of “state crossing standards,” “Highway Division Stream Crossing Handbook,”
and “enhanced stream crossing standards.” We would recommend clarifying which standards are
to be used. It may be useful to note too the standards used for the example project given on
page 66 at the McNerney Road Bridge in Becket, Massachusetts.
Will clarify language and references
27
We would recommend an indicator about emergency rebuilding following extreme weather events, Pioneer Valley Planning
such as “Design standards for reconstruction of structures and restoration of water resources
Commission
damaged during extreme weather events should be evaluated to help ensure that damage is not
repeated or worsened during similar future events.” Examples of “How Not To” rebuild such as the
case of the Chickley River in Hawley, Massachusetts following Tropical Storm Irene in 2011 could
be useful to include. There could also be a reference to the need for coordination with Hazard
Mitigation Plans and Evacuation plans efforts.
GreenDOT is hesitant to set standards for emergency
responses, but we will look into the example. This
comment will inform the broader indicator below
regarding Climate Adaption Plan - see response 33.
28
Prioritize stream crossing for replacement of culverts and bridges which are designed to better
enable fish and wildlife passage, and which are sized to accommodate increased stormwater
flows expected with climate change. The University of Massachusetts Conservation and
Assessment Prioritization System (CAPS) could be utilized as a guide.
Thank you for your comment. Your concern will be
documented for the MassDOT Divisions for
consideration in the development of their annual
GreenDOT Work Plans
29
Investigate and identify areas where highway runoff is discharged directly to waterways and
Pioneer Valley Planning
combined sewer overflow (CSO) systems, and prioritize the implementation of Best Management Commission
Practices, such as bio-retention areas to eliminate these discharges. Interstates 91 and 291 in
Springfield, Holyoke and Chicopee are priority examples.
Page 73 of 74
Pioneer Valley Planning
Commission
Pioneer Valley Planning
Commission
Feedback + Responses
Reference
number
Comment
Commenter
(if known)
Response and Proposed plan revisions
(if applicable)
30
Establish a funding program to assist communities in re-constructing urban streets as Green
Streets, using such BMPs as permeable pavement and tree box filters to retain stormwater onsite.
Pioneer Valley Planning
Commission
MassDOT will work with the Bay State Roads
technology transfer program to assist communities in
implementing BMP's. Add new indicator in Water
theme: Stormwater LID integrated into revised Project
Development Design Manual.
31
Decrease potable water use in buildings - Consider dual-flush toilets, waterless urinals and
Cape Cod Commission
composting toilets, low-flow lavatory faucets, and composting toilets and vermicomposting toilets.
32
Onsite greywater treatment and use programs for irrigation and filling toilets.
Cape Cod Commission
33
Adapt facilities for climate change resilience: Increase drainage capacities to accommodate
increased rainfall intensities.
Climate change resilience/adaptation could be another new plan and should be.
Cape Cod Commission
Add new indicator in Water theme: Climate Adaptation
Plan applicable to all MassDOT facilities adopted
34
Minimize impacts of ROWs + bridges on fluvial processes: Include tidal flushing considerations
for estuaries in bridge designs
Cape Cod Commission
Revise first indicator to reference Tidal flushing
Page 74 of 74
The indicators under reduce water use (such as 10%
and 20% reductions, dual use plumbing) in GreenDOT
will consider the use of all of the proposed fixtures and
technologies depending on the facility and location.