Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan – Transit Commitments
2014 Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
February 11, 2015
For questions on this document, please contact:
Massachusetts Department of Transportation
Office of Transportation Planning
10 Park Plaza, Room 4150
Boston, Massachusetts 02116
planning@state.ma.us
(857) 368-9800
Charlie Baker, Governor
Karyn Polito, Lt. Governor
Stephanie Pollack, MassDOT Secretary & CEO
February 11, 2015
Mr. Martin Suuberg
Commissioner
Massachusetts Department of Environmental Protection
One Winter Street
Boston, MA 02108
Dear Mr. Suuberg:
Pursuant to Section 7 of amended 310 CMR 7.36, Transit System Improvements,
please find enclosed our responses to public comments on the annual Status Report on
transit projects required under the revised State Implementation Plan (submitted to the
Department of Environmental Protection on July 22, 2014). Section 7 requires the
Massachusetts Department of Transportation to file a summary of all public comments
and written responses to those comments within 120 days of the public meeting also
required by Section 7. A public meeting was held by DEP on October 2 and 6, 2014.
This status report will be made publicly available on the MassDOT website at
http://www.massdot.state.ma.us/SIP.
If you have any questions or concerns or if we can be of assistance, please do
not hesitate to contact me at (857) 368-8865 or david.mohler@state.ma.us.
Sincerely,
David J. Mohler
Executive Director
Office of Transportation Planning
cc: U.S. Environmental Protection Agency, Region 1
Boston Region Metropolitan Planning Organization
Leading the Nation in Transportation Excellence
Ten Park Plaza, Suite 4160, Boston, MA 02116
Tel: 857-368-4636, TTY: 857-368-0655
www.mass.gov/massdot
Charlie Baker, Governor
Karyn Polito, Lt. Governor
Stephanie Pollack, MassDOT Secretary & CEO
State Implementation Plan – Transit Commitments
2014 Annual Status Report
Agency Responses to Public Comments
I.
MassDOT Certification
II.
List of Public Comments Received
III.
Agency Responses to Public Comments
IV.
2014 Annual Status Report
V.
Public Comments
a. Emails & Letters
b. Oral Testimony
Leading the Nation in Transportation Excellence
Ten Park Plaza, Suite 4160, Boston, MA 02116
Tel: 857-368-4636, TTY: 857-368-0655
www.mass.gov/massdot
COMMONWEALTH OF MASSACHUSETTS MASSACHUSETTS
DEPARTMENT OF TRANSPORTATION OFFICE OF
TRANSPORTATION PLANNING
MEMORANDUM
TO:
Martin Suuberg
Commissioner
Department of Environmental Protection
FROM:
David J. Mohler
Executive Director
MassDOT Office of Transportation Planning
DATE:
February 11, 2015
RE:
310 CMR 7.36 (7)(c)
This memo is intended to fulfill the reporting requirements of 310 CMR 7.36 (7)(c), in which the
Massachusetts Department of Transportation must attest that:

MassDOT has provided complete information for all requirements of 310 CMR 7.36 (7)(a).

MassDOT has provided complete information about any actual or known potential need and
reasons to delay any project required by 310 CMR 7.36(2)(f) through (j).

MassDOT has provided complete information about any actual or known potential need and
reasons for a project substitution pursuant to 310 CMR 7.36(4)(b).

MassDOT has provided complete information on the interim offset projects implemented or
proposed to be implemented pursuant to 310 CMR 7.36(4)(b) and (5)(g)4.
I certify that all of the information listed above has been provided and that MassDOT has, to the best of
its ability, fulfilled all public process and reporting requirements described in 310 CMR 7.36 (7).
__________________________________________
David J. Mohler
Executive Director
MassDOT Office of Transportation Planning
Comments Received on the MassDOT 2014 Annual SIP Status Report (by format and date)
Written Testimony
Date
Title
10/6/2014 Staff Attorney
10/6/2014 Staff Attorney
10/6/2014 Representative
10/6/2014
10/10/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014 President
10/14/2014
10/14/2014 Co-Presidents
10/14/2014 Director of Environmental
and Transportation Planning
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/14/2014
Chief Executive Officer
President and CEO
President
Town Manager
President
Multiple
10/14/2014
10/14/2014
10/14/2014 Speaker
10/14/2014
10/14/2014
10/14/2014
10/15/2014
10/15/2014 Representative
First Name
Rafael
Rafael
Denise
Jeffrey
Linda
Frederick
Matthew
Elisabeth
Ellin
Ken
Alan
Susanne
Last Name
Mares
Mares
Provost
Morrow
Carrubba
Salvucci
Danish
Bayle
Reisner
Krause
Moore
Rasmussen
Leonard
Thomas
Richard
Alan
James
John
John
Tom
Eric
Harry
Tower
Glynn
Dimino
Fein
McKenna
Sanzone
Roland Elliot
Lamar
Weil
Mattison
Karen
John
Robert
Kevin
Eliahu
Kevin
John
Carlo
Molloy
Vitagliano
DeLeo
Cuddeback
Sussman
Donovan
MacDougall
Basile
Affiliation
Conservation Law Foundation
Conservation Law Foundation
Massachusetts House of Representatives
Additional Authors
Somerville Transportation Equity Partnership
Friends of the Community Path
City of Cambridge
Lynn Weissman
Massport
A Better City
Kendall Square Association
Town of Winthrop
Friends of the Grand Junction Path
Multiple
Massachusetts House of Representatives
Massachusetts House of Representatives
Steven Bercu, Glen Berkowitz (Livable Streets Alliance), Preston
Buehrer, Matthew Danish, Paola Ferrer, Galen Mook, Jessica
Robertson, Jimmy Sloan, Brent Whelan, Joshua Wilson
Comments Received on the MassDOT 2014 Annual SIP Status Report (by format and date)
Oral Testimony
Date
Title
10/2/2014 Staff Attorney
10/2/2014
10/6/2014
10/6/2014
10/6/2014 Co-President
First Name
Rafael
Last Name
Mares
Wig
John
Fred
Lynn
Zamore
Vitagliano
Salvucci
Weismann
Affiliation
Conservation Law Foundation
Somerville Transportation Equity Partnership,
Mystic View Task Force
Winthrop Resident
Friends of the Community Path
Additional Authors
Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan - Transit Commitments
2014 Annual Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
February 11, 2015
For questions on this document, please contact:
Massachusetts Department of Transportation
Office of Transportation Planning
10 Park Plaza, Room 4150
Boston, Massachusetts 02116
planning@state.ma.us
(857) 368-9800
INTRODUCTION
This document summarizes and responds to public comments received by the Massachusetts
Department of Transportation (MassDOT) on the State Implementation Plan-Transit
Commitments 2014 Annual Status Report (the Status Report) submitted to the Massachusetts
Department of Environmental Protection (DEP) on July 22, 2014 in order to fulfill the
requirements of 310 CMR 7.36, Transit System Improvements. The Status Report detailed the
status of three public transit projects – listed below – required of MassDOT under 310 CMR
7.36 and not yet complete. The projects are:
 Fairmount Line Improvement Project
 Red Line/Blue Line Connector - Final Design
 Green Line Extension to Somerville and Medford
MassDOT accepted public comments on the Status Report through October 14, 2014, following
two public meetings (held on October 2, 2014 and October 6, 2014) at which MassDOT staff
presented an overview of the contents of the Status Report and members of the public asked
questions and provided feedback and comments. The majority of the comments received by
MassDOT pertained to the Petition to Delay the extension of the Green Line to Somerville and
Medford, and MassDOT’s proposed interim emission reduction offset measures although
comments were also received on the other State Implementation Plan (SIP) projects, as well as
on non-SIP issues. MassDOT staff reviewed all of the comments received – they are appended
here in full, as is a list of all of the submitting individuals and organizations – and have grouped
and summarized them so as to capture the salient ideas while reducing redundancy and
overlap. In this document, indication of the authorship of each comment has been omitted.
Each year, MassDOT receives comments and questions in response to the Status Report that
are similar to comments and questions received in past years. When that happens, MassDOT
will often refer the commenter back to an earlier response or, if the issue has changed in a
meaningful way, will clarify and update earlier responses as appropriate. MassDOT staff
recognize that major decisions relating to the implementation of SIP projects do not, and likely
cannot, satisfy all project advocates, and that decisions can and will continue to generate public
controversy into the future, even when MassDOT considers an issue to be resolved. MassDOT
will continue to respond to questions and concerns as they come up, and is grateful for the
comments received on this Status Report and for the ongoing passion and commitment that so
many individuals and organizations bring to the SIP projects.
Throughout this document, the SIP regulation (310 CMR 7.36) is referenced. Additional
information and detail on the regulation (310 CMR 7.36) can be viewed at:
http://www.massdot.state.ma.us/SIP.
Project Updates
For the latest status of the SIP projects, please see the most recent monthly SIP status reports,
which can be found online at: http://www.massdot.state.ma.us/SIP.
Massachusetts Department of Transportation
February 11, 2015
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SIP 2014 - Page 1
Public Input
The projects described in the Status Report each have public input processes associated with
them, but the public process associated with the SIP itself provides an additional opportunity
for MassDOT and the MBTA to hear from interested individuals and organizations about the
progress and direction of our projects. This is a valuable reminder that our projects serve real
people in real communities, and we strive to shape our efforts to meet the needs of the users
of the transportation network, both present and future. At the same time, the framework of
the SIP obliges us to retain a regional perspective and to understand that the portfolio of
projects mandated under the SIP is intended to work together to bring benefits to the Boston
Metropolitan Region as a whole.
Transportation Funding
MassDOT and the MBTA must always be sensitive to the overall constrained fiscal climate of
both the MBTA and the Commonwealth, constraints which have grown more severe over the
years during which the SIP projects have evolved through planning, design, and into
construction. As many may be aware, the Commonwealth engaged in a lengthy debate during
2013 about the appropriate level and by what means transportation should be funded in the
Commonwealth, ending with the provision of new revenues to support the activities of
MassDOT and the MBTA at a level less than what had been recommended, but sufficient to
continue the construction of the Green Line Extension project. The MBTA received a Federal
Funding Grant Agreement (FFGA) from the Federal Transit Administration (FTA) but other
funding issues confront MassDOT with the repeal of the annual inflation – based gas tax
increase by voters in 2014.
Green Line Extension Project – Petition to Delay- The petition to delay the Green Line
Extension project was submitted by the Massachusetts Department of Transportation
(MassDOT), in conjunction with Massachusetts Bay Transportation Authority (MBTA) to the
Massachusetts Department of Environmental Protection (DEP). Since the GLX project was not
completed by the date in the Transit Regulation (12/31/2014), steps were taken to implement
some type of project or service improvements that can be in place by this date which will have
air quality benefits (for those pollutants listed in the regulation) that would have been achieved
if the GLX were fully operational by that date.
Interim Offset Mitigation Measures Recommendations
MassDOT proposed and implemented a series of air quality projects by the December 31, 2014
deadline. These measures will serve to meet – and in fact exceed – the emission reductions that
would have been in place due to the GLX project. MassDOT and the MBTA have identified three
interim emission reduction offset measures which together would meet the required emissions
reduction targets and provide valuable transportation benefits in the period prior to the full
implementation of the Green Line Extension project. Although the Transit Regulation does not
require that an interim offset be in the same area as the project, the package of proposed
measures were developed with this goal in mind. Other considerations were the ability of the
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February 11, 2015
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SIP 2014 - Page 2
interim service to be in place on or before December 31, 2014, to avoid overtaxing the MBTA’s
existing fleet, and to minimize the impact on the MBTA’s operating budget.
Many of the comment letters submitted in response to the Status Report included additional
recommendations for interim offset mitigation measures to compensate for the delayed
implementation of the Green Line Extension project. MassDOT appreciates that there is
substantial public interest in the selection of appropriate interim mitigation measures.
Project Completion
As discussed in the annual report and in the monthly status reports, MassDOT considers the
requirement to construct 1,000 new parking spaces as part of 310 CMR 7.36 to have been
completed with the opening of Wonderland Garage on June 30, 2012.
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I. GENERAL COMMENTS
The failure to modernize all Blue Line stations is a continuing violation of the SIP, which required
that Blue Line station modernization be completed by 2008.
MassDOT previously addressed this issue in 2010. See:
http://www.eot.state.ma.us/downloads/sip/SIP_CommentResponses011110.pdf.
The Orient Heights Station is fully accessible to all passengers and large scale improvements
were made to modernize the station. The station was reopened with full accessibility in
November 2013. In March 2014, Government Center Station was closed to reconstruct the
station into a fully accessible, safer, modern, and more comfortable facility.
We remain concerned about the escalation of project delays, and the lack of urgency expended
by MassDOT in addressing these delays.
MassDOT and the MBTA have been and continue to work tirelessly to complete the different
SIP projects, and to minimize delays as much as possible. At this point, many project
commitments are fully complete, including the entire 1,000 parking space commitment, and
several elements of the Fairmount corridor, and the Green Line Extension is under construction.
While the Green Line Extension is significantly delayed and remains the largest outstanding SIP
commitment, MassDOT and the MBTA are working as expeditiously as possible to move the
project forward. In 2014, the Green Line Extension (GLX) project advanced as follows:

In March 2014, the project was recommended for $100M in funding in President
Obama’s FY2015 budget.

On May 14, 2014, the MassDOT Board approved a $118M contract for CAF USA to
supply 24 light rail vehicles for the Green Line Extension project. The new vehicles are
anticipated to be supplied beginning in late 2017 through late 2018. The MBTA is also
proceeding with the rehabilitation of eight cars to support the Phase 2/2A opening of the
extension to Washington Street and Union Square.

In May 2014, MassDOT and the City of Somerville, announced an agreement for the
construction of
the Community
Path, including
a connection to the
Cambridge/Northpoint area. The Path Extension is not part of the SIP commitment.

PCB Cleanup and Disposal Approval were received from US EPA on May 22, 2014 for the
21 Water Street site in Cambridge, and the contractor has now completed environmental
mitigation.

On October 2, 2014, the Construction Manager/General Contractor Master Agreement
and the Pre-Construction contract were signed, and a Notice to Proceed (NTP) was
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issued to the CM/GC for the early work construction contracts. The four key early work
packages, Interim Guaranteed Maximum Price (IGMP #1, IGMP #2, IGMP #3, and
IGMP#4A) have progressed through final design and, as noted, have been issued NTPs
for construction activities.

In Medford at Harvard Street, construction of the new retaining wall, the new Commuter
Rail Track 1 (T1, outbound) bridge structure and T1 relocation are complete. In addition,
the new Commuter Rail Track 2 (T2, inbound) bridge structure has been installed. The
new T2 track bed installation is underway and track installation/throw to the new T2
bridge alignment is anticipated in the next two months (weather permitting).

The soil stockpiling at the 21 Water Street site (Cambridge) and the associated soil
transport activities for the reuse of the soil as retaining wall backfill at the Harvard
Street bridge site have been completed. Remaining soils will be moved in a later IGMP
contract.

On December 1, 2014, FTA Acting Administrator notified applicable Congressional
committee leadership its intention to execute the FFGA upon completion of the required
30 day Congressional review period. On January 5, 2015, the U. S. Secretary of
Transportation signed the FFGA for the Green Line Extension project, approving $996
million of FTA New Starts funding to support the design and construction of the Green
Line Extension project
Massachusetts Department of Transportation
February 11, 2015
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It was a major mistake to include parking lots as any sort of air quality mitigation measure.
At the time that MassDOT, the MBTA, and DEP first entered into the SIP – and then the
affiliated Administrative Consent Orders and SIP amendments – the provision of satellite
commuter parking was considered to be an effective Transportation Demand Management
technique, aimed at reducing the number of cars entering the Central Business District and
encouraging commuters to shift as much of their travel as possible to public transit and car- and
van-pooling. In many ways, the Commonwealth has been successful with satellite parking, and
MassDOT now maintains a network of well-used park-and-ride lots around the Commonwealth.
Parking spaces encourage greater use of the public transit network by encouraging motorists to
park their cars at remote locations and then board public transit to complete their trips. This
will induce a mode shift from automobile to commuter rail transit, which in turn would result in
improved air quality. They provide transportation alternatives that make it possible for
individuals to travel in such a way that will reduce the overall production of air pollutants.
Massachusetts Department of Transportation
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II. FAIRMOUNT LINE IMPROVEMENT PROJECT
Can MassDOT provide a more concrete timeline for the completion of the Blue Hill Avenue
station?
MassDOT and the MBTA remain committed to a Fairmount Line station at Blue Hill Avenue. The
MBTA and MassDOT made a final determination on the design of Blue Hill Avenue station in
May 2011, but opposition to the design and proposed mitigation continues. Community
concerns regarding the construction of a station at Blue Hill Avenue, as well as construction
challenges throughout the Fairmount Line, have resulted in a delay of the overall Fairmount
Line Improvement Project. In terms of schedule, MassDOT recognizes that this delay has
triggered the Project Delay component of the SIP regulation and is operating interim offset
mitigation. The 90% design plans are expected in March of 2015, with 100% plans in June 2015,
and construction is scheduled to begin in fall 2015. If this schedule holds the station opening
will be in December 2017.
Massachusetts Department of Transportation
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III. CONSTRUCTION OF 1,000 NEW PARKING SPACES
MassDOT failed to include the 1,000 new parking spaces required by the SIP in its 2013 and
2014 status reports. There have been significant changes since MassDOT stopped reporting and
there is potential of further changes. DEP should require MassDOT to continue reporting on this
requirement until the full accounting of parking spaces is settled.
MassDOT considers the requirement to construct 1,000 new parking spaces as part of 310 CMR
7.36 to have been completed with the opening of Wonderland Garage on June 30, 2012.
MassDOT ceased reporting on the parking space commitment as of the 2013 annual SIP report.
All parking related projects slated to fulfill the SIP commitment are now complete.
Massachusetts Department of Transportation
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IV. RED LINE/BLUE LINE CONNECTOR
The proposed Red/Blue Line Connector would be a significant addition to the MBTA Rapid
Transit System. This project would link the only two lines that do not currently intersect within
the rapid transit system. MassDOT should consider completing the design of the project.
MassDOT’s proposal to amend the Transit System Improvement Regulations to eliminate the
Red Line/Blue Line Connector design requirement and to not propose a substitute project was
based on the fact that the Commonwealth does not have (and will not have in the foreseeable
future) the resources to construct an estimated $700 million project and, therefore, spending
$48 million (estimated) on design now would be a poor use of taxpayer dollars.
MassDOT believes that it is irresponsible to devote scarce public resources at a time of such
great need to the design of a project for which MassDOT and the MBTA clearly do not have the
financial capacity to implement over the next two decades.
MassDOT is overestimating or purposefully inflating the costs of completing design for the Red
Line/Blue Line Connector intentionally in order to justify the proposed removal from the SIP.
MassDOT’s explanation of their budget estimating fails to disclose that a higher inflation rate
was utilized. MassDOT also did not explain why it used less favorable assumptions within the
cost estimate than any other transit project currently under review.
The cost estimates prepared for the Draft Environmental Impact Report for the Red Line/Blue
Line Connector project were professional, rigorous estimates, prepared by a technical team and
reviewed by MassDOT staff. They were also the first serious analysis of the costs of the project
to be developed in a generation.
MassDOT continues to strongly reject any claim that the cost estimates prepared for the Red
Line/Blue Line Connector were purposefully inflated. Project cost estimation methodologies
vary across major capital projects. Variations are due to rising and falling construction costs, to
understanding the specific risks and uncertainties faced by each project, and to an evolving
awareness of the unique challenges faced by MBTA projects. For example, of the projects
recently or currently in planning at MassDOT and the MBTA, the Red Line/Blue Line Connector
is the only one with a substantial tunneling component, which presents its own set of
schedule/cost risks.
Massachusetts Department of Transportation
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Of the transit commitments included in the 1990 MOU none was more important than the
proposed direct connection between MBTA Blue Line and Red Line at Charles Station. This
project would enhance transit access to the Massachusetts General Hospital for all the Blue Line
communities. DEP should rescind its decision of October 8, 2013 that approved MassDOT’s
request to eliminate the Red/Blue Line Connector design as an obligation.
Although this project could have future benefits the financial constraints facing the MBTA
restrict the ability to pursue this project. On October 8, 2013, the Department of Environmental
Protection released a new SIP regulation that eliminates the requirement for the design of the
Red Line/Blue Line Connector. On December 1, 2014, the Environmental Protection Agency
(EPA) published in the Federal Register a proposed rule to approve a State Implementation Plan
(SIP) revision submitted by the Commonwealth of Massachusetts on November 6, 2013. This
proposal, if finalized, would remove the design of the Red Line/ Blue Line Connector as a
requirement in the SIP. The public comment period closed on December 31, 2014. MassDOT is
not currently aware of the timing of the EPA’s decision.
Massachusetts Department of Transportation
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V. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD
The Green Line Extension project continues to be plagued by delays, which MassDOT has not
fully explained. In its 2012 and 2013 SIP status reports, MassDOT estimates that service to
College Avenue Station will open by July 2019. The PMOC/FTA Risk Assessment completed in
late Winter of 2011 with a report dated August 2011, however, states in its executive summary
that the “schedule risk modeling points to a revenue service date that could slip from October
2015 to the range of March 2017 to December 2017”. MassDOT provides no explanation for the
additional nineteen months delay in its petition to DEP, its 2011, 2012, and 2013 SIP status
reports, or otherwise, which violates the Transit System Improvement regulations.
As Indicated in the MassDOT August 2011 SIP report, the MBTA Green Line Extension (GLX)
team did an additional Risk and Schedule review after the above referenced PMOC/FTA
Assessment.
As a result of this analysis, the projections for the GLX project had been refined. Under the
revised timeframe, passenger service would begin no earlier than the fall of 2018 and no later
than the summer of 2020. The MassDOT January 2012 SIP monthly report also indicated the
anticipated range of completion dates based on using one D/B contract. The range of projected
dates for initiation for full revenue service for the Green Line Extension is:


10% probability of completing in Autumn 2018
90% probability of completing by the Summer 2020
As reported in the latest SIP information and the dates included in the now fully executed Full
finding grant agreement between MassDOT and the FTA the targeted completion date for
Green Line service to College Avenue Station is currently projected to be June 2020, a date that
is within the range of dates presented in 2011/2012. The FFGA also includes a one year
additional schedule contingency such that the outside completion date that would be in
accordance with the FTA grant would be July 2021.
Given the delays that have postponed the completion of the Green Line Extension project (Phase
I) into the 2020’s, it is time to reinstate the preferred full-build alternative long advocated by
MassDOT, namely a terminus at Route 16/ Mystic Valley Parkway. One notable absence in the
Annual Status Report was any reference to the extension of GLX to Mystic Valley Parkway/
Route 16. While not part of the SIP MassDOT should be referencing the Route 16 phase of
project in its annual and monthly status reports as it does with the Community Path, another
non-SIP commitment.
MassDOT is committed to fully designing and constructing the extension of the Community
Path, in collaboration with the City of Somerville and advocates for the Path, so that it is
effectively integrated with the Green Line Extension. The annual and monthly SIP reports refer
to the Community Path extension because of its integration into the construction of the Green
Line. The extension of GLX to Mystic Valley Parkway/ Route 16 is not part of the Full Funding
Grant Agreement (FFGA) nor is it a SIP requirement. The GLX extension from College Avenue to
Massachusetts Department of Transportation
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Route 16 is a MPO funded project. This project is programmed in the Federal Fiscal Year (FFY)
2015-2018 Boston MPO Transportation Improvement Program (TIP) and MassDOT’s FFY 20152018 State Transportation Improvement Program (STIP).
The Interim Offset Measure for the Green Line Extension project’s delay, 20% increase in offpeak vehicle trips per hour for all Green Line services: hope that the proposal to increase “all
Green Line services” requires a specific increase in service to Lechmere station. Provide
increased off peak service on bus lines 80 and 88.
The interim offset measure to provide 20% increase in off-peak vehicle trips per hour on an
average weekday has occurred for all Green Line branches, B, C, D, and E. This measure
provides additional service to Lechmere station, which is a major transfer point for many of the
customers who are currently in the service area and will ultimately be customers of the GLX
extension. The twenty percent increase in the number of vehicle trips per hour has also
occurred on MBTA bus routes including Routes 80 and 88.
Interim Offset Measure for the Green Line Extension project’s delay, 20% increase in off-peak
bus service in the GLX corridor: Please add more service to the #90 bus and #85 buses.
MassDOT and the MBTA developed and implemented interim offset measures, programs, and
projects that realize air quality improvements, which in 2015, would be greater than what
would have been achieved by constructing the GLX. The 20% increase in off-peak bus service
has occurred for five of MBTA’s key bus routes 80, 88, 91, 94, and 96. At this time MassDOT is
not in a position to increase the service to any other routes in the corridor.
Interim Offset Measure for the Green Line Extension project’s delay, purchase of 142 hybrid
vehicles should not be double-counted as SIP commitment, since it is already required to meet
GreenDOT carbon emission reduction goals.
The 142 new hybrid electric vehicles are energy efficient and clean burning vehicles. These
vehicles allowed the MBTA to retire much older, less fuel efficient and dirtier vehicles. The
purchase of these vehicles is one of the interim offset measures identified by the MBTA and
MassDOT to improve air quality benefits in the region. GreenDOT is MassDOT’s comprehensive
environmental responsibility and sustainability initiative. It is an initiative that provides
flexibility to MassDOT Divisions and the MBTA to include projects, investments, and programs
that they believe effectively meet the goals of GHG reductions. Since GHGs are not part of the
SIP commitment this is not germane. Changing the MBTA fleet from dirtier and less fuel
efficient vehicles to much cleaner vehicles fulfills interim offset measures.
Interim Offset Measure for the Green Line Extension project’s delay, the addition of 374 Park
and Ride Spaces in Salem and 378 more commuter parking spaces at Beverly Station should not
be permitted as for GLX interim Offsets, because the parking garages were already under
contract. The spaces also do not benefit Somerville, which has the most air quality impacts
Massachusetts Department of Transportation
February 11, 2015
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during this mitigation period. Thus far, the Beverly garage has had only a 20% utilization rate,
underperforming expectations.
The air quality benefits of the GLX investment are regional therefore an offset measure such as
the addition of park and ride spaces within the region is mitigation. The utilization of the
Beverly garage is growing and is now up to 50%. MassDOT does not agree that the SIP prevents
projects that are in progress from being an offset measure. MassDOT has stated previously that
interim offset measures are not committed to the corridor, rather to the region.
A second proposed interim offset measure, the purchase of new The RIDE vehicles, will result in
lower emission reductions than estimated due to the application of incorrect miles per gallon
rate in the calculation of its air quality benefits.
CTPS assisted MassDOT in calculating the emission benefits associated with the Interim Offset
Measures for the SIP. One of the proposed offset measures was replacing The RIDE fleet of
Crown Victorian vehicles, which were produced 2005-2007 and got an average fuel economy
for highway/city driving of 17mpg; with the more fuel efficient Ford Fusions. The MBTA
researched the fuel economy of the 2014 Ford Fusions in the winter of 2013/2014 using the
federal website fueleconomy.gov and identified they got an average fuel economy of 47 mpg.
The 47 mpg was used to calculate the emissions used in the Interim Offset Measure Report
CTPS produced in April 17th, 2014. By the summer of 2014, after further vehicle testing, the fuel
economy website revised the average fuel economy of Ford Fusions downward to 42 mpg.
Once this change was discovered, CTPS updated the calculations using an average economy of
42 mpg for The RIDE vehicles in order to understand what impact it had on emission benefits.
The update showed that even though the drop in fuel economy reduced the emissions benefits,
the reduction was not significant enough to drop it below the threshold of the target.
The table below shows the emissions reductions for the Ride vehicles and the total emission
reductions relative to the target:
Emission Reductions from The RIDE
Emissions reductions from The Ride
Assumptions
Ford Fusions at
47mpg
Ford Fusions at
42mpg
Target
Emissions reductions relative to the
target
CO
NOX
VOC
578.4
25.7
16.8
CO
125.2
NOX
5.3
VOC
3.6
116.7
4.9
3.4
569.9
25.3
16.6
N/A
N/A
N/A
459.2
22.4
13.5
Other Suggested Ideas for Offset Measures:
MBTA should add new bus routes or increase other existing bus services.
Massachusetts Department of Transportation
February 11, 2015
Page 13
SIP 2014 - Page 13
MassDOT and the MBTA must always be sensitive to the overall constrained fiscal climate of
the available resources while considering new or increased service. Such a consideration must
be balanced with competing needs across the service area. Therefore the MBTA is not in a
position to increase or add additional service without impacting other service.
Install bus priority sensors and signal prioritization to traffic signals in Somerville, Medford, and
Cambridge.
Installation of sensors and implementing signal prioritization are infrastructure projects that
would require ample time and resources to design and implement such measures. MassDOT
would need partnerships with the cities of Somerville, Medford, and Cambridge to implement
these projects as most local streets are city owned. The time for implementation and resources
required make this suggestion infeasible as a mitigation idea.
Provide free or subsidized (by MassDOT) Hubway memberships to those living in the Green Line
Corridor, or at least its Environmental Justice (EJ) blocks.
While this proposal may positively impact mode shift, providing incentives such as free or
subsidized Hubway memberships to those living in the GLX corridor will prove un-equitable to
other communities in the metropolitan area.
Build the Community Path Extension and Twin Cities Path Spur.
On April 30, 2014 MassDOT announced funding the Community Path Extension which parallels
the Green Line Extension. Investments in additional bike paths must be balanced regionally and
across the state to build out a high-quality network equitably.
Utilize the cleaner commuter rail locomotives with the Fairmont and GLX corridors exclusively
due to impacts on EJ communities.
MassDOT does not believe it would be equitable to isolate the use of these locomotives in just
two corridors. Other corridors within the commuter rail network pass through EJ communities
as well. The reduced burden on these communities that these locomotives contribute to should
be equitably distributed.
Remove the McGrath Highway.
MassDOT would not be able to achieve this as an offset measure during the period in which
mitigation is required.
Elements of the Urban Ring Corridor
As of January 2010, MassDOT is no longer advancing the Urban Ring project.
While bus
connections in the corridor identified in the comment letter may have some utility, the benefit
Massachusetts Department of Transportation
February 11, 2015
Page 14
SIP 2014 - Page 14
over the existing service is not always clear. In many instances, buses would have to run at a
very high frequency, even during off-peak, uncongested travel, in order to be competitive with
the existing rail trip. Moreover, transfers would not be eliminated for all passengers who
require use of the existing rapid transit line. While the Lechmere to Kendall connection may
prove promising due to the travel time savings, EZ-Ride already offers shuttle service
connecting these points during peak travel times. The Kendall to Kenmore service may also
have some benefit due to the demand and potential travel time savings; however, the MBTA
already provides very frequent bus service along Massachusetts Avenue, which is a short walk
from both Kendall and Kenmore squares. For the other proposed connections, the
improvement over the existing service, particularly at peak times, would be tenuous at best. In
light of MassDOT and the MBTA’s financial constraints, we would only want to pursue projects
that have a clear benefit for our customers.
To mitigate the Green Line Extension delay, MassDOT should implement the Grand Junction
DMU rail shuttle service from the recently announced West Station over a new track rail plus
bike and pedestrian bridge over the Charles, with a stop in Kendall area, and connecting to the
North Station, as announced in MassDOT CIP. MassDOT should commit to constructing a
structurally sound Grand Junction replacement bridges over the Charles River and Soldiers Field
Road as part of the I-90 Allston Interchange Project.
The Transit Commitment Regulations require that for delayed projects, MassDOT shall
implement interim emission reduction offset projects or measures during the period of delay.
All the three MassDOT and the MBTA proposed and implemented interim offset measures went
through a public and technical process. Steps were taken that these measures would be in
effect by the December 31, 2014 deadline. The Grand Junction DMU rail shuttle service is
infeasible for mitigation given the fact that the proposed West Station could not be constructed
in the time frame required to mitigate the Green Line delay. The MBTA does not currently have
DMU’s to run such a service, although they are in the process of procuring a number of these
vehicles. MassDOT and the MBTA believe that the interim offset measures in place adequately
address the air quality issues associated with the delay in the construction of Green Line
Extension project.
Massachusetts Department of Transportation
February 11, 2015
Page 15
SIP 2014 - Page 15
Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan – Transit Commitments
2014 Status Report
Submitted to the Massachusetts Department of Environmental Protection
July 22, 2014
For questions on this document, please contact:
Massachusetts Department of Transportation
Office of Transportation Planning
10 Park Plaza, Boston, Massachusetts 02116
planning@dot.state.ma.us
SIP 2014 - Page 16
INTRODUCTION
This report is submitted by the Massachusetts Department of Transportation (MassDOT), in
conjunction with the Massachusetts Bay Transportation Authority (MBTA), to the Massachusetts
Department of Environmental Protection (DEP) in order to fulfill the requirements of 310 CMR
7.36(7), Transit System Improvements. Below is a project description and status information for each
of the outstanding public transit projects required under the amended State Implementation Plan
(SIP).
As noted in previous Status Reports, MassDOT is no longer reporting on Blue Line Platform
Lengthening and Station Modernization, the Greenbush Commuter Rail Restoration and the
Construction of 1,000 Parking Spaces. All of those projects have been completed and MassDOT
believes that the relevant commitments have been met.
As always, MassDOT hopes to make the annual Status Report process one of iterative
improvement, and looks to DEP and to the public for comments and other suggestions to refine
its efforts.
This report (along with past reports and supporting documents) will be posted to MassDOT’s SIP
Regulations website at: www.state.ma.us/massdot/SIP.
SIP 2014- Page 17
I. FAIRMOUNT LINE IMPROVEMENT PROJECT
SIP Requirement
Before December 31, 2011, construction of the following facilities shall be completed and opened to full
public use: Fairmount Line improvements consisting of enhancements of existing stations including without
limitation: platform extensions; improved lighting and improved access; a new station in the general location
of Four Corners, and a new station in each of the neighborhoods of Dorchester, Mattapan and Roxbury; and
bridge upgrades and other measures to improve service and increase ridership (the Fairmount Line project).
EOT 1 shall meet the following interim deadlines for the Fairmount Line Project:
A. One year from the effective date of this regulation (December 1, 2006), develop a Request for Proposals for
a design consultant, complete the competitive procurement process, and issue a notice to proceed for a design
consultant.
 Done
B. Within two years following the issuance of a notice to proceed, complete final design, apply for all
necessary permits and grants, file any required legislation, and initiate all public and private land acquisition.
 Done (for all elements of the project except for Blue Hill Avenue Station)
Project Description
The 9.2-mile Fairmount commuter rail line runs from South Station, previously served four
stations (Uphams Corner, Morton Street, Fairmount, and Readville) in the communities of
Dorchester, Mattapan, and Hyde Park, and terminates in the Readville section of Boston. The
line, which uses right-of-way entirely owned by the MBTA, also includes 41 bridges. It is the only
commuter rail line that exclusively serves neighborhoods within the City of Boston, but ridership
has historically been low and passenger facilities along the line have not met modern standards.
The Fairmount Line Improvement Project is defined as the rehabilitation of the existing Uphams
Corner and Morton Street Stations, construction of four new stations (Newmarket, Four Corners,
Talbot Avenue, and Blue Hill Avenue), reconstruction of six existing railroad bridges (located over
Columbia Road, Quincy Street, Massachusetts Avenue, Talbot Avenue, Woodrow Avenue, and
the Neponset River), and construction of a new interlocking and upgraded signal system (required
to advance the bridge reconstruction work). The intent of these upgrades has been to enhance
future service, allowing for increased frequency on the line.
Planning Conformity
Throughout the life of the project, improvements to the Fairmount Line have been included in all
relevant transportation planning documents, including the Regional Transportation Plans of the
Boston Region Metropolitan Planning Organization (MPO).
1
EOT is the predecessor to the legislatively-created Massachusetts Department of Transportation (MassDOT). For the
purposes of referencing 310 CMR 7.36(7) Transit System Improvements of the SIP, this report will continue to use the
EOT designation. However, the MassDOT designation will be used for all other language or text contained in this
report.
SIP 2014 - Page 18
Project Status
The sections below describe the current status of the different elements of the Fairmount Line
Improvement Project.
Systems
Necessary upgrades to the required interlocking and signal systems have been completed and are
currently in use, which has allowed for the reconstruction of structurally deficient bridges along
the Fairmount Line.
Bridges
A construction contract to replace the Columbia Road, Quincy Street, and Massachusetts Avenue
bridges was awarded in October of 2007, and construction was completed in 2010.
The
construction of the Talbot Avenue and Woodrow Avenue bridges, is complete (see “New
Stations” below). Construction of three bridges over the Neponset River began in fall 2010, and
was completed in summer 2013.
Existing Stations
As stated above, existing stations at Uphams Corner and Morton Street required only
rehabilitation for the project. The MBTA held a station re-opening at Uphams Corner on January
23, 2007. The reconstruction of Morton Street was celebrated at a station re-opening on July 17,
2007. New elements at both stations include extended high-level passenger platforms, accessible
walkways, canopies, benches, windscreens, signage, bicycle racks, variable messages signs, lighting,
and landscaping. Work at both stations is complete.
New Stations
Four Corners Station opened for service July 1, 2013. The station had been under construction
since January 2010.
The construction of Four Corners Station experienced delays due to
unforeseen geotechnical conditions, relocation of existing utilities, and a redesign of the inbound
sloped walkway structure at Geneva Avenue. Substantial completion of Four Corners Station
occurred in June 2013 and final construction was complete in September 2013.
The construction of Talbot Avenue Station and the Talbot and Woodrow Avenue Bridges
Rehabilitation projects began in fall 2010. The construction lasted approximately twenty-six
months, with substantial completion of the station and the bridges in October 2012 and final
completion of work in January 2013. The structural replacement of the two bridges was
completed over weekends in November and December 2011. Talbot Avenue Station opened in
November 2012.
Newmarket Station opened for service on July 1, 2013. The station had been under construction
since October 2010. Delay in the completion of the station was attributed to the discovery of an
existing power duct bank for the South Bay Shopping Center not previously identified on any
existing utility plans. The necessity to redesign elements of the inbound and outbound retaining
walls and a delay in the manufacturing of the precast concrete platform panels further contributed
to the delay.
SIP 2014- Page 19
The proposed Blue Hill Avenue Station has been the subject of significant community
controversy over the past five years. In early 2009, after design work for the station was well
underway (at the 60% design level), a small number of abutters raised concerns about negative
impacts to residences immediately surrounding the proposed station, which at the time was
proposed to have two side platforms. In an effort to address these concerns, the MBTA conducted
a new analysis of alternative station locations. This additional analysis determined that at least one
alternative location (River Street) was infeasible due to track curvature, and that two other
alternative locations (north of Blue Hill Avenue and south of Cummins Highway) would have
greater impacts to abutting residential properties than would the original design and would also
serve fewer riders at a greater cost. The MBTA developed one additional alternative that made use
of a center-island platform at the original station site in order to address some abutter concerns by
locating the platform further from homes and backyards. The MBTA then completed an
additional analysis of noise and vibration impacts (and considered mitigation measures) to try to
address any outstanding abutter concerns. Nevertheless, the MBTA continues to encounter
opposition from these abutters, who question the need for and appropriateness of any commuter
rail station at the Blue Hill Avenue location.
The MBTA and MassDOT made a final determination on the Blue Hill Avenue station in May
2011. Design of the center-island station concept is continuing, as is ongoing discussion with the
opposing abutters about appropriate mitigation. The redesign of the station has reached the 60%
level. In addition, MassDOT funded a peer review of the proposed station, to be performed by a
firm selected by the abutters. The peer review is complete and the MBTA is working with the
legislative leadership and community to develop a new schedule for completion of Blue Hill
Avenue Station. Given the unexpected delays, it is unlikely that the Blue Hill Avenue Station will
be completed before 2016, at the earliest.
Project Funding
In August 2007, MassDOT and the MBTA executed a contract to transfer approximately $39
million from the ‘immediate needs’ Transportation Bond Bill of 2007 (which provided
Commonwealth bond funding to support the costs of the SIP projects) from MassDOT to the
MBTA to support the costs of (1) signal work, (2) reconstructing the Columbia Road, Quincy
Street, and Massachusetts Avenue Bridges, (3) designing the Talbot Avenue, Woodrow Avenue,
and Neponset River Bridges, and (4) designing the Newmarket, Talbot, and Blue Hill Avenue
Stations.
A supplemental funding agreement providing $23,756,574 in Commonwealth bond funding to
the MBTA was executed in June 2009 in order to advance the construction of the station at Four
Corners. A third funding agreement, approved in June 2011 in the amount of $61,616,500, has
allowed the remaining stations (including Blue Hill Avenue) and bridges to advance. These
contracts total approximately $124.4 million in authorized spending on the Fairmount Line
Improvement Project to this point.
SIP Requirement Status
SIP 2014 - Page 20
Community concerns (described above) regarding the construction of a station at Blue Hill Avenue, as well as
construction challenges throughout the Fairmount Line project, have resulted in a delay of the overall
Fairmount Line Improvement Project beyond the December 31, 2011 SIP deadline. However, three of the
four stations – Four Corners, Talbot Avenue, and Newmarket – are open for service, although they were
completed after the required SIP deadline. A reliable completion date for Blue Hill Avenue station continues
to be unknown at this time, although the MBTA is working to advance the project as quickly as possible,
given the strong opposition mounted by a small group of abutters.
In its efforts to encourage new riders on the improved Fairmount Line, on July 1, 2013, the MBTA
introduced a new fare structure for the Fairmount Line which makes fares on the line more competitive with
MBTA rapid transit and bus fares. Travel between any two stations on the Fairmount Line, with the one
exception of trips between Readville and South Station, has the same $2.10 fare as an MBTA subway trip.
Given the delays in final completion of the project, MassDOT prepared a Petition to Delay and an Interim
Emission Offset Plan, to be implemented for the duration of the delay. Both the Petition and Offset Plan
were submitted to DEP on July 27, 2011, and are posted to the MassDOT SIP website.
As described in the Offset Plan, MassDOT estimated the reduced emissions expected to be generated by the
implementation of the new Fairmont Line stations. MassDOT and the MBTA, in consultation with
Fairmount Line stakeholders, identified a set of potential interim emission reduction offset measures that
would meet the emissions reduction targets. MassDOT submitted these proposed measures to DEP in a July
27, 2011 petition, after which time MassDOT and the MBTA continued to work to refine the offset concepts
for implementation, including a second letter to DEP (dated November 29, 2011) describing changes to the
proposed offsets. On January 2, 2012 (the first weekday following January 1), the offset measures were
implemented: additional trips via a dedicated shuttle on the CT3 bus route between Andrew Station and
Boston Medical Center and increased weekday frequency on the Route 31 bus. These services will remain in
place until the Fairmount Line Improvement Project is fully complete.
SIP 2014- Page 21
II. RED LINE/BLUE LINE CONNECTOR - DESIGN
SIP Requirement
Before December 31, 2011, complete final design of the Red Line/Blue Line Connector, from the Blue Line
at Government Center to the Red Line at Charles Station.
Project Description
The proposed Red Line/Blue Line Connector consists of an extension of the MBTA Blue Line
under Cambridge Street to the Red Line station at Charles/MGH. As envisioned, the project
would consist of two major components: (1) a new tunnel extending the Blue Line under
Cambridge Street from Joy Street to Charles Circle and (2) a new underground Blue Line station
connected to the existing Charles/MGH station. The project would also require a decision on
whether and how to make use of existing Bowdoin Station.
The SIP requires only that MassDOT complete final design for the project. Construction of the
Red Line/Blue Line Connector is not required.
Planning Conformity
The design of the Red Line/Blue Line connector project has been included in all relevant
transportation planning documents, including the Regional Transportation Plans of the Boston
Region MPO.
Project Status
On September 14, 2007, MassDOT filed an Expanded Environmental Notification Form with the
Massachusetts Environmental Policy Act Office. A public scoping session was held on October 17,
2007, and the Secretary of Energy & Environmental Affairs issued a certificate on the project on
November 15, 2007. Based on the project scope as defined in the MEPA Certificate on the
Expanded Environmental Notification Form, MassDOT issued a Request for Proposals on March
27, 2008 for a consultant to complete the necessary environmental reviews and engineering for the
project. MassDOT awarded a consultant contract during the summer of 2008.
MassDOT has completed the following tasks for the project:
Draft Environmental Impact Report
 The Draft Environmental Impact Report (DEIR) was filed on March 31, 2010
 A MEPA Certificate for the DEIR was issued on May 28, 2010
Public Outreach
 Six Working Group meetings were held
 A public hearing on the DEIR was held on May 3, 2010
 A project website was created
SIP 2014 - Page 22
Refinement of Alternatives/Conceptual Engineering
 Refinement of potential alternatives was performed for three options: (1) a no-build
option, (2) a tunnel option with Bowdoin Station remaining open, and (3) a tunnel option
with Bowdoin Station closed. The refinement of alternatives also included an evaluation of
potential construction options (a mined tunnel vs. a cut-and-cover tunnel) and
construction phasing schemes.
 A Definition of Alternatives/Conceptual Engineering Report was completed in November 2009.
Design Criteria
 A draft Design Criteria Report was prepared and was included with the Definition of
Alternatives Report.
Alternatives Analysis
 An Alternatives Analysis Technical Report was completed on March 31, 2010.
Design
 The conceptual design of the project is complete.
Cost Estimates
 Conceptual cost estimates were included in the Definition of Alternatives Report.
Construction Staging and Sequencing Plans
 Construction staging and sequencing plans were included in the Draft Environmental
Impact Report.
Real Estate Requirements
 Potential real estate impacts were identified as part of the DEIR.
Project Funding
The ‘immediate needs’ Transportation Bond Bill of 2007 provided state bond funding to support
the costs of the SIP projects, including the design of the Red Line/Blue Line Connector project.
The estimated funding needed to complete design increased from the $29 million estimated prior
to the initiation of the environmental review/conceptual design process to $52 million, according
to the new cost estimates completed during the development of the DEIR.
SIP Requirement Status
MassDOT has made a good faith effort to meet the commitment to complete final design of the Red
Line/Blue Line Connector, including the accomplishments listed above. However, as part of the
environmental review and conceptual design process, MassDOT determined that the ultimate construction
costs for the project would far outstrip what the project costs were believed to be at the time that the SIP
regulation was promulgated: $290 million at the time of the SIP regulation versus the best estimate of $748
million (escalated to year of expenditure) developed during the environmental review process. MassDOT has
already spent $3 million to advance the project through environmental review and conceptual design, but the
current $52 million estimate to complete final design substantially exceeds the $29 million last identified for
SIP 2014- Page 23
the effort in the 2009 Regional Transportation Plan for the Boston Region. Furthermore, MassDOT has
been unable to identify funding with which to construct the Red Line/Blue Line Connector at any point in
the next 20 years. As a matter of policy, MassDOT believes that it is irresponsible to spend precious public
funds to design and permit transportation projects for which there are no identified construction funds,
particularly given the need to continually refresh planning and permitting materials for major projects. To
pursue final design of the Red Line/Blue Line Connector project at this point would be to squander resources
that could otherwise be spent on projects for which construction funds are already committed.
Therefore, MassDOT initiated a process to amend the SIP to permanently and completely remove the
obligation to perform final design of the Red Line/Blue Line Connector. To that end, in 2011 MassDOT
officially sought approval from DEP to support a SIP amendment process, a process which has included public
input and discussion. MassDOT is not proposing to substitute any new projects in place of the Red
Line/Blue Line Connector commitment, given the absence of any air quality benefits associated with the
current Red Line/Blue Line commitment (final design only). Correspondence from MassDOT to DEP
formally initiating the amendment process was submitted on July 27, 2011, and is posted to the MassDOT
website. In response to requests made by elected officials, MassDOT and DEP provided additional
information about the history and status of the project, as well as the rationale behind the request for
amendment.
On September 13, 2012, DEP held two public hearings to take public comment on MassDOT’s proposed
amendments to 310 CMR 7.36, Transit System Improvements, including the elimination of the requirement
to complete final design of the Red Line/Blue Line Connector. Between the two hearings there were 16
attendees, 10 of whom gave oral testimony. All those who spoke at the hearings spoke in favor of DEP not
removing the commitment. DEP accepted written testimony until September 24, 2012.
On August 23, 2013, EPA sent a letter to FHWA providing an update on Massachusetts Air Quality
Conformity. In that letter, EPA noted the Red Line/Blue Line Connector Design project has not met the SIP
completion date of December 31, 2011, but that MassDOT is not obligated to implement interim emission
reduction offset projects because no emission reductions are associated with the design project.
On October 8, 2013, the Department of Environmental Protection approved a request made by MassDOT in
July of 2011 to revise 310 CMR 7.36 to remove the requirement for MassDOT to complete the design of the
Red Line/Blue Line Connector. This revision to the State Implementation Plan must now also be approved
by the U.S. Environmental Protection Agency. The timing of that final approval is currently unknown. The
text of the revision is available on the MassDOT website at:
http://www.massdot.state.ma.us/Portals/17/docs/sip/October13UpdatedSIPReg.pdf.
SIP 2014 - Page 24
III. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD
SIP Requirement
Before December 31, 2014, construction of the following facilities shall be completed and opened to full
public use: 1. The Green Line Extension from Lechmere Station to Medford Hillside; 2. The Green Line
Union Square spur of the Green Line Extension to Medford Hillside; and

On or before 18 months following the effective date of the regulation (December 1, 2006),
MassDOT must develop a request for proposals for a design consultant, complete the competitive
procurement process, and issue a notice to proceed.
 Done

Within 15 months of the completion of the above requirements, MassDOT must complete conceptual
design and file an Environmental Notification Form.
 Done

On or before two years after MEPA’s issuance of a scope for a Draft Environmental Impact Report
or a Single Environmental Impact Report, MassDOT must complete preliminary design and file a
DEIR or SEIR.
 Done

On or before one year after MEPA’s issuance of a scope for a Final Environmental Impact Report,
MassDOT must file an FEIR.
 Done

On or before 18 months after MEPA’s issuance of a certificate on an FEIR or an SEIR, MassDOT
must complete final design, apply for all necessary permits funds and grants, file any required
legislation, and initiate all public and private land acquisition.
Expected completion 2015

Upon completion of all of the above milestones, DEP and MassDOT shall establish a schedule for
project construction and deadlines for project completion.
Ongoing
Extensive information about the Green Line
www.mass.gov/greenlineextension.
Extension project can
be found at
Project Description
This project – the purpose of which is to improve corridor mobility, boost transit ridership,
improve regional air quality, ensure equitable distribution of transit services, and support
opportunities for sustainable development – will extend the MBTA Green Line from a relocated
Lechmere Station in East Cambridge to College Avenue in Medford, with a branch to Union
Square in Somerville. The project is a collaborative effort of MassDOT and the MBTA, with the
MBTA taking the lead in design, engineering, construction and project management.
SIP 2014- Page 25
Proposed Stations
New Green Line stations are currently proposed for:

College Avenue, Medford – Located at the intersection of College Avenue and Boston
Avenue in Medford, adjacent to Tufts University. The station platform will be located on
the north side of the College Avenue Bridge, which crosses over the MBTA Lowell Line.
Access to the station will be provided from both Boston Avenue and College Avenue, as
well as from the Burget Avenue neighborhood, which lies northeast of the station site.

Broadway/Ball Square, Medford/Somerville – Located at the intersection of Broadway
and Boston Avenue on the north side of Ball Square. The station platform will be located
on the north side of the Broadway Bridge, which crosses over the MBTA Lowell Line.
Access to the station will be provided from both Boston Avenue and Broadway. A traction
power substation will also be installed at this location.

Lowell Street, Somerville – Located at the Lowell Street Bridge, which crosses over the
MBTA Lowell Line adjacent to the proposed extension of the Somerville Community
Path. The station platform will be located on the north side of the Lowell Street Bridge.
Access to the station will be provided from Lowell Street.

Gilman Square, Somerville – Located in the vicinity of the Medford Street crossing of the
MBTA Lowell Line, behind Somerville City Hall, Public Library and High School. The
station platform will be located on the north side of the Medford Street Bridge, which
crosses over the MBTA Lowell Line. Access to the station will be provided from Medford
Street. The Somerville Community Path will be located adjacent and connected to the
station. A traction power substation will be installed on the south side of the corridor.

Washington Street, Somerville – Located at the Washington Street Bridge, proximate to
Somerville’s Brickbottom, Inner Belt, and Cobble Hill neighborhoods. The station
platform will be located south of the MBTA New Hampshire Main Line Bridge over
Washington Street. Access to the station will be provided via entrances located under or
adjacent to the south abutment of the bridge, in conjunction with improved sidewalk and
street-crossings in the area. The extension of the Somerville Community Path will be
located adjacent to and provide access to the station.

Union Square, Somerville – Located east of Prospect Street in the vicinity of Union
Square in Somerville. The station platform will be located within the MBTA Fitchburg
Line right-of-way east of Prospect Street. Access to this station will be provided from both
the street and bridge levels of Prospect Street.
Vehicle Maintenance and Storage Facility
The Green Line Extension also requires the construction of a new light rail vehicle maintenance
and storage facility (VMSF) in the vicinity of the Green Line Extension. The facility will be
SIP 2014 - Page 26
constructed on an L-shaped parcel in the Inner Belt area of Somerville, adjacent to the Boston
Engine Terminal. The MBTA has acquired two of the four parcels needed to build the VMSF and
is in progress on the remaining two parcels. Relocation activities are ongoing.
Somerville Community Path Extension
Until recently, the Green Line Extension project included just the design of the proposed
extension of the Somerville Community Path from the proposed Lowell Street Station to the Inner
Belt area. In May 2014, MassDOT and the City of Somerville, announced an agreement for the
construction of the Community Path, including a connection to the Cambridge/Northpoint area.
The Path Extension is not part of the SIP commitment.
Planning Conformity
The Green Line Extension project has been included in all relevant transportation planning
documents, including the Regional Transportation Plans of the Boston Region Metropolitan
Planning Organization.
Project Status
Project Team
The MBTA has established an experienced project team to manage the design and complete the
construction of the Green Line Extension project. These team members are referenced throughout
the remainder of this report:
• Program Manager / Construction Manager (PM/CM): HDR/Gilbane; functions as an
extension of MBTA staff.
• Advanced Preliminary Engineering / Final Design (APE/FD): AECOM/HNTB;
responsible for advanced preliminary engineering and final design.
• Phase 1 Contractor (Design-Bid-Build): Barletta Heavy Division.
• Construction Manager / General Contractor (CM/GC): WSK (JF White/Skanska/
Kiewit); responsible for preconstruction support services to the MBTA and is anticipated to
be responsible for the Construction of Phases 2/2A, 3 and 4 of the GLX Program.
• Owner’s Representative: Hatch Mott MacDonald; Commonwealth-required position for
projects of this size.
• Relocation Consultant: Peter W. Sleeper Associates; reports to MBTA Real Estate
preparing Relocation Plans for those properties that require relocation.
• Independent Cost Estimator (ICE): Stanton Constructability Services; provides
independent cost estimates for the project.
In addition to these team members, the GLX also works very closely with the Federal Transit
Administration (FTA) and its Program Management Oversight Consultant (PMOC) on the GLX
project.
SIP 2014- Page 27
Environmental Approvals
State-level environmental review (Massachusetts Environmental Policy Act [MEPA]) was completed
in July 2010. Federal-level environmental review (National Environmental Policy Act [NEPA])
documents were submitted to the Federal Transit Administration (FTA) in September 2011, and a
public hearing was held on October 20, 2011 (to accompany a 45-day public comment period). A
Finding of No Significant Impact (FONSI) was issued by the FTA on July 9, 2012. The July 2012
release of a FONSI completed the federal-level environmental review process, approximately seven
months later than anticipated by the Green Line Extension project schedule.
Funding Approvals
MassDOT is pursuing federal funding – through the competitive New Starts program managed by
FTA – to support the design and construction of the Green Line Extension project. The Green
Line Extension project is, in many ways, a strong candidate project for the New Starts program. In
June 2012, FTA rated the Project as a “Medium” and gave their approval for the Project to enter
the Preliminary Engineering phase. Following enactment of the Moving Ahead for Progress in the
21st Century Act (MAP-21), in January 2013 the FTA revised the project’s status from Preliminary
Engineering to Engineering. The project’s updated status allowed the MBTA to begin planning for
the submission of the Full Funding Grant Agreement (FFGA) application – which, if approved,
will codify the federal funds to be granted for construction of the project.
During September and October of 2013, the MBTA developed and submitted a Fiscal Year 2015
(FY15) New Starts Update package to FTA, which included an updated GLX Project Finance Plan.
This effort was followed by a letter from the MBTA General Manager to the FTA in late January
2014 reiterating the project’s goals and the importance of the timing of the Advance Work
approval and FFGA execution toward this end.
In March 2014, the project was recommended for $100M in funding in President Obama’s
FY2015 budget. Subsequently, on March 31, 2014, the MBTA submitted a Request for Letter of
No Prejudice (LONP) to FTA to allow advance work associated with the Fitchburg Mainline and
Millers River Drainage. On July 9, 2014, the MBTA received a letter from FTA approving the
LONP. This is a major milestone for the project, as it allows critical work to commence as
planned in August 2014.
The MBTA has been coordinating development of the FFGA application material, with the final
materials slated to be submitted in September 2014. The congressional review and execution
process may, thereafter, take as long as three months.
Budget and Schedule
In January 2014, an MBTA/FTA risk workshop was held, with active participation by
representatives from the FTA, PMOC, MBTA, Owner’s Representative (OR), Independent Cost
Estimator (ICE), Design Consultant, CM/GC and PM/CM. As part of the risk modeling process,
the participants evaluated possible base cost adjustments arising from identified risks. This
workshop resulted in a combination of base cost adjustments and risk variables for cost elements.
The preliminary results were reviewed with the project team including the FTA in mid-February.
SIP 2014 - Page 28
The FTA also requested their PMOC to run an independent risk simulation model separate from
that prepared by the MBTA.
Based on this risk analyses, the FTA determined that the final GLX project budget should be
established at $1.992 Billion, including a 30% project cost contingency. The FTA also determined
a project completion date of June 2021. This schedule includes most of the identified schedule
risks without consideration to planned risk mitigation activities. The MBTA believes the FTA’s
budget and schedule is based on an extremely conservative assessment of the Project’s ability to
mitigate many of the identified cost and schedule risks.
The FTA’s budget is important to set the upper limit for the project’s budget and federal
reimbursement levels. In addition, acceptance of the FTA’s higher project cost and later scheduled
completion actually improves the Program’s likelihood of receiving the desired FFGA. The MBTA
continues to maintain that the lower cost and faster schedule are achievable, if potential risks are
properly mitigated.
The MBTA has now established a target project budget of $1.665 Billion, including a 20%
contingency factor that is consistent with industry practice for a project at this level of design. The
MBTA has also identified a project completion date in June 2020, which is within the range of
previously announced project completion dates.
Changes from the previous estimate of the project budget are caused by additions to the project
scope, design modifications based on new information, and administrative factors. The additions
to the project scope since the last budget estimate include:
• Construction of the Community Path;
• Enhanced drainage improvements to account for 100- year storm events in the Millers
River area;
• Various changes to anticipate future increases in Green Line ridership, including longer
station platforms to accommodate four-car trains.
Design modifications based on new project information include:
• Deeper foundations and new structure designs for track viaduct sections in Cambridge,
based on extensive geotechnical boring results;
• Safety improvements to catenary pole foundations;
• Additional utility relocations beyond those originally identified.
Finally, the updated contract cost budget adjustments include additional project administration
costs to account for the phasing of the project and its duration, additional fringe benefit costs
associated with the use of union labor, and additional indirect labor costs for the Construction
Manager/General Contractor (CM/GC). The additional indirect labor rates are based upon other
states’ experiences and are subject to final negotiation between the MBTA and the CM/GC. The
cost estimate includes a 20% contingency factor, consistent with standard MBTA practice for a
project at this level of design, but lower than FTA’s assigned 30% contingency.
SIP 2014- Page 29
Project Phasing and Delivery
To tailor the project delivery method to best mitigate the larger project risks, the MBTA developed
and is implementing a phased project delivery plan, which has divided the project into four phases.
Phase 1 Early Bridge/Demolition is using the traditional Design-Bid-Build approach for (1) the
widening of two railroad bridges (Harvard Street Bridge in Medford, and Medford Street Bridge in
Somerville) to accommodate the additional Green Line tracks and (2) the demolition of the
MBTA tire storage building at 21 Water Street in the Lechmere Station area to provide parking
and staging areas for the Phase 2/2A work.
The MBTA awarded the Phase 1 contract on December 13, 2012 and issued a Notice to Proceed
to Barletta Heavy Division on January 31, 2013. The MBTA is currently adding some retaining
wall construction to the Phase 1 contract that had been programmed for Phase 4. By constructing
this work under the Phase 1 contract, this retaining/noise wall should be completed in time to
better support and facilitate the construction of Phase 4. The addition of this work will extend the
end date of the Phase 1 contract by six months
At the Harvard Street Bridge in Medford, the new (relocated) outbound Commuter Rail track
bridge structure was placed in April 2014 and fit up work continues. Installation of the temporary
support continues to allow for concrete abutment modifications and steel erection for the new
(relocated) inbound Commuter Rail track bridge structure. The installation of the new storm
drainage system and associated sewer relocation work in Winchester Street and Harvard Street will
be completed in July 2014.
At the Medford Street Bridge in Somerville, concrete abutment modification work continues in
advance of steel erection activities to widen the bridge structure (steel erection is anticipated to
begin mid-Summer 2014).
The PCB Cleanup and Disposal Approval was received from US EPA on May 22, 2014 for the 21
Water Street site in Cambridge, and the contractor has now completed environmental mitigation.
Phases 2, 3, and 4 are expected to be completed utilizing the CM/GC project delivery-approach
after legislative approval to use this method as a pilot program was given in 2012. The CM/GC
contract was approved by the MassDOT Board of Directors in July 2013. In order to advance
Phases 2, 3 and 4, the CM/GC has been conducting preconstruction services including design
reviews, participating in the bidding process and supporting the scheduling process. The CM/GC
has also been active in performing constructability assessments and recommending construction
savings opportunities. As part of the CM/GC delivery method, an Independent Cost Estimator
(ICE) was hired in October 2013. The ICE began by validating the estimate prepared by the
PM/CM and has been actively participating in the process to establish construction estimates for
the various construction work packages.
SIP 2014 - Page 30
Phase 2/2A will extend service from the (new) Lechmere Station to the Washington Street and
Union Square Stations and relocate the bus facility and vehicle storage at Lechmere Station.
MBTA’s construction phasing plans anticipate completing construction on this phase in late 2017.
Phase 3 will construct the Vehicle Maintenance and Storage Facility (VMSF). As the full storage
yard and maintenance facility are not needed to support initial (Phase 2/2A) passenger service to
Washington Street and Union Square, this phase has been scheduled to be completed some six
months ahead of the date for revenue service to the northern four stations. It is anticipated that
the relocation activities of the current occupants of the VMSF site will be completed by early 2016,
such that site cleanup and demolition will commence shortly thereafter. The property acquisition
and relocation activities (described below) are critical to the start of construction and completion
of this facility.
Phase 4 will provide service beyond Washington Street Station (completed as part of Phase 2/2A
above) to College Avenue Station. It is currently targeted to be completed in accordance with the
schedule discussed earlier in this document. The bulk of construction is anticipated to begin in
2015 after receipt of the FFGA.
New Green Line Vehicles
The MBTA advertised for the new vehicles in January 2011 and proposals were submitted in June
2011 to be reviewed by the MBTA Technical Selection Committee. In March 2013, the MBTA
requested the two proposing teams update and re-submit their proposals as a Best and Final Offer
to the MBTA; these were received in September 2013. On May 14, 2014, the MassDOT Board
approved a $118M contract for CAF USA to supply 24 light rail vehicles for the Green Line
Extension project. The new vehicles are anticipated to be supplied beginning in late 2017 through
late 2018. The MBTA is also proceeding with the rehabilitation of eight cars to support the Phase
2/2A opening of the extension to Washington Street and Union Square.
Real Estate:
MassDOT and the MBTA are collaborating on tasks associated with the property acquisition effort
for the Green Line Extension project. The list of potential property impacts has been confirmed
for most portions of construction. The MBTA continues to review and refine the identified
property impacts, including further definition of temporary easements that may be needed to
support construction as the design progresses.
Property needs have been prioritized by construction phase and construction package sequence to
track progress against the Program schedule. All acquisition packages (title review, survey and
environmental assessment) for Phase 2/2A and early Phase 4 have been submitted. License
agreements and acquisitions are under negotiation for a number of the properties. In addition,
the MBTA is in the process of acquiring the NStar property (near the Medford Street Bridge).
This property is required for early Phase 4 utility work and Gilman Square Station. Property
activities for other Phase 4 work have been initiated for approximately 80 permanent easements.
The temporary easement process will commence as Phase 4 design continues, likely beginning in
fall 2014.
SIP 2014- Page 31
The appraisal and relocation plan for the current occupants of the Vehicle Storage and
Maintenance Facility (VSMF) site was approved by the FTA. With this approval, MBTA reached
agreement with two of the property owners at the VSMF site, and payments were made to
complete the acquisitions there and start the relocation process. Negotiations with the remaining
two owners continue.
Various real estate coordination is underway with the City of Somerville. A Memorandum of
Agreement (MOA) for the Community Path was executed on February 20, 2014 in order to allow
the City to acquire parcels needed for the Path. The Union Square MOA – Amendment No. 1, to
convey necessary parcels at the Union Square Station site, is currently under review by MBTA.
The Gilman Square MOA, to convey necessary parcels at the Gilman Square Station site, has been
drafted. Completion of the various agreements will continue throughout 2014.
Design Progress
Many project design milestones have already been reached on the Green Line Extension project
over a number of years. The completed Advanced Preliminary Design was submitted in September
2013 for all portions of the project. Following this, design focus turned to completing 100%
design plans for various construction work packages. Three key early work packages have been
recently completed, including: (1) the purchase of long lead items, (2) early utility relocation work
and (3) drainage work in the Millers River area and relocation of the Fitchburg Main Line between
the Red Bridge area and Union Square.
The 90% design plans for the Phase 2/2A stations and associated work will be submitted at the
end of July 2014. The 60% design plans for Phase 4 stations and associated work will recommence
in fall 2014. Further design work associated with the VSMF will begin in spring 2015, after FFGA
approval is received.
As the station, track, wall and bridge design has continued, new challenges have developed. Some
of these new issues relate to the incorporation of geotechnical conditions for some of the viaduct
sections and at the VSMF site, while others are linked to the receipt of new, more detailed survey
information and recently identified utility conflicts. Work has also proceeded on revisions to the
Ball Square station layout to resolve NStar and MWRA utility conflicts.
Public Outreach
Public outreach on the project has included hundreds of meetings and other events over multiple
years. MassDOT and MBTA staff have met with numerous public groups, elected officials, and
other interested parties. Meetings have been held with a variety of local groups, including two
different project advisory committees and their subcommittees; design review sessions with rightof-way abutters; interagency meetings; neighborhood briefings; briefings with elected officials;
institutional and business group meetings; public meetings and hearings; land use workshops; and
‘meet and greet’ sessions, as well as many others. Meetings on the station designs as well as the
retaining wall and noise wall facades have been held to obtain community input as the Final
Design progresses. The Community Path has also been the subject of community meetings. The
SIP 2014 - Page 32
next round of meetings, targeted for fall 2014, will consider the first three stations to be
constructed. A public meeting will also be held before the start of work on the early construction
packages.
Project Funding
As highlighted above, MassDOT is pursuing federal funding – through the competitive New Starts
Program managed by FTA – to support the design and construction of the Green Line Extension
project. As noted in the current MassDOT Capital Investment Plan (released January 2014), in
addition to the use of any federal funding, MassDOT and the MBTA will use Commonwealth
funds to support the design and construction of the Green Line Extension project.
SIP Requirement Status
By filing an Expanded Environmental Notification Form, procuring multiple design consultants, and
publishing both Draft and Final Environmental Impact Reports, MassDOT has met the first four interim
milestones associated with the Green Line Extension project. MassDOT – which has committed substantial
resources to the Green Line Extension project, a top transportation priority of the Commonwealth and the
largest expansion of the MBTA rapid transit system in decades – has transitioned the project from the
planning and environmental review phases to design, engineering, and eventual construction, coupled with the
tasks associated with applying for New Starts funding.
In the 2011 SIP Status Report, MassDOT reported that the Green Line Extension project would not meet the
legal deadline of December 31, 2014. At that time, MassDOT projected a timeframe for the introduction of
passenger service on the Green Line Extension. The points within the timeframe are associated with different
probabilities, as shown below:


10% Probability of Not Exceeding – Autumn 2018
90% Probability of Not Exceeding – Summer 2020
As stated earlier in this report, the MBTA’s schedule for overall project completion remains within the range
of completion outcomes above, which were first drafted in 2011. FTA’s projected completion date is
approximately one year later, in summer 2021.
MassDOT and the MBTA continue to seek measures to accelerate the project timeline wherever possible. The
phasing approach discussed above provides for an accelerated delivery of some portions of the project. In
addition, the use of CM/GC delivery method described above is expected to aid in meeting the established
project schedule and overcoming some of the delays that were encountered related to the FONSI and the
approval to enter into the FTA New Starts program. With the FTA approval of the LONP, also discussed
above, critical program work may now commence.
A major critical path item is the completion of the next steps in the New Starts process, primarily completion
of the package for initiation of the negotiations for a FFGA, and receipt of an FFGA by December 31, 2014.
The receipt of the FFGA is a key milestone, as it restricts the start of construction for the bulk of the Phase
2/2A and Phase 4 work.
SIP 2014- Page 33
Finally, although the goal of the phased project delivery approach is to complete components in an incremental
way, the timeline for overall project completion listed above represents a substantial delay beyond the current
SIP deadline of December 31, 2014, triggering the need to provide interim emission reduction offset projects
and measures for the period of the delay (beginning January 1, 2015).
Working with the Central
Transportation Planning Staff, MassDOT and the MBTA have calculated the reductions of NMHC, CO,
and NOx – reductions equal to or greater than the reductions projected for the Green Line Extension itself, as
specified in the SIP regulation – that will be required for the period of the delay.
In June 2012, MassDOT released a list of potential mitigation ideas received from the public that could be
used as offset measures. In the summer and fall of 2012, MassDOT solicited public comments on these
potential measures. Since that time, the MBTA created an internal working group to determine a final
portfolio of interim mitigation measures to implement by December 31, 2014, the legal deadline for the
implementation of the Green Line Extension. This work resulted in a recommendation to implement the
following three interim mitigation measures which collectively would meet the emissions reduction target for
the project:



Additional off-peak service along existing routes serving the GLX corridor, including the Green Line,
and bus routes 80, 88, 91, 94 and 96;
Purchase of 142 new hybrid electric vehicles for The RIDE;
Additional park and ride spaces at the Salem and Beverly intermodal facilities.
The Petition to Delay, which expands further on the analysis and determination of the interim offset measures,
is appended to this Report, and available on the MassDOT website.
SIP 2014 - Page 34
BOARD OF DIRECTORS
Tom Andrews
Alexandria Real Estate Equities
Christopher Barr
Biog en Idee
Kelley Brown
M assachusetts Institu te of
Technology
Tim Canon
DivcoWest
Brian Dacey
CIC
Tom Evans
Cambridge Redevelopment
Authority
Alan Fein
Broad Institute
Sarah Gallop
Massachusetts Institute of
Technology
Bill Gartner
BioM ed Realty Trust
BryanKoop
Boston Pro perties
Annemarie Levins
Microsoft
feff Lockwood
N ovartis
Ryan Mack
Facebook
Stephen M eunier
Genzyme, a Sanofi com pany
Martin Mullins
Whitehead Institute for
Biomedical Research
MichaeiOwu
Massachusetts Institute of
Technology
Eric Quadrino
M exiCali Burrito Co.
feremy Rishel
T witter
Alan Smith
Boston Ma rriott Cambridge
October 14, 2014
OFFICERS
David W. Cash
Commissioner
Department of environmental Protection
One Winter Street
Boston, MA 02108
Sarah Gallop
Vice President
RE:
MichaeiOwu
Treasurer
Alan Fein
President
Steve Vinter
Vice President
MassDOT Petition to Delay Green Line Extension Project
Tom Andrews
Secretary
Dear Commissioner Cash:
The Kendall Square Association (KSA) has reviewed the Petition to
Delay (Petition) dated July 22, 2014, that the Massachusetts
Department of Transportation (MassDOT) submitted to the
Department of Environmental Protection (DEP or the Department).
In its Petition, MassDOT requests to delay the Green Line
Extension (GLX) Project, a State Implementation Plan (SIP)
requirement. It is our understanding, based on the October 6, 2014,
comments of the Conservation Law Foundation that one ofthe offset
measures proposed for the GLX Project does not meet the SIP's
requirements and therefore does not qualify as such, and that the
emissions reductions for another measure were inadvertently
overestimated and cannot be applied to the whole time period of the
delay. As a result, the set of proposed measures does not meet the
emission reductions that would have been in place due to the GLX
Project by December 31, 2014. The baseline applied to determining the
amount of emission reductions required in the first place is also too low
because it does not include the complete extension of the Green Line as
required by the SIP. We therefore respectfully request that you deny the
Petition and require MassDOT to resubmit a petition to delay with
adequate interim offset projects and measures.
Alexandra Lee
Executive Director
Cassandra Grey
Office Manager
We would like to suggest an interim offset project that would qualify
under the SIP and would provide air quality improvements. Improve bus
service linking Orange Line (Sullivan Station/Community College) to
Lechmere and Kendall Square (a new route CT4). More specifically, we
recommend that this service be provided under contract by the Charles
River Transportation Management Association. This service could begin
quickly and could provide outstanding headways and service for the
difficult connections from the north and northwest to Kendall Square.
Steve Vinter
YtfP}Iis47-5772
C.A.Webb
N e w Engla nd Venture
Capital Association
Kendall Square Association
P.O.Box 425865
Cambridge, MA 02142
a dmin @kendallsq.org
SIP 2014- Page 35
MassDOT Petition to Delay Green Line Extension Project
October 14,2014
The City of Cambridge's K2 study (2013) found that 45% (4,330) of the peak
time origins of Kendall Square commuters were north of the City. Approximately
40% of those commuters are driving, in part to avoid a multiple seat ride,
sometimes through the crowded core of the entire transit system. A new bus
service from Sullivan Station could be a powerful impetus for drivers to switch
modes of travel by providing more direct and faster transit connections. We
would like to see this route tested for its emissions elimination potential. This
could be one important part of a package of projects that will serve as an offset to
the delay
We would also like to suggest, as an interim offset project, that DEP consider a
Communication Based Train Control (CBTC) signaling system. This CBTC
system would replace the current fixed block system and would dramatically
increase headways and capacity on the MBTA's Red Line. The opportunity to
make this change is being presented by the MBTA's upcoming purchase of new
vehicles for the Red Line and Orange Line. The potential to upgrade this
technology is a once in a generation opportunity. No other system improvement
has the potential for capacity increases of such magnitude. The MBTA could
create a provision in their purchase contract to allow for implementation of this
CBTC system.
Thank you for this opportunity to comment on this important transportation and
air quality improvement opportunity.
With regards,
rr
Alan Fein, President
Kendall Square Association
CC:
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston, Massachusetts 02116
Jerome Grafe
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street Boston, MA 02108
SIP 2014 ·Page 36
From:
To:
Cc:
Subject:
Date:
Attachments:
Friends of the Community Path
Sreelatha.Alam@dot.ma.us; Grafe, Jerome (DEP)
Secretary Davey (DOT); Scott, Beverly (MBTA) ; Mohler, David (DOT); Ainsley, Mary R. (MBTA) ; arpinoshaffer@gilbaneco.com; kshaffer@gilbaneco.com; Michael.McBride@hdrinc.com; rhenke@HNTB.com;
david.farmer@hdrinc.com; JSgroi@GilbaneCo.com; Sutton, Peter (DOT); mayor@somervillema.gov;
patricia.Jehlen@state.ma.us; Timothy.Toomey@mahouse.gov; denise.provost@MAHouse.gov;
Tim.Snyder@masenate.gov; William.Sutton@mahouse.gov; mark.kennedy@mahouse.gov; Raffi.Freedman Gurspan@mahouse.gov; daniel.weber@mahouse.gov; aldermanconnolly@gmail.com;
MJRossetti@somervillema.gov; aldermansullivan@aol.com; aldermanwhite@comcast.net;
mmclaughlin@somervillema.gov; mheuston@hotmail.com; RMcWatters@somervillema.gov;
tony@tonylafuente.com; M.Niedergang@comcast.net; rebekah.gewirtz@gmail.com; katjana@katjana.org;
hmorrison@somervillema.gov; sspicer@somervillema.gov ; wdeignan@cambridgema.gov ;
jrosenblum@cambridgema.gov; tobrien@hyminvestments.com; reisnere51@gmail.com; wigzamore@gmail.com;
kmolloy@gmail.com ; grandjunctionpath@gmail.com; denison@gmail.com; kara@livablestreets.info;
steve@livablestreets.info; snutter@gmail.com; david@massbike.org; bostongreenroutes@somervillebikes.org ;
djessicamink@gmail.com; pete@bostoncyclistsunion.org; jason@bostoncyclistsunion.org;
ehalvorsen@mapc.org ; EBourassa@mapc.org ; JRaitt@mapc.org ; TReardon@mapc.org ;
mlevy@somervillecdc.org; andre@ma-smartgrowth.org; mlevy@somervillecdc.org; dleblanc@somervillecdc.org ;
chris@groundworksomerville.org ; rmares@clf.org; info@somervillebikes.org; wlandman@walkboston.org;
alan@pathfriends.org; rachy.rb2@gmail.com; jonah@petri.us; friendspath@yahoo.com;
grandjunctionpath@gmail.com
GLX Petition to Delay; Interim Offsets. SIP Comments from Friends of the Community Path
Tuesday, October 14, 2014 12:57:54 PM
GJP CPX gap map -01_CPX-GJP Gap.png
GJP Options from Fei Peng in PDF.pdf
October 14, 2014
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning, Room 4150
Ten Park Plaza, Boston, MA 02116
Jerome Grafe
Mass DEP Bureau of Waste Prevention
One Winter Street, Boston, MA 02018
Re: GLX Petition to Delay; Interim Offsets. SIP Comments in Support of GLX, CPX, Red-Blue
Connector, and GLX Mitigation
To Sreelatha Allam and Jerome Grafe:
We take this opportunity on behalf of the Friends of the Community Path, a regional group with ~1400
members, to comment on the annual State Implementation Plan (SIP) Transit Commitments report (
http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf , in time for the 5:00 pm
October 14 deadline for public comment.
The state has proposed the following for GLX Interim Offset Projects (= Mitigation): on p19:
·
Extensive new suburban commuter rail parking in Salem and Beverly
·
142 new hybrid electric vehicles New RIDE vehicles to replace aging and less -efficient
models
·
Additional off peak bus service in the GLX corridor
·
In conjunction with the increased bus service, MassDOT proposes a 20% increase in offpeak Green Line service. This program will provide additional service to Lechmere Station.
The Friends of the Community Path emphasize the importance of sustainable urban transportation,
including transit, walking and biking. We enthusiastically support the completion of GLX, the major
remaining transit commitment that originated with the Big Dig and then became incorporated into the
SIP at 310 CMR 7.36. We greatly appreciate that MassDOT is proceeding with the GLX
implementation.
SIP 2014 - Page 37
We do not agree with MassDOT’s recommendation to stop the design of the Red/Blue connector and
eliminate it from the SIP. This is a critical link necessary for the MBTA riders.
We hope that the DEP does not allow these two requested changes in the SIP and instead substitutes
other interim measures as discussed below.:
Concerns about the proposed GLX interim offsets
We have serious concerns about the viability of three of the four proposed GLX interim offsets to
produce the stated air quality benefits:
1)
Twenty percent increase in off-peak vehicle trips per hour for all Green Line services
We hope that the proposal to increase “all Green Line services” requires a specific increase in
service to Lechmere station; not just to the Green Line on average, or as a whole. We would be
glad to see a proposal that will increase Green Line service to Lechmere by 20%. The infrequency of
off-peak Lechmere cars is a great disincentive to travelers choosing how to reach many destinations.
2)
20% increase in off-peak bus service in the GLX corridor
We are also unconvinced about the air quality benefits of increasing off-peak bus service along the
bus routes proposed (routes 80, 88, 91, 94, and 96). Our skepticism is based on decades of using,
waiting for, and watching others wait for the buses in Somerville.
We understand that the air quality benefits are going to be derived from individuals deciding to switch
from an automobile to a bus for an off-peak trip and that the air quality modeling is built on such
assumptions. We believe that the MBTA should be required to collect data to verify this mode shift.
When Representative Denise Provost raised this issue at a meeting, MBTA General Manager Scott
seemed quite willing to do so. If actual usage patterns do not reflect these modeling assumptions,
then other offsets should be required – especially as increased diesel bus trips in Somerville will
worsen local air quality.
Other bus service-related mitigations to consider are:
a. Filling true voids in existing service, such as the #90 to Assembly Square (and its
associated new T-station), and the #85 bus, which stops early in the evening, and offers
no service on weekends. Also, the #85 late-day buses often become so full that they don’t
stop to pick up riders – a terrible disincentive to transit use.
b. Adding bus priority sensors and signal prioritization to traffic lights in Somerville,
Medford, and Cambridge (e.g. Highland Avenue, Broadway, and Medford Street). This will
help these bus routes keep more on schedule, making them more attractive to riders, while
reducing delay -exacerbated emissions on the #80, #88, #89, and #90 routes.
3)
Purchase of 142 new hybrid vehicles for the Ride
The fuel-efficient hybrids should not be double -counted also as SIP commitments. This substitution
of hybrids is already required to meet GreenDOT carbon emission reduction goals; for compliance
with Executive Order 44; and for compliance with the Global Warming Solution Act and Green
Communities Act benchmarks.
4) Addition of 374 Park and Ride Spaces in Salem and 378 more parking spaces at Beverly
Station
While we support the commuter rail system, the Salem and Beverly parking garages constitute
prior contractual obligations, in violation of pertinent provisions of the SIP (See attached legal
language after our signatures).
Thus, these long-planned improvements should not legally count as GLX interim offsets. We
SIP 2014 - Page 38
instead urge interim offsets directly benefiting Somerville, where pollution burdens have been and
will be greatest in the absence of the GLX.
Recommendation for a Substitute/Additional Interim Offset: Build the CPX and “Twin Cities Path
Spur”
Given that substitute interim offsets, plus additional offsets due to further GLX project delays, will likely
need to be identified, the Friends of the Community Path urge, these SIP interim offsets:
1) MassDOT/MBTAcomplete the design and the full construction of the Community Path
extension (CPX)
2) MassDOT/MBTA also design and construct a GLX Twin Cities path spur from the CPX to
Twin Cities Plaza.
The reasons for this recommendation:
·
The CPX is a Regional (not just local) project that will link 11 Boston metro cities/towns:
Somerville -- including its Environmental Justice neighborhoods, Cambridge, Arlington,
Lexington, Bedford, Belmont, Medford, Watertown, Waltham, Newton, & Boston. By linking the 23mile Minuteman Bikeway and 23-mile Charles River path networks, this Community Path will make
for 48 continuous miles of path network, and millions of bike/ped trips each year.
·
The air quality benefits of the CPX are permanent. It will be most effective and desirable to
spend mitigation funds on projects with permanent, rather than just temporary air quality benefits.
The community very much looks forward to the long-term benefits of the CPX, and will be
accepting of this as an offset measure.
According to the June 2013 Metric Report on the Community Path, by the Metropolitan Area
Planning Council’s (MAPC) http://www.mapc.org/sites/default/files/2013-0607_Final%20Metric%20Report.pdf :
1)
There will be up to ~3 million trips per year on CPX (p19)
2) "MAPC used the Boston Region MPO’s Congestion Mitigation and Air Quality (CMAQ)
spreadsheet calculations to quantify the VMT reduction and air quality benefit of the
CPX. The CMAQ spreadsheet projects a VMT reduction of 24,735 miles per day and a
reduction of approximately 2,800 metric tons of CO2 per year 34. This is the
equivalent to removing 552 cars from the road during the course of a year. This is an
important statistic because the City of Somerville currently has the most (25.7) lane miles
of road per square mile of any municipality in the Commonwealth, with many being used as
cut thru roads to get to and from Boston. A high density of roadways leads to poor air
quality and negative health impacts on the most vulnerable populations across the City."
(p19)
These MAPC estimates above do not showing trending projections. The Friends of the community
Path believe that, over time, the CPX use and benefits will surpass these MAPC estimates, since
the paths used to extrapolate the estimates likely do not have:
The synergy of the bike/ped traffic enjoyed my the Minuteman Trail (one of the most
popular Paths in the U.S.) and the Charles River Paths
The synergy of both the GLX and the Red Line
The high commuter use that the CPX will enjoy
The huge population density of Somerville, Cambridge, and Boston
The CPX advances sustainability and serves Somerville’s Environmental justice
SIP 2014 - Page 39
Community , it also confers a better chance of FTA New Starts funding for GLX project.
Environmental sustainability is an important part of the MBTA’s onoing application for FTA federal
funding for a half-match for GLX project funding. The MBTA's application will be submitted soon
and decided upon by the Federal Transit Administration (FTA) over the winter. By including the
design and construction of the CPX to complement the GLX and serve as “bicycle and pedestrian
highway,” the CPX will provide non-car access to municipal buildings, schools, shopping and dining
areas, parks, and houses of worship. As an off-road Path, Community Path will serve people all
ages, abilities, and socio-economic status. This Path may take some burden off our at-capacity
transit systems, while still advancing the MassDOT's Green DOT Mode Shift Goals.
·
We are concerned that portions of the CPX may be carved away from the CPX when a new
state administration takes office, so we hope the CPX can be codified as a legal requirement, as a
GLX interim offset project.
Priority Recommendation for Replacement Interim Offset Measure (for parking garages)
·
Twin Cities Path Spur: For similar reasons to the CPX, we request that, as an interim
offset, the State do a feasibility study followed by design and construction of a GLX Twin
Cities path spur. If this spur is not done/designed soon as part of GLX, the GLX design
(approaching 100% for this section) and build may preclude this connection.
This Twin Cities path spur can act as a stand-alone project, connecting this area of Somerville
and East Cambridge to the CPX, or may someday connect to a Grand Junction Path across
Cambridge and into Allston. Notably, the current developer of the refrigerator building already plans
to build a section of path there next to that building along that segment of the Grand Junction
corridor to Gore Street. Attached is a concept map, and also a sketch of options from Fei
Peng, a Northeastern University student working with Northeastern Civil and
Environmental Engineering Professor Peter Furth. The options shown are by the back of
Twin Cities Plaza and McGrath. .
Other Substitute/Additional Interim Offsets
As the GLX opening will be delayed beyond its current legal deadline (and perhaps delayed even
further than expected, we suggest the following interim projects that MassDOT should do in the
corridor that will fully make up for the delayed environmental benefits.
1. Provide free transit and Hubway programs during the delay. This will also provide a
financial incentive for timely project completion
2. Accelerate other regional bicycle/pedestrian paths and facilities equal to 50% or more of the
GLX air quality benefits, to reach the GLX’s environmental benefits and also fulfill the above
goals,
3. Reject any additional diesel rail stops on commuter rail lines through the area. Diesel rail
pollutes communities most during when starting from a stop. Diesel emissions were just
classified by WHO as a Class 1 carcinogen just like smoking and asbestos. This is both a
serious occupational and adjacent community issue.
4. Designation of the new cleaner diesel commuter rail locomotives to the Fairmount Line
and GLX corridors. These locomotives, which will replace half of those currently in service, are
in the process of being delivered and deployed. Diesel fueled transportation is a major
contributor to atmospheric black carbon, the most important Short Lived Climate Pollutant and a
direct cause of lung cancer.
SIP 2014 - Page 40
Thank you for balancing many interests and for your consideration of this public comment. The entire
state (and beyond!) will benefit from these sustainable transportation projects and the healthier urban
neighborhoods and regional economy they will support.
The timely completion of these projects will:
Advance the MassDOT’s Mode Shift goal of tripling the bicycle, pedestrian, and transit mode
share by the year 2030
Advance MassDOT objectives of greenhouse gas emission reductions within the transportation
sector, as required under the Commonwealth’s Global Warming Solutions Act.
Serve as a model for 21st century urban transportation for the whole state.
Sincerely,
Alan Moore and Lynn Weissman, Co-Presidents
Friends of the Community Path
facebook.com/FriendsoftheCommunityPath
http://www.pathfriends.org/scp/join.html
twitter.com/pathfriends
617.776.7769
Regarding Additional of 374 Park and Ride Spaces in Salem and 378 more parking spaces at
Beverly Station:
The relevant language in pertinent provisions of the SIP states:
(4) Project Delays and Implementation of Interim Emission Reduction Offset Projects
and Measures.
(a) Provided that the requirements of 310 CMR 7.36(7) and 310 CMR 7.36(4)(b)
and (c) are met, the projects listed in 310 CMR 7.36(2)(h) and (j) may be delayed
beyond the project deadlines established pursuant to 310 CMR 7.36(2).
(b) For delayed projects, EOT shall implement interim emission reduction offset
projects or measures during the period of delay. Such interim emission offset
projects or measures shall achieve emission reductions of NMHC, CO and NOx
equal to or greater than the emission reductions that would have been achieved
had the project not been delayed. EOT shall meet the requirement of 310 CMR
310 CMR 7.36 Page - 4 7.36(4)(b) by either:
1. Implementing projects or measures that are not otherwise required by any
contractual or other legal obligation, state or federal law or regulation
including without limitation 310 CMR 7.36 and 310 CMR 7.38, or by any
state or federal enforcement action; Such projects shall include providing new
park and ride parking spaces serving commuter transit facilities or the retrofit
of diesel engines with verified diesel retrofit technologies in the transit
ridership area of the delayed project; or
2. Implementing a project required by 310 CMR 7.36(2)(h) through (j) prior
to its required completion date.[1]
On September 12, 2012, the MassDOT Board of Directors approved a $21.7 million contract with
Suffolk Construction for the Beverly parking facility (MBTA contract CMR-62, entitled “Beverly
Depot Parking Garage,” Beverly, MA). Shortly thereafter, the MassDOT Board of Directors voted
unanimously on December 5, 2012, to approve a $32 million contract with Consigli Construction to
build the Salem Parking Garage (MBTA contract CMR-92, entitled “Salem Station Improvements
and Parking Garage,” Salem, MA). Pursuant to those contracts, the Beverly garage was built,
opening just eleven days after the petition was filed with DEP, on August 2, 2014. The Salem
SIP 2014 - Page 41
garage is expected to be completed by Halloween, 2014.
In its 2012 New Starts application, MBTA offered a different list of parking spaces as SIP “offsets,”
claiming that the Salem and Beverly park and ride spaces which it had traditionally offered as SIP
commitments had been subjected to “unexpected delay.” (2012 New Starts submittal for the GLX,
on page 8-37, attached.) MassDOT has been putting forth the Beverly and Salem parking
structures as fulfillment of its SIP commitment at DEP oversight hearings for many years now, yet
it’s clear that they don’t qualify under the SIP regulations. They should not be allowed as SIP
interim offsets for the GLX delay
[1] http://www.epa.gov/region1/topics/air/sips/ma/310CMR7_36_c136.pdf
SIP 2014 - Page 42
1
The Commonwealth of Massachusetts
House of Representatives
State House, Boston, MA 02133-1054
Denise Provost
Representative
27th Middlesex
District
Jerome Grafe
Committees:
Transportation,
Higher Education,
Personnel and
Administration, &
State House Room 473B
Boston, MA 02133
Tel. (617) 722-2263
Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
Re: GLX Petition to Delay; Interim Offsets
Dear Mr. Grafe:
I am writing to comment on the Interim Offsets proposed by MBTA in connection with its
petition to delay the Green Line Extension (GLX) project. While not happy about the delay in
the GLX, I’m pleased with the many project milestones that MassDOT and MBTA have reached.
That said, I have serious reservations about the suitability of three of the four interim offsets
which have been proposed, for reasons stated below:
1) Twenty percent increase in off-peak vehicle trips per hour for all Green Line services
I am glad to see a proposal which will increase Green Line service to Lechmere by 20%. The
infrequency of off-peak Lechmere cars is, I believe, a great disincentive to travelers choosing
how to reach many destinations. I am concerned that the proposal to increase “all Green Line
services” be interpreted to require a specific increase in service to Lechmere station; not just to
the Green Line on average, or as a whole.
2) 20% increase in off-peak bus service in the GLX corridor
SIP 2014 - Page 43
2
I am skeptical about the air quality benefits of increasing off-peak bus service along the bus
routes proposed (routes 80,88,91,94, and 96) That feeling comes from decades of using,
waiting for, and watching others wait for the buses in Somerville.
I’m told that the air quality benefits are going to be derived from individuals deciding to
switch from an automobile to a bus for an off-peak trip. I understand that air quality
modeling is built on such assumptions, but I would ask that MBTA be required to collect
data to verify that this shift is happening -when I raised this issue at a meeting, General
Manager Scott seemed quite willing to do so. If actual usage patterns do not reflect these
assumptions, then other offsets should be required – especially as increased diesel bus trips in
Somerville will worsen local air quality ( I realize that regional measurements of ozone are
the basis of the legal standard – but I think we’re all aware that this standard lacks robust
scientific support.)
Other bus service-related mitigations to consider are:
a. Filling true voids in existing service, such as the #85 bus, which stops early in the
evening, and offers no service on weekends (also, its late-day buses often become so
full that they don’t stop to pick up riders – a terrible disincentive to transit use).
b. Adding bus priority sensors and signal prioritization to traffic lights in Somerville,
Medford, and Cambridge (e.g. Highland Avenue, Broadway, and Medford Street).
This will help these bus routes keep more on schedule, making them more attractive
to riders, while reducing delay-exacerbated emissions on the #80, #88, #89, and #90
routes.)
3) Purchase of 142 new hybrid vehicles for the Ride
I consider that the 142 new Ford Fusion hybrid vehicles should not carry so much weight
towards fulfillment of the SIP commitments. Fleet procurement must be ongoing for the
Ride, and that the substitution of fuel-efficient hybrids is already required to meet
GreenDOT carbon emission reduction goals; for compliance with Executive Order 44; and
for compliance with the Global Warming Solution Act and Green Communities Act
SIP 2014 - Page 44
3
benchmarks. The hybrids could not be counted twice under the SIP – should GreenDOT
obligations also be allowed to count also as SIP commitments?
4) Additional of 374 Park and Ride Spaces in Salem and 378 more parking spaces at Beverly
Station
While I applaud the creation of incentives for using the commuter rail system, I cannot see
why these long-planned improvements should be allowed to count as interim offsets for the
GLX. There is a legal impediment to MassDOT offering the Salem and Beverly parking
garages as interim offsets under the SIP, because they constitute prior contractual obligations,
in violation of pertinent provisions of the SIP. The relevant language states:
(4) Project Delays and Implementation of Interim Emission Reduction Offset Projects
and Measures.
(a) Provided that the requirements of 310 CMR 7.36(7) and 310 CMR 7.36(4)(b)
and (c) are met, the projects listed in 310 CMR 7.36(2)(h) and (j) may be delayed
beyond the project deadlines established pursuant to 310 CMR 7.36(2).
(b) For delayed projects, EOT shall implement interim emission reduction offset
projects or measures during the period of delay. Such interim emission offset
projects or measures shall achieve emission reductions of NMHC, CO and NOx
equal to or greater than the emission reductions that would have been achieved
had the project not been delayed. EOT shall meet the requirement of 310 CMR
310 CMR 7.36 Page - 4 7.36(4)(b) by either:
1. Implementing projects or measures that are not otherwise required by any
contractual or other legal obligation, state or federal law or regulation
including without limitation 310 CMR 7.36 and 310 CMR 7.38, or by any
state or federal enforcement action; Such projects shall include providing new
park and ride parking spaces serving commuter transit facilities or the retrofit
of diesel engines with verified diesel retrofit technologies in the transit
ridership area of the delayed project; or
2. Implementing a project required by 310 CMR 7.36(2)(h) through (j) prior
to its required completion date.1
On September 12, 2012, the MassDOT Board of Directors approvated a $21.7 million
contract with Suffolk Construction for the Beverly parking facility (MBTA contract CMR62, entitled “Beverly Depot Parking Garage,” Beverly, MA). Shortly thereafter, the
MassDOT Board of Directors voted unanimously on December 5, 2012, to approve a $32
million contract with Consigli Construction to build the Salem Parking Garage (MBTA
contract CMR-92, entitled “Salem Station Improvements and Parking Garage,” Salem, MA).
1
http://www.epa.gov/region1/topics/air/sips/ma/310CMR7_36_c136.pdf
SIP 2014 - Page 45
4
Pursuant to those contracts, the Beverly garage was built, opening just eleven days after the
petition was filed with DEP, on August 2, 2014. The Salem garage is expected to be
completed by Halloween, 2014.
In its 2012 New Starts application, MBTA offered a different list of parking spaces as SIP
“offsets,” claiming that the Salem and Beverly park and ride spaces which it had traditionally
offered as SIP commitments had been subjected to “unexpected delay.” (2012 New Starts
submittal for the GLX, on page 8-37, attached.) MassDOT has been putting forth the Beverly
and Salem parking structures as fulfillment of its SIP commitment at DEP oversight hearings
for many years now, yet it’s clear that they don’t qualify under the SIP regulations. They
should not be allowed as SIP interim offsets for the GLX delay
5) Additional Suggestions
Since I expect that substitute interim offsets will have to be identified, I would urge
MassDOT to try to ascertain the air quality benefits of its admirable decision to complete
construction of the Community Path, and include the Path as a SIP interim offset. I realize
that there may be few existing methodologies for calculating the air quality benefits of paths
generally, but I believe, however, that one could be found for an urban path such as this.
Specifically, I’d urge MassDOT to build on MAPC’s work on this question:
Removing vehicle trips from many already congested roadways in the Somerville area
will have both air quality and mobility benefits for the City and region. The Completed
Community Path will reduce vehicle miles traveled (VMT) and take cars off the road and
replace them with walking and biking trips. Constructing the connection in this regional
pathway system will make it easier, safer and more efficient for cyclists and pedestrians
to travel from their points of origin to their destinations.
MAPC used the Boston Region MPO’s Congestion Mitigation and Air Quality (CMAQ)
spreadsheet calculations to quantify the VMT reduction and air quality benefit of the
Community Path Extension33. The CMAQ spreadsheet projects a VMT reduction of
24,735 miles per day and a reduction of approximately 2,800 metric tons of CO2 per
SIP 2014 - Page 46
5
year34. This is the equivalent to removing 552 cars from the road during the course of a
year. This is an important statistic because the City of Somerville currently has the most
lane-miles of road per square mile of any municipality in the Commonwealth, with many
being used as cut-thru roads to get to and from Boston. A high density of roadways leads
to poor air quality and negative health impacts on the most vulnerable populations across
the City.2
Cities are the most likely locations for incentivizing a mode shift away from cars by offering
off-road, dedicated paths. As the Community Path lengthens, it will reach larger populations
of people who might otherwise drive to, say, Davis Square, either as a destination, or to make
a transit connection. Who might be induced to switch modes, were the completed path
available?
One group would be timid or inexperienced bicyclists, who won’t ride in traffic, but would
use a dedicated path. The welcome addition – and use – of increased bike storage around
Davis Square (which should be replicated elsewhere in Somerville), speaks to potential
increase use of the Path were more secure bike storage available. More Hubway stations
proximate to the Path would also help.
I also believe there would be more mode shift if free or subsidized (by MassDOT) Hubway
memberships were made available to those living in the Green Line Corridor, or at least its
Environmental Justice (EJ) blocks. The promotion of mode shift requires provision of
sufficient facilities to satisfy demand. Another method of encouragement could be the
introduction of a fleet of available “loaner” bicycles, such as one sees on some college
campuses and in some European cities.
There are definitely individuals who modify their destinations in order to use the Path, and
avoid car trips. I know several people who no longer drive to the Trader Joe’s on Memorial
Drive in Cambridge, because the store on Alewife Brook Parkway can be reached from
2
Pg. 26, “Vehicle Reduction,” The Community Path Extension (MAPC), June 2013
SIP 2014 - Page 47
6
Somerville entirely off-road via the Path. Such usages deserve attention, and point to the
need to consider Path-based transit in local planning and zoning decisions.
Thanks for considering my comment on the proposed GLX Delays Interim Offsets.
Respectfully submitted,
Denise Provost
SIP 2014 - Page 48
1
The Commonwealth of Massachusetts
House of Representatives
State House, Boston, MA 02133-1054
Denise Provost
Representative
27th Middlesex
District
David W. Cash
Committees:
Transportation,
Higher Education,
Personnel and
Administration, &
State House Room 473B
Boston, MA 02133
Tel. (617) 722-2263
Commissioner
Department of Environmental Protection
One Winter Street
Boston, MA 02108
Re: GLX Petition to Delay; Interim Offsets
October 14, 2014
Dear Commissioner Cash:
I am writing with a post script to my previous comments on MassDOT’s wholly inadequate
proposed interim offsets under 310 MCR 7.36 for it petition to delay the Green Line Extension
(GLX) project. I’m writing to suggest an offset which would provide real air quality benefits and
do so in the GLX corridor. A truly beneficial interim offset would be to start providing cleanerburning buses (e.g., CNG) for the toxic diesel buses which now spew their exhaust fumes on our
congested streets.
When DEP is considering which interim offsets will fulfil the requirements of law, I hope that
the agency will take this suggestion into consideration.
Very truly yours,
Denise Provost
SIP 2014 - Page 49
From:
To:
Subject:
Date:
Eliahu
Allam, Sreelatha (DOT); Jerome.Grafe@state.ma.us; friendspath@yahoo.com
Comments- SIP, GLX Petition to Delay, Interim Offsets
Tuesday, October 14, 2014 3:40:44 PM
To Sreelatha Allam and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan (SIP) Transit
Commitments report (http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf ). I am
pleased that MassDOT is proceeding with the GLX implementation, as it will be a tremendous boon to
many communities that are currently underserved by public transportation.
However, I do not agree with MassDOT’s recommendation to stop the design of the Red/Blue
connector and eliminate it from the SIP. I also voice my concerns here about the proposed GLX
interim offsets to produce the stated air quality benefits:
* 20% increase in off-peak vehicle trips per hour for all Green Line services: I hope that the proposal
to increase “all Green Line services” requires a specific increase in service to Lechmere station;
not just to the Green Line on average, or as a whole. By servicing Lechmere station, it will actually
provide benefit to the people who most stand to gain by the GLX, and who are also most impacted by
delays.
* 20% increase in off-peak bus service in the GLX corridor: MBTA should collect data to verify this
mode shift and associated air quality benefits. Please add more service to the #90 bus and the #85
bus. Also please add bus priority sensors and signal prioritization to traffic lights in Somerville,
Medford, and Cambridge.
* The purchase of 142 new hybrid vehicles for the RIDE should not be double-counted also as SIP
commitments, since it is already required to meet GreenDOT carbon emission reduction goals; for
compliance with Executive Order 44; and for compliance with the Global Warming Solution Act and
Green Communities Act benchmarks.
* The addition of 374 Park and Ride Spaces in Salem and 378 more commuter parking spaces at
Beverly Station should not be permitted as for GLX Interim Offsets, because the parking garages were
already under contract (in addition to not providing benefits to the area of the GLX).
Please instead do these interim offsets, due to their health and air quality benefits and regional
potential:
- MassDOT/MBTA to complete the design and full construction of the Community Path extension
(CPX). This will also ensure that future administrations do not carve the CPX from the GLX project.
The CPX is an integral component of the GLX, and it will be transformative for the communities that it
will serve.
- MassDOT/MBTA to design and construct a GLX Twin Cities path spur from the CPX to Twin Cities
Plaza.
- Provide free transit and Hubway programs during the delay. This will also provide a financial incentive
for timely project completion
- Accelerate other regional bicycle/pedestrian paths and facilities equal to 50% or more of the GLX air
quality benefits, to reach the GLX’s environmental benefits and also fulfill the above goals,
SIP 2014 - Page 50
- Reject any additional diesel rail stops on commuter rail lines through the area. Diesel rail pollutes
communities most during when starting from a stop. Diesel emissions are classified by WHO as a
Class 1 carcinogen just like smoking and asbestos.
- Deploy new cleaner diesel commuter rail locomotives for the Fairmount Line and GLX corridors.
Thank you for listening.
Sincerely,
Eliahu Sussman
32 Central Road
Somerville, MA 02143
SIP 2014 - Page 51
From:
To:
Cc:
Subject:
Date:
Elisabeth Bayle
"matthew.ciborowski@state.ma.us" ; Grafe, Jerome (DEP)
"richard.davey@state.ma.us" ; Scott, Beverly (MBTA) ; "Clinton.Bench@state.ma.us";
"MassDEP.Commissioner@state.ma.us"
Comment letter on SIP Transit Commitments 2014 Status Report and Petition to Delay the Green Line
Extension Project
Tuesday, October 14, 2014 4:55:26 PM
I am writing to comment on the Green Line Extension project:
1. I’m grateful that there is some concrete progress on actually funding and building the Green
Line Extension.
2. The budget increases and delays since I first became involved in the project in 2006 are truly
disheartening.
3. The Preferred Build Alternative identified by MassDOT (then EOT) in February of 2009 after
years of study and public participation was to extend the Green Line to Route 16/Mystic
Valley Parkway (in other words, to Medford Hillside, not just to Tufts University at College
Ave., which is unsuitable as a terminus). The opportunities for significant improvements in air
quality, transit-oriented development, and quality of life that are made possible by building
the Green Line Extension to Route 16 have been amply documented in the superb report on
the Mystic Valley Parkway Green Line Extension Community Visioning Process which was
completed in February 2012. (Report at
http://mapc.org/sites/default/files/Final_Report_forweb.pdf, appendices at
http://mapc.org/sites/default/files/Green_Line_report_Appendices.pdf.) Please fulfill the
promise of the Extension by planning for and funding the Green Line Extension to the
preferred terminus at Route 16 on as expeditious a timetable as possible.
4. The interim offset measures described in the Petition to Delay state that “...the Transit
Regulation does not require than an interim offset be in the same area as the project...” This
is extremely discouraging. The legal deadline for the Extension to be operational was
December 31, 2014 (already a delay from earlier planning that had a deadline in 2011). The
interim measures outlined do not seem to achieve any of the goals of the project with the
possible exception of the expanded area bus service. Can’t we do better for the underserved
populations that have already waited so long, and will now wait many additional years to
benefit from this project?
Best regards,
Elisabeth Bayle
Medford resident
SIP 2014 - Page 52
Ellin Reisner, Ph.D.
51 Mount Vernon Street
Somerville, MA 02145
Reisnere51@gmail.com
617-776-1987
Commissioner David Cash
Department of Environmental Protection
One Winter Street
Boston, MA 02108
Jerome Grafe
Mass DEP Bureau of Waste Prevention
One Winter Street, Boston, MA 02018
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning, Room 4150
Ten Park Plaza, Boston, MA 02116
Re: GLX Petition to Delay; Interim Offsets. SIP Comments in Support of GLX, CPX, Red‐Blue Connector,
and GLX Mitigation
Greetings:
I am writing to comment on the Interim Offsets proposed by MBTA related to their petition to delay the
Green Line Extension (GLX) project. Although it is very disappointing that the GLX is delayed, it is
promising to see that the MBTA and MassDOT are moving forward with the project. Most of the
proposed specific interim offsets really do not accomplish the required goals of the SIP to reduce
emissions as required by the SIP.
As president of the Somerville Transportation Equity Partnership I have been very involved in promoting
the GLX extension for over 10 years as well as working on ways to reduce dangerous emissions that
affect the health of residents in our city through research on the cardiac health impacts of mobile
pollution on people living near highways [http://sites.tufts.edu/cafeh/.]
The goal of expanding commuter rail parking in Salem and Beverly and adding 142 new hybrid electric
vehicles New RIDE vehicles to replace aging and less‐efficient models are very good decisions that
clearly support the state’s Green DOT goals and do provide mitigation. However, since neither meets the
requirements for interim offset projects and measures as defined by the SIP. I strongly request that you
deny the Petition pursuant to 310 CMR 7.36(4)(c) and instead require MassDOT to resubmit a petition
with adequate interim offset projects and measures without instead.
Adding additional off peak bus service in the GLX corridor has merit even though the air quality benefits
of increases in off‐peak bus service are not clear based on the MBTA calculations. Increased bus service
should be aligned with 20% increase in Green Line off‐peak service to Lechmere Station to link transit
riders with the expanded off beak bus service. Currently, the level of off peak GLX service to Lechmere is
a deterrent to using public transportation.
SIP 2014 - Page 53
The proposed increase in off‐peak bus service along the bus routes proposed (routes 80, 88, 91, 94, and
96) is insufficient to reduce emissions in the corridor. The MBTA should add the CT2 route to the
proposed increase in off‐peak service. The CT2 is a heavily used bus by Somerville residents to get to jobs
and school in the Kendall Square area, the Longwood Medical area and to Northeastern University. CT2
provides the direct route to these key locations (at key points along the proposed GLX at Washington
Street and Union Square), yet service terminates at 7PM and does not operate at all on weekends when
there are many people who would use this service. When the GLX opens people will be able to take the
GLX to these locations, but now rely on the CT2 during its limited hours of operation. Increasing service
on this bus line would add to emission reduction by diverting people from automobiles.
Additional improvements in service and diversion of people from cars would result in increasing service
on the #90 bus to Assembly Square (and new Orange Line T‐station). The hours of the #85 bus should
be extended on weekdays and weekend service should be added.
Another recommendation to reduce emissions and keep buses on schedule would be to install bus
priority sensors and signal prioritization to traffic signals in Somerville, Medford, and Cambridge (along
Highland Avenue, Broadway, in Union Square and Medford Street).
I would also support the recommendation of the Friends of the Community Path to substitute the
Community Path extension and Twin Cities Path Spur as SIP mitigation offsets. This would involve
completing the design and the full construction of the Community Path extension (CPX) and design and
construction of a GLX Twin Cities path spur from the CPX to Twin Cities Plaza.
The value of this substitution is that the Community Path is a regional transportation improvement that
will provide permanent air quality benefits and reductions of emissions. It is estimated that there will be
up to three million trips per year on the Path.
Although MassDOT has committed to construct the Community Path along the GLX it is not a legal
requirement (despite the huge air quality benefits) and could be eliminated by a new elected
administration after 2015.
There are several additional interim offsets that could be substituted for those proposed by the MBTA
that do not meet the SIP requirements. They are:
ƒ
ƒ
Provision of reduced fare transit and Hubway during the delay.
Construct other regional bicycle/pedestrian paths equal to 50% or more of the GLX air quality
benefits, to reach the GLX’s environmental benefits and also fulfill the above goals,
ƒ Ensure that the new cleaner diesel commuter rail locomotives are placed on the Fairmount Line
and on the lines in the Green Line corridors. These locomotives should serve environmental
justice communities which experience the worst exposure to mobile pollution.
ƒ Absolutely reject adding any diesel rail stops on commuter rail lines through the area since .
Diesel emissions are worst when trains are stopped and started. Diesel emissions are classified
by the World Health Organization as a Class 1 carcinogen just like smoking and asbestos. To add
diesel stops in the GLX corridor would be counter to the purpose of emission reduction.
I appreciate the opportunity to comment on the Petition to Delay (Petition) dated July 22, 2014 that the
Massachusetts Department of Transportation (MassDOT) submitted to the Department of
SIP 2014 - Page 54
Environmental Protection (DEP or the Department). We look forward to working with the MBTA and
MassDOT to maximize the benefits of the SIP for the health of residents in our region.
Sincerely,
Ellin Reisner, President
Somerville Transportation Equity Partnership
www.somervillestep.org
SIP 2014 - Page 55
From:
To:
Subject:
Date:
Eric Weil
Allam, Sreelatha (DOT); jerome.grafe@massmail.state.ma.us
Comments- SIP, GLX Petition to Delay, Interim Offsets
Tuesday, October 14, 2014 5:00:13 PM
To Sreelatha Allam and Jerome Grafe:
I have read the annual State Implementation Plan (SIP) Transit Commitments report
(http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf) and I appreciate the
opportunity to comment. There are some things I am pleased about and others that I am not
happy about.
I am pleased that MassDOT is proceeding with the GLX implementation.
However, I do not agree with MassDOT’s recommendation to stop the design of the Red/Blue
connector and eliminate it from the SIP. I also disagree with many of the GLX interim offsets to
produce the stated air quality benefits. These measures are required due to the ABSURDITY of
delays that this project has experienced, even though it is legally required
and desperately needed. Comments on the interim measures:
* 20% increase in off-peak vehicle trips per hour for all Green Line services: I hope this actually
happens
* 20% increase in off-peak bus service in the GLX corridor: MBTA should collect data to verify
this mode shift and associated air quality benefits. Please add more service to the #90 bus, the
#88 bus and the #85. Also please add bus priority sensors and signal prioritization to traffic
lights in Somerville, Medford, and Cambridge.
* The purchase of 142 new hybrid vehicles for the RIDE should not be double-counted also as
SIP commitments, since it is already required to meet GreenDOT carbon emission reduction
goals; for compliance with Executive Order 44; and for compliance with the Global Warming
Solution Act and Green Communities Act benchmarks.
* The addition of 374 Park and Ride Spaces in Salem and 378 more commuter parking spaces
at Beverly Station should not be permitted as for GLX Interim Offsets, because the parking
garages were already under contract (in addition to not providing benefits to the area of the
GLX). These suburban parking garage projects do nothing to help the transit users that get
screwed over by these ridiculous delays.
I also propose these interim offsets, due to their health and air quality benefits and regional
potential:
- MassDOT/MBTA to complete the design and full construction of the Community Path extension
(CPX). This will also ensure that future administrations do not carve the CPX from the GLX
project.
- MassDOT/MBTA to design and construct a GLX Twin Cities path spur from the CPX to Twin
Cities Plaza.
- Provide free transit and Hubway programs during the delay. This will also provide a financial
incentive for timely project completion. This incentive seems badly needed as otherwise I have
SIP 2014 - Page 56
no faith in this project ever being completed.
- Accelerate other regional bicycle/pedestrian paths and facilities equal to 50% or more of the
GLX air quality benefits, to reach the GLX’s environmental benefits and also fulfill the above
goals,
Thank you.
Eric Weil
13 Henry Ave, Somerville, MA
SIP 2014 - Page 57
From:
To:
Subject:
Date:
Frederick P Salvucci
Grafe, Jerome (DEP)
Fwd: Letter to DEP on Green Line Slippage mitigation
Tuesday, October 14, 2014 3:42:12 PM
Sent from my iPad
Begin forwarded message:
From: Frederick P Salvucci <salvucci@mit.edu>
Date: October 14, 2014 at 9:38:09 AM EDT
To: Frederick P Salvucci <salvucci@mit.edu>
Subject: Letter to DEP on Green Line Slippage mitigation
Davis W. Cash
Commissioner
Department of Environmental Protection
One Winter Street
Boston, Ma. 02108
I am writing to object to the inadequacy of the mitigation proposed by
MBTA for the announced slippage of completion of the Green Line
Extension by an estimated 6 years, and to propose that a minimum, and
immediate commitment for additional mitigation be required, including:
1) Immediate contracting for a shuttle bus service in the ""Urban Ring"
corridor,to provide service connecting Sullivan Square to Existing
Lechmere Station to Kendall Square to Kenmore Square. This service
should be contracted prior to December, to expand the existing EZ ride
service, in combination with the improvement in frequency of Green Line
service to Lechmere in order to improve transit mode share throughout
the corridor, with a service of 10 minute frequency during the peak
period, and 15 minutes during off peak times. This initiative should
include the modifications needed in the Green Line construction at New
Lechmere station to accommodate the NorthPoint Boulevard bridge to
Inner Belt road, for the permanent path for Urban Ring service.
2) Immediate initiation of a design build procurement process for the
construction of the extension of the Blue Line to the Red Line station at
Charles street, based on the conceptual plan developed in the EIR for the
project. This connection was required to have been fully engineered by
this December, but is only at the EIR stage. It is proposed that the lost
time be made up by proceeding directly to a design build procurement,
so that construction can be integrated with the current Longfellow Bridge
reconstruction, and the MEEI below grade garage and Esplanade
expansion provided for in recently approved legislation. The connection
will provide access to the Mass General Hospital, and nearby Kendall
square for residents of East Boston, Winthrop and Revere, and the near
North shore, making beneficial use of available capacity on the Blue Line,
reducing the use of the overloaded link of the Green Line between
Government Center and Park Street, and supporting the availability of
SIP 2014 - Page 58
capacity for the new ridership attracted by the Green Line Extension to
Somerville. It also will provide for improved convenience to Red Line
passengers destined to Logan Airport, as the Silver lIne service capacity
becomes substantially fully required for trips to the Seaport Innovation
District. these service improvements will help to offset growing auto
congestion associated with economic growth in Kendall , downtown and
the innovation district, by attracting trips to available transit capacity.
3)The procurement of modern signal systems and sufficient vehicles on
the Red and Orange lines to provide significant added capacity to deal
with overcrowding, and the need for increased capacity.
4) Implementation of the Grand Junction DMU rail shuttle service from
the recently announced West Station over a new two track rail plus bike
and pedestrian bridge over the Charles, with a stop in the Kendall area,
and connecting to the North Station, as announced in the five year plan
of Massdot. This will also require accommodation of a two track rail
section and a bike and pedestrian connection in the Green Line extension
and Somerville Community Path currently under design. This vital
connection will improve both transit and bicycle capacity and convenience
in the area, and needs to be included now in the physical design of the
Green Line project and the Allston multi-modal project.
It is 23 years since the DEP vent shaft regulations for the Central Artery
/Tunnel project required that the previously programmed Blue to Red
connection be completed by the year 2000, and the Green line extension
to Medford hillside be competed by 2011, and the Orange Line vehicles
were to have been replaced by 1995. In the SIP of 1993, similar
requirements were required. The latest delays must be understood in the
context of over two decades of non performance of obligations required
by DEP, and accepted by the predecessor of Massdot. Part of this delay is
partly attributed to blatant lack of any effort to proceed with the
mitigation requirements. Administrative Consent Orders were entered into
in which the transportation agencies were given more time, and promised
to perform, only to be followed by more delay. Subsequent political
administrations either failed to take any action, or switched priority to
other projects, with no approval from DEP. Indeed the current situation
shows some progress in comparison to prior delay processes, in that the
Green Line Extension is now fully approved and proceeding, though late;
the Blue Line extension project has completed its EIR process; and the
Orange Line new Vehicles which were to have been replaced by 1995,
are now the subject of an active procurement process.But more than two
decades of delay have seen the return of congestion to the Big Dig
tunnels, the very problem the mitigation measures were intended to
avoid. And thus the added mitigation outlined above is urgently required
at a minimum to avoid the congestion which is now upon us, and the air
pollution which it will cause.
I say "at a minimum" because the congestion now appearing will
certainly become more severe as continued desirable job growth in the
Kendall and Seaport Innovation districts require that new analysis be
carried out to determine additional mitigation to catch up, which DEP
should require Massdot to carry out. Other worthy projects should
undoubtedly be added,( not substituted) to achieve adequate
attractiveness in the transit system to achieve Greendot goals.
But one of the problems recurring during the past two decades has been
cycles of reconsideration and "planning" with constantly changing
SIP 2014 - Page 59
priorities, without ever beginning implementation, as in the case of the
missing link of the Silver Line, and the Urban Ring planning, which
displaced the attention needed to implement the commitments made in
1991 and 1993. For this reason I believe that the appropriate DEP action
is to insist that Massdot Implement the Blue Red connector, the mini
Urban ring bus shuttle,and the new signals for the Red and Orange Lines
because these have been studied extensively, and are action ready.
Further study is appropriate to develop additional investments now
required to establish conditions that will attract riders to transit, but the
priority for DEP action should be to demand action on these four
actionable items.
I fully recognize that only the proposed mini urban ring bus shuttle can
be contractually committed by January 1, 2015, but I do not believe that
DEP should limit itself to actions which commence by January. all of
these proposals can be in service during the 6 years of announced
slippage on the Green Line, and it is essential to get enough
improvement implemented to be effective at attracting new riders,
ridership which should have been attracted over the past several years if
transit implementation had been timely.
I appreciate your attention to these proposals,
Frederick P. Salvucci
Sent from my iPad
SIP 2014 - Page 60
October 14, 2014
David W. Cash
Commissioner
Department of Environmental Protection
One Winter Street
Boston, MA 02108
Delivery by Adobe PDF via email to Sreelatha.allam@state.ma.us and jerome.grafe@state.ma.us
RE: MassDOT Petition to Delay Green Line Extension Project
Dear Commissioner Cash:
We are writing to support the comments submitted by Rafael Mares of the Conservation Law Foundation on October 6,
2014. The offset projects and measures proposed by the Massachusetts Department of Transportation (MassDOT) in its
Petition to Delay1 the Green Line Extension (GLX) Project are not adequate. We would like to take this opportunity to
propose additional offset projects that are consistent with goals of the Commonwealth and previously announced plans.
The State’s goals in 3 areas are relevant to how MassDOT should mitigate Green Line Extension delay2:
1. Achieve a greenhouse gas emission reduction target of 25% by 2020,
2. Achieve positive public health outcomes by increasing access to healthy transportation options
3. Triple the share of travel in Massachusetts by bicycling, transit and walking
On September 30, 2014, MassDOT committed to construct a West Station passenger rail stop in Allston as part of the
I-90 Interchange Improvement Project3 . The MassDOT FY2014 - FY2018 Capital Investment Plan includes a MBTA plan
that connects West Station in Allston to Kendall Square and North Station.4 Additionally, MassDOT5 and the City of
Cambridge 6 are planning a Grand Junction Community Path for cyclists and pedestrians that will run alongside the
existing tracks in the Grand Junction corridor from the Boston University Bridge and connecting to the extension of the
Somerville Community Path being constructed as part of the Green line Extension.
To mitigate the Green Line Extension delay in a manner consistent with the goals, projects, and commitments listed
above, MassDOT should construct a two track Grand Junction rail connection and bike/ped path from West Station to
North Station. In order to achieve this DMU service and the bicycle and walking benefits as soon as possible, and reduce
auto travel within the 6 to 7 year slippage of the Green Line Extension project, MassDOT should commit to constructing a
structurally sound Grand Junction replacement bridges over the Charles River and Soldiers Field Road as part of the I-90
Allston Interchange Improvement Project which is scheduled to start construction in 2017.
The Allston project should also provide immediately for new I-90 entrance and exit ramps connecting to Beacon Street.
These ramps would provide direct access to Longwood Medical and Brookline destinations, reduce circuitous auto and
truck paths which cause unnecessary congestion and extra vehicle miles travelled, and reduce the current overuse of
Cambridge Street and Harvard Ave in Allston, the River Street Bridge, Memorial Drive, and BU Bridge.
For the West Station / Kendall / North Station route to become operational, MassDOT should purchase a sufficient
number of DMU vehicles. The engineering and construction of the Green Line extension should be modified to include the
two track connection for the Grand Junction service within the City of Somerville and the bike and pedestrian connection
1
2
3
4
5
6
https://www.massdot.state.ma.us/Portals/17/docs/sip/GLX%20Petition%20for%20Delay_final.pdf
http://www.mass.gov/eea/docs/eea/gwsa/10-9-12-massdot-bic-trans.pdf
http://blog.mass.gov/transportation/mbta/governor-patrick-announces-new-commuter-rail-station-in-allston/
http://www.massdot.state.ma.us/Portals/0/docs/infoCenter/docs_materials/cip_FY14_FY18.pdf
http://www.massdot.state.ma.us/planning/Main/CurrentStudies/GrandJunctionTransportationStudy.aspx
http://www.cambridgema.gov/CDD/Projects/Transportation/GrandJunctionPathway
SIP 2014 - Page 61
from North Point Boulevard to the Grand Junction corridor within Somerville. Finally, MassDOT and the City of Cambridge
must expeditiously complete the planning and construction of upgraded rail tracks and safe street crossings and a
Kendall Square Station for the Grand Junction DMU service , as well as a bike and pedestrian link to provide bike and
pedestrian connectivity from the Green Line , through Somerville and Cambridge, and across the Charles River to the Paul
Dudley White path and the "People's Pike" multiple treadway shared use path that has been included in the planning for
the I-90 Interchange Realignment in Allston.
These mitigation measures could be implemented during the mitigation period and would ensure that MassDOT continues
to make real progress towards its important goals relating to clean air, public health, environmental justice, and
supporting economic growth. We respectfully request that DEP deny MassDOT’s Petition to Delay pursuant to 310 CMR
7.36(4)(c)7 until such time as MassDOT agrees to include these projects to mitigate the GLX delay.
Sincerely,
Steven Bercu, 132 Fayerweather Street, Cambridge
Glen Berkowitz, LivableStreets Alliance, 70 Pacific Street, Cambridge
Preston Buehrer, 127 Washington Street, Brighton
Matthew Danish, 53 Ashford Street, Allston
Paola Ferrer, 19 Royal Street, Allston
Harry Mattison, Charles River Conservancy, 4 Brattle Street, Cambridge
Galen Mook, 55 Royal Street Apt 3, Allston
Jessica Robertson, 55 Royal Street Apt 3, Allston
Jimmy Sloan, 103 Child Street, Jamaica Plain
Brent Whelan, 332 N Harvard Street, Allston
Joshua Wilson, 96 Naples Road Apt. 1, Brookline
cc:
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston, Massachusetts 02116
Sreelatha.allam@state.ma.us
Jerome Grafe
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street Boston,
MA 02108
jerome.grafe@state.ma.us
7
http://www.epa.gov/region1/topics/air/sips/ma/310CMR7_36_c136.pdf
SIP 2014 - Page 62
TOWN OF WINTHROP
Town Manager's Office
Town Hall 1 Metcalf Square Winthrop Massachusetts 02152 Telephone: (617) 846-1077 Fax: (617) 846-5458
October 14,2014
David W. Cash, Commissioner
Department of Environmental Protection
One Winter Street,
Boston, MA 02108
Subject: State Implementation Plan-Transit Commitments 2014 Status Report
Dear Commissioner Cash:
I am writing today to discuss with you the Massachusetts Department of Transportation's recent
request to eliminate the design of the Blue Line-Red Line connector, which was initially
developed as environmental mitigation for the impacts of the Central Artery/ Third Harbor
Tunnel project. The Town of Winthrop opposes MassDOT's request to remove this obligation,
as it is the only significant mitigation measure recommended that would benefit our community
and its residents.
Of the transit commitments included in the 1990 MOU, none was more important to Winthrop and
other Blue Line communities than the proposed direct connection between the MBTA Blue Line
and the Red Line at Charles Station. This project would greatly enhance transit access to the
Massachusetts General Hospital (MGH) for all of the Blue Line communities, as well as
improving access to job opportunities, education and high-tech centers in Cambridge and
Somerville.
Residents of our town who rely on public transit and wish to use the Blue Line to access MGH,
for instance, have to walk a half-mile from the Bowdoin Street station, a trip made even more
difficult in adverse weather. The Blue Line-Red Line connection will also significantly improve
transit service to Cambridge and Somerville, important centers of commerce and higher
education, helping to improve connections between our small community and the places where
our residents can work, learn and shop.
Additionally, the Blue Line-Red Line Connection would benefit the entire MBTA transit
system in the form of measurable congestion relief for both the Park Street and
Government Center Stations which must currently accommodate Blue Line passengers bound
for MGH and Cambridge. These passengers now must change at Government Center, take
the Green Line to Park Street and then board the Red Line. By bypassing both of these
congested stations the Blue Line-Red Line Connection would benefit the entire MBTA system.
SIP 2014- Page 63
Specifically, the Town of Winthrop requests that DEP rescind its decision of October 8, 2013
that approved MassDOT's request to eliminate the Blue Line-Red Line Connector design as an
obligation, and to immediately inform the U.S. Environmental Protection Agency of its reversal
of last year's vote.
Town Manager
CC: Speaker Robert DeLeo
Senator Anthony Petruccelli
Senator Edward Markey
Senator Elizabeth Warren
Congresswoman Katherine Clark
SIP 2014 ·Page 64
From:
To:
Subject:
Date:
Grafe, Jerome (DEP)
Allam, Sreelatha (DOT)
FW: GLX Mitigation
Monday, January 26, 2015 9:37:07 AM
From: Max Morrow [mailto:maxmorrow77@gmail.com]
Sent: Monday, October 06, 2014 8:06 AM
To: Sreelatha.Alam@dot.ma.us; Grafe, Jerome (DEP)
Subject: GLX Mitigation
Having read the state's proposal for mitigation related to the Green Line Extension, I must
offer that there is one mitigation project that is significantly omitted: The Community Path. It
may seem that there already is enough commitment to the Path so as to make it's inclusion in
the mitigation measures superfluous. I disagree. The inclusion of the Community Path
construction as part of the GLX would provide enhanced security against changes in a new
administration's commitment or any unanticipated threats to its inclusion in the project.
Jeffrey S Morrow, M.D.
49 Irving St
Somerville, MA 02144
SIP 2014- Page 65
From:
To:
Subject:
Date:
Macdougall, John
Allam, Sreelatha (DOT); Grafe, Jerome (DEP)
state transit plans
Wednesday, October 15, 2014 7:23:07 AM
-----------------------------------------------------------------------------------------To:
Sreelatha.Allam@dot.state.ma.us, Jerome.Grafe@state.ma.us, friendspath@yahoo.com
Subject:
Comments- SIP, GLX Petition to Delay, Interim Offsets
DRAFT LETTER
To Sreelatha Allam and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan (SIP) Transit
Commitments report ( http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf .
I am pleased that MassDOT is proceeding with the GLX implementation.
However, I do not agree with MassDOT’s recommendation to stop the design of the Red/Blue
connector and eliminate it from the SIP. I also voice my concerns here about the proposed GLX
interim offsets to produce the stated air quality benefits:
20% increase in off-peak vehicle trips per hour for all Green Line services: I hope that the
proposal to increase “all Green Line services” requires a specific increase in service to
Lechmere station; not just to the Green Line on average, or as a whole.
20% increase in off-peak bus service in the GLX corridor : MBTA should collect data to verify
this mode shift and associated air quality benefits. Please add more service to the #90 bus
and the #85 bus. Also please add bus priority sensors and signal prioritization to traffic lights in
Somerville, Medford, and Cambridge.
The purchase of 142 new hybrid vehicles for the RIDE should not be double -counted also as
SIP commitments, since it is already required to meet GreenDOT carbon emission reduction
goals; for compliance with Executive Order 44; and for compliance with the Global Warming
Solution Act and Green Communities Act benchmarks.
The addition of 374 Park and Ride Spaces in Salem and 378 more commuter parking spaces at
Beverly Station should not be permitted as for GLX Interim Offsets, because the parking
garages were already under contract (in addition to not providing benefits to the area of the
GLX).
Please instead do these interim offsets, due to their health and air quality benefits and regional
potential:
1. MassDOT/MBTA to complete the design and full construction of the Community Path extension
(CPX). This will also ensure that future administrations do not carve the CPX from the GLX
project.
2. MassDOT/MBTA to design and construct a GLX Twin Cities path spur from the CPX to Twin
Cities Plaza.
3. Provide free transit and Hubway programs during the delay. This will also provide a financial
incentive for timely project completion
4. Accelerate other regional bicycle/pedestrian paths and facilities equal to 50% or more of the
GLX air quality benefits, to reach the GLX’s environmental benefits and also fulfill the above
goals,
SIP 2014 - Page 66
5. Reject any additional diesel rail stops on commuter rail lines through the area. Diesel rail
pollutes communities most during when starting from a stop. Diesel emission sareclassified by
WHO as a Class 1 carcinogen just like smoking and asbestos.
6. Deploy new cleaner diesel commuter rail locomotives for the Fairmount Line and GLX
corridors.
Thank you.
John MacDougall
175 RIchdale Ave. #209
Cambridge MA 02140
john_macdougall@uml.edu
member, 350MA Transportation Working Group
SIP 2014 - Page 67
From:
To:
Subject:
Date:
Attachments:
Ciborowski, Matthew (DOT)
Allam, Sreelatha (DOT)
FW: Comment letter on SIP Transit Commitments 2014 Status Report
Wednesday, October 15, 2014 8:06:22 AM
2013 SIP Comments.pdf
Matthew Ciborowski
Office of Transportation Planning
857.368.8845
matthew.ciborowski@state.ma.us
From: John Roland Elliott [mailto:JohnRolandElliott@Comcast.net]
Sent: Tuesday, October 14, 2014 5:05 PM
To: Ciborowski, Matthew (DOT); jerome.grafe@massmail.state.ma.us
Subject: Comment letter on SIP Transit Commitments 2014 Status Report
To:
Matthew Ciborowski
MassDOT Office of Transportation Planning
Jerome Grafe
MassDEP, Bureau of Waste Prevention
From:
John Roland Elliott
34 Emery Street
Medford Hillside
Dear Messrs Ciborowski and Grafe:
As a whole-hearted, full-throated supporter of public transportation, especially light rail, I’m pleased
and relieved to see that progress continues on the Green Line Extension to Medford Hillside and
Somerville Union Square. I implore you make every effort and take every action to see to it that this
critical bit of infrastructure continues to advance 1) without any further delay and 2) without any
further dilution or scope reduction.
I have repeatedly advocated for a terminus at Route 16 / Mystic Valley Parkway (instead of the
temporary College Avenue terminus) and cogent argument for same can be found in my 2013 SIP
Comments [see attached or https://app.box.com/s/svs5i4eypblgdta063yg].
Over the lifetime of the Green Line Extension, the project as been extended to include
1) a maintenance facility need for and serving the entire MBTA system, surely a worthwhile
addition to the system but beyond the intrinsic goal of the GLX;
2) the reconstruction of Lechmere Station, originally the purview of a private commercial
developer;
SIP 2014 - Page 68
3) expansive community path design and construction costs, critical to the community but
feature creep to a rail expansion project.
Simultaneously, the final mile of the extension, to bring the Green Line to Medford Hillside,
satisfying the letter of the SIP and the spirit of the original goal of the project, had been deferred to
a second phase.
Given the delays that have postponed the completion of the full project into the 2020s, once again,
it is time to reinstate the preferred full-build alternative long advocated by MassDOT, namely, a
terminus at Route 16 / Mystic Valley Parkway.
Sincerely,
John Roland Elliott
SIP 2014 - Page 69
From:
To:
Subject:
Date:
Attachments:
sanzoneja@gmail.com on behalf of GrandJunctionPath
Allam, Sreelatha (DOT); jerome.grafe@massmail.state.ma.us; Friends of the Community Path
Comments re: GLX Petition to Delay
Tuesday, October 14, 2014 5:40:30 PM
GJP CPX gap map -01_CPX-GJP Gap.png
GJP Options from Fei Peng in PDF.pdf
To Sreelatha Allam and Jerome Grafe,
I am writing as the President of the Friends of the Grand Junction Path, a group that
is advocating for an important regional walk/bike connection in Cambridge,
Somerville, and Allston along the Grand Junction corridor--more details in the
attachments, and at facebook.com/grandjunctionpath and grandjunctionpath.org.
Please consider our full support and "second" for the Friends of the Community
Path's letter, dated today, October 14, 2014, identifying several interim offsets that
will have beneficial, and in many ways, profound regional transportation impact.
The Twin City Plaza spur--explained in the relevant excerpt below in this email--is of
particular interest for our group. With or without the Grand Junction Path, the spur
will greatly enhance the utility and impact of the Somerville Community Path, and be
an important resource for some of the most underserved areas in the City of
Cambridge, Wellington-Harrington, Area Four, and East Cambridge.
Thank you for the opportunity to comment, and we look forward to more great work
and openness in communication as the GLX project proceeds.
Sincerely,
John Sanzone, President
Friends of the Grand Junction Path
Web: grandjunctionpath.org
Like: facebook.com/grandjunctionpath
Email: grandjunctionpath@gmail.com
-Excerpt from the original letter from the Friends of the Community Path:
Twin Cities Path Spur: For similar reasons to the CPX, we request that, as
an interim offset, the State do a feasibility study followed by design and
construction of a GLX Twin Cities path spur. If this spur is not
done/designed soon as part of GLX, the GLX design (approaching 100% for
this section) and build may preclude this connection.
This Twin Cities path spur can act as a stand-alone project, connecting
this area of Somerville and East Cambridge to the CPX, or may someday
connect to a Grand Junction Path across Cambridge and into Allston.
Notably, the current developer of the refrigerator building already plans to
build a section of path there next to that building along that segment of
the Grand Junction corridor to Gore Street. Attached is a concept map,
and also a sketch of options from Fei Peng, a Northeastern University
student working with Northeastern Civil and Environmental Engineering
SIP 2014 - Page 70
Professor Peter Furth. The options shown are by the back of Twin Cities
Plaza and McGrath.
SIP 2014 - Page 71
John Vitagliano
19 Seymour Street
Winthrop, MA 02152
October 14, 2014
David W. Cash, Commissioner
Department of Environmental Protection
One Winter Street,
Boston, MA 02108
Subject: State Implementation Plan-Transit Commitments 2014 Status Report
Dear Commissioner Cash:
I vigorously oppose the request of MassDOT to be relieved of the long standing
requirement to complete the design of the Blue Line-Red Line Connector which
was initially developed as a major environmental remediation obligation of the
Big Dig.
Of the transit commitments included in the 1990 MOU none was more
important that the proposed direct connection between the MBTA Blue Line
and Red Line at Charles Station. This project would greatly enhance transit
access to the Massachusetts General Hospital for all of the Blue Line
communities including Winthrop. Residents of our town who h a v e desired
to use the Blue Line to utilize Mass. General have to walk half a mile after
disembarking at the Bowdoin station. The Blue Line‐Red Line connection
would also provide significantly improved transit service between
W i n t h r o p and the many important high tech destinations in Cambridge such
as Kendall Square and beyond. Furthermore the Blue Line-Red Line Connector
would provide enhanced public transit service from Winthrop and other north
shore communities to the south shore communities served by the Red Line by
also bypassing the convoluted Government Center-Park Street Station Green
Line route.
It is important to note the significant benefit the Blue Line‐Red Line connection
would provide to the entire MBTA transit system in the form of measurable
congestion relief for both the Park Street and Government Center Stations
SIP 2014 - Page 72
which must accommodate Blue Line passengers bound for Mass. General
Hospital and Cambridge. These passengers now must change at Government
Center, take the Green Line to Park Street and then board the Red Line. By
bypassing both of these congested stations the Blue Line‐Red Line Connection
would benefit the entire MBTA system.
I have attached two letters from 2005 and 2006 in which I commented on this
issue and I resubmit now in regards to July 22, 2014 MassDOT annual update and
status report for transit projects.
Specifically I request that DEP rescind its decision of October 8, 2013 that
approved MassDOT’s request to eliminate the Blue Line-Red Line Connector
design as an obligation, and to immediately inform the U.S. Environmental
Protection Agency of its reversal of last year’s vote.
Thank you,
John Vitagliano
CC: Speaker Robert DeLeo
Senator Anthony Petruccelli
Senator Edward Markey
Senator Elizabeth Warren
Congresswoman Katherine Clark
SIP 2014 - Page 73
John Vitagliano
19 Seymour Street
Winthrop, MA 02152
January 10, 2005
The Honorable Daniel A. Grabauskas, Secretary
Executive Office of Transportation
Commonwealth of Massachusetts
10 Park Plaza—Suite 3170
Boston, Massachusetts 02116
Mr. Robert W. Golledge, Jr., Commissioner
Department of Environmental Protection
Executive Office of Environmental Affairs
One Winter Street
Boston, Massachusetts 02108
Subject: MBTA Blue Line‐Red Line Connection Status
Dear Secretary Grabauskas and Commissioner Golledge:
Having served as both Transportation Commissioner for the City of Boston and as a Massachusetts Port
Authority board member I want to express my grave concern about your recent public comments
concerning the proposed MBTA Blue Line connection to the Red Line at Charles Station which infer that
the status of this crucial transit improvement project is under review. When the Big Dig was evolving
through its formulaic stages a major concern was that this impressive project would not be an incentive
for increasing regional automobile dependency so that a number of important transit mitigation
measures were designed to complement the projects highway improvement aspects. These transit
upgrades were considered to be so crucial that they were incorporated into the legally binding 1990
Memorandum of Understanding between EOTC, MHD and CLF in order to provide public assurance of
the Big Digs long term regional traffic and air quality benefits.
Of the transit commitments included in the 1990 MOU none was more important that the proposed direct
connection between the MBTA Blue Line and Red Line at Charles Station. This project would greatly
enhance transit access to the Massachusetts General Hospital for all of the Blue Line communities
including East Boston, Chelsea, Winthrop, Revere, Lynn and others. Presently residents of these
municipalities who wish to use the Blue Line to utilize Mass. General must walk half a mile after
disembarking at the Bowdoin station, a particularly harsh disincentive for the infirm. The Blue Line‐Red
Line connection would also provide significantly improved transit service between these north shore
communities and the many important destinations in Cambridge.
Another major benefit of the Blue Line‐Red Line connection would be much better transit service to
Logan Airport from the residential communities northwest of Boston. Red Line passengers from these
areas must traverse through Park Street Station, the MBTAs most congested station, on their way to
Logan. The same is true for the many business passengers from Cambridge also bound for Logan. Both of
these constituencies would realize a vastly improved transit link to Logan with the Blue Line‐Red Line
connection. It is essential to note here that, contrary to certain published accounts, the new MBTA Silver
Line service is not a competitive substitute for the Blue‐Red connection but rather a fine complement.
SIP 2014 - Page 74
The Silver Lines direct connection to Logan serves only certain Boston origin/destinations without
addressing the northwest communities and Cambridge mentioned herein.
It is also important to note the significant benefit the Blue Line‐Red Line connection would provide in the
form of congestion relief at Park Street Station which suffers from an absence of the kind of primary
system redundancy inherent in the Blue Line‐Red Line connection, an important consideration in light of
contemporary security concerns.
In summary I strongly urge you to immediately initiate a design/build program for the MBTA Blue Line‐
Red Line connection project to assure its completion by the original 2010 deadline obligated by the 1990
MOU.
Sincerely,
John Vitagliano
SIP 2014 - Page 75
John Vitagliano
19 Seymour Street
Winthrop, MA 02152
January 11, 2006
Christine Kirby
Department of Environmental Protection
Bureau of Waste Management
One Winter Street
Boston, MA 02108
Subject: Proposed Amendment to 310 CMR 7.36 to Eliminate Blue Line‐Red Line Connection
Dear Ms. Kirby:
Having served as both Transportation Commissioner for the City of Boston and as a Massachusetts Port
Authority board member I want to express my strong opposition to the proposed amendment to 310
CMR 7.36 which would eliminate the MBTA Blue Line connection to the Red Line at Charles Station, a
public promise that was made in 1990 and which I was directly involved in. When the Big Dig was
evolving through its formulaic stages a major concern was that this impressive project should not be an
incentive for increasing regional automobile dependency, so a number of important transit mitigation
measures were designed to complement the project’s highway improvement aspects. These transit
upgrades were considered to be so crucial that they were incorporated into the legally binding 1990
Memorandum of Understanding between EOTC, MHD and CLF in order to provide public assurance of
the Big Dig’s long term regional traffic and air quality benefits.
Of the transit commitments included in the 1990 MOU none was more important that the proposed direct
connection between the MBTA Blue Line and Red Line at Charles Station. This project would greatly
enhance transit access to the Massachusetts General Hospital for all of the Blue Line communities
including East Boston, Chelsea, Winthrop, Revere, Saugus and others. Presently residents of these
municipalities who wish to use the Blue Line to utilize Mass. General must walk half a mile after
disembarking at the Bowdoin station, a particularly harsh disincentive for the infirm. The Blue Line‐Red
Line connection would also provide significantly improved transit service between these north shore
communities and the many important destinations in Cambridge.
It is also important to note the significant benefit the Blue Line‐Red Line connection would provide to the
entire MBTA transit system in the form of measurable congestion relief for both the Park Street and
Government Center Stations which presently must accommodate Blue Line passengers bound for Mass.
General Hospital and Cambridge. These passengers now must change at Government Center, take the
Green Line to Park Street and then board the Red Line. By bypassing both of these congested stations the
Blue Line‐Red Line Connection would benefit all MBTA users.
Finally I’ve noticed that a large part of the rationale put forward for eliminating the Blue Line‐Red Line
Connection is based on the alleged success of the new Silverline service to Logan Airport, implying that it
replaces an original proposed benefit of the Blue Line‐Red Line Connection. This a classic red herring
argument because the Blue Line‐Red Line Connection was never justified to improve transit access to the
airport but rather as a major public transit improvement between the major population centers of
Boston’s north shore region and Cambridge and Mass. General Hospital. During my fourteen years as a
SIP 2014 - Page 76
Massport board member and as Boston’s Transportation Commissioner the Blue Line‐Red Line
Connection was never proposed as an airport transit access palliative.
I strongly urge you to categorically reject the recommended elimination of the Blue Line‐Red Line
Connection and instead require that it be completed as originally promised
Sincerely,
John Vitagliano
SIP 2014 - Page 77
THE COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
BUREAU OF WASTE PREVENTION
DIVISION OF CONSUMER AND TRANSPORTATION PROGRAMS
NOTICE OF SCHEDULED PUBLIC MEETINGS
Notice is hereby given that the Massachusetts Department of Environmental Protection
(MassDEP), under its authority pursuant to M.G.L. Chapter 111, Sections 142A through 142M,
will hold two public meetings pursuant to subsections (4) and (7) of 310 CMR 7.36, the Transit
System Improvements regulation.
The public meetings will be conducted to receive public comment, both oral and written, on the
annual update and status report for transit projects required by 310 CMR 7.36 (2) (f) through (j) and
on the petition to delay the Green Line Extension Project pursuant to 310 CMR 7.36(4). The
Massachusetts Department of Transportation (MassDOT) submitted the update, status report and
petition to MassDEP on July 22, 2014.
Two public meetings will be held:
On:
At:
October 2, 2014 at 2:00PM - 3:30PM and October 6, 2014 at 5:00PM - 6:00PM.
The 5:00 PM public meeting will be extended after 6:00 PM as needed to allow
all interested parties attending to present testimony.
Washington Street Conference Center, 2nd Floor, Rooms A, B, & C
MassDEP, One Winter Street, Boston, MA 02108.
The public meeting site is wheelchair accessible. This information is available in alternative format
upon request by contacting Michelle Waters-Ekanem, MassDEP’s Diversity Director, at (617) 2925751. TDD Service 1-866-539-7622 or 617-574-6868, One Winter Street, Boston, MA 02108.
Testimony may be presented orally and/or in writing at the public meetings. Written testimony will
be accepted until 5:00 PM on Tuesday, October 14, 2014. Written testimony must be submitted to:
Sreelatha Allam at MassDOT, Office of Transportation Planning, Room 4150, Ten Park Plaza,
Boston, MA 02116 or sreelatha.allam@dot.ma.us and Jerome Grafe at MassDEP, Bureau of Waste
Prevention, One Winter Street, Boston, MA 02018 or jerome.grafe@state.ma.us.
Copies of the update and status report will be available for inspection during normal business hours
at MassDEP, One Winter Street, Boston MA. In addition, the report will be available on
MassDOT’s website at: www.state.ma.us/massdot/SIP
By order of the Department.
David W. Cash, Commissioner
SIP 2014 - Page 78
From:
To:
Subject:
Date:
K Molloy
Sreelatha.Alam@dot.ma.us; Grafe, Jerome (DEP)
My comments regarding Interim Offsets proposed by MBTA for delay in the GLX project.
Tuesday, October 14, 2014 5:09:41 PM
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning
Room 4150
Ten Park Plaza
Boston, MA 02116
Dear Ms Allam,
I am writing to comment on the interim mitigation measures to be
implemented by December 31, 2014, the legal deadline for the
implementation of the GLX.
Specifically I'd like to comment on this measure:
"Additional off peak service along existing routes serving the GLX
corridor, including the Green Line, and bus routes 80, 88, 91, 94 and
96."
As a car-free, longtime bus-riding resident of Somerville I'm glad to
see a commitment to improving the dwindling service on these bus
routes.
As a rider who depended on buses for decades, I would ask you to add
two more bus routes to this list:
#90 bus between Davis Sq and Sullivan Sq. This bus route, which has
never had a good schedule and has a horrible schedule adherence record
is the means by which many Somervillians get to jobs in the new
Assembly Row complex. Having to rely on this bus, which travels route
not covered by other bus routes, is a real hardship. Please look into
this.
#85 between Spring Hill and Kendall Sq. is another route that many
Somervillians who work in Kendall Sq depend on for jobs. (I used to
depend on it myself.) But it has a big void in its service -- no
nighttime or weekend service. I've never understood why the T has not
increased this key route service that connects central Somerville to
Kendall Sq. and MIT.
I urge you to add service to these two routes that connect residents
to key commercial districts as part to the GLX interim mitigation
measures.
Thanks very for your consideration.
-Karen Molloy
197 Highland Ave.
Somerville, MA 02143
SIP 2014 - Page 79
kmolloy@gmail.com
SIP 2014 - Page 80
Kenneth J. Krause
50 Mystic Street Medford, MA 02155
781-396-0920 kenneth.krause@comcast.net
October 14, 2014
Matthew Ciborowski
MassDOT Office of Transportation Planning
Room 4150, Ten Park Plaza
Boston, MA 02116
Jerome Grafe
MassDEP, Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
Dear Mr. Ciborowski and Mr. Grafe,
Thank you for the opportunity to comment on the Annual Update and Status Report for Transit
Commitments required by 310 CMR 7.36(2), and on the petition to delay the Green Line
Extension pursuant to 310 CMR 7.36(4), both submitted by the Massachusetts Department of
Transportation (MassDOT) and the Massachusetts Bay Transportation Authority (MBTA) to the
Massachusetts Department of Environmental Protection (MassDEP) on July 22, 2014.
Green Line Extension to Somerville and Medford
After two consecutive years of significant progress and almost 100% positive developments in
the Green Line Extension (GLX) project, the past year saw additional important milestones
achieved, but also a potentially troublesome return to a delay in the completion schedule, which
was revealed in the Annual Status Report.
The MBTA and the GLX Project Team are to be commended for:


Proceeding into the second year of Phase I construction on time and on budget
Completing Advanced Preliminary Design and advancing station designs past 60% to
near 90%

Submitting a GLX Project Finance Plan and New Starts Update package to the Federal
Transit Administration (FTA) and making further progress toward submitting a Full
Funding Grant Application to FTA

Receiving a Letter of No Prejudice from FTA to allow advance work associated with the
Fitchburg Main Line and Millers River Drainage, which is crucial to the Phase 2/2A
construction being completed on time

Hiring an Independent Cost Estimator as part of the CM/GC delivery method

Achieving MassDOT board approval for a $118 million contract with CAF USA to supply
24 new Green Line vehicles in 2017 and 2018

Acquiring properties and starting to relocate businesses in order to obtain land for the
Green Line maintenance and storage facility in Somerville
MassDOT also is be commended for agreeing to not only design but also construct the
Community Path from the proposed Lowell Street station to the Cambridge/North Point area,
Kenneth J. Krause - 2014 SIP Annual Report
SIP 2014 - Page 81
even though construction of the Community Path is not part of the SIP commitment. This is a
valuable complementary project that makes sense to construct as part of this project as
opposed to later.
However, a disconcerting development is new delays in the project completion timetable
compared to last year’s Annual Status Report — about six months for Phases 2 and 2A, and of
approximately 12 months for Phase 4. The Phase 2/2A delays were indicated in the monthly
GLX status reports over the last year, but the Phase 4 delay was not:
Phase 2/2A Completion
Phase 4 Completion
2013 Annual Status Report
(7-1-13)
Early 2017
End of July 2019
September Monthly Report
(9-19-2013)
Early 2017
End of July 2019
October Monthly Report
(10-17-2013)
Late Spring 2017
On or before July 2019
November Monthly Report
(11-21-2013)
Late Spring 2017
On or before July 2019
December Monthly Report
(12-19-2013)
Mid-2017
On or before July 2019
January Monthly Report
(1-23-14)
Mid-2017
On or before July 2019
February Monthly Report
(2-20-14)
Mid-Summer 2017
On or before July 2019
March Monthly Report
(3-20-14)
Mid-Summer 2017
On or before July 2019
April Monthly Report
2014 Annual Status Report
(4-17-14)
Mid-Summer 2017
Late 2017*
On or before July 2019
June 2020
(7-22-14)
* Since the release of the 2014 Annual Status Report, the completion deadlines have been pushed back even farther
for Phase 2/2A, to December 2017 (GLX Design Working Group meeting presentation, October 2, 2014).
The Annual Status Report provides no reason for the changes to the proposed completion
schedule, although they logically could be related to additions to the project scope and design
modifications noted in the section on the project budget, which has grown to $1.665 billion, up
from $1.33 billion in the 2013 Annual Status Report. However, the majority of those items
involve Phase 2/2A work, not Phase 4 work.
MassDEP should request that the MBTA provide a detailed explanation for all significant
schedule changes, as they put MassDOT further in arrears of meeting one of the important
remaining SIP Requirements, as noted on Page 9 of the Annual Status Report:
“On or before 18 months after MEPA’s issuance of a certificate on an FEIR or an SEIR,
MassDOT must complete final design, apply for all necessary permits funds and grants, file any
required legislation, and initiate all public and private land acquisition.”
MEPA issued its certificate on the FEIR on July 30, 2010, meaning the final design and other
deliverables listed in the paragraph above were due on January 1, 2012. The 2014 Annual
Status Report states that “expected completion” of these items is 2015, or more than three
years late. MassDEP should remind the MBTA of the urgency of completing these tasks in order
for MassDOT to be making sufficient progress toward fulfilling all of the SIP Requirements.
One notable absence in the Annual Status Report was any reference to the MassDOT Preferred
Full Build Alternative terminus station on the Medford Branch of the GLX at Mystic Valley
Parkway/Route 16. While not part of the SIP, the final section of the expansion beyond College
Avenue continues to receive programmed funds from the Boston Region Metropolitan Planning
Organization. This year, $39.9 million was programmed for Federal Fiscal Year 2018 in the
Kenneth J. Krause - 2014 SIP Annual Report
SIP 2014 - Page 82
2015-18 Transportation Improvement Program, bringing to $78 million the total funding
programmed for Federal Fiscal Years 2016-18:
In its response to public comments on last year’s SIP Annual Status Report, dated January 17,
2014, MassDOT acknowledged the MPO’s funding allocation, adding: “This will allow for further
design and environmental work [for the Mystic Valley Parkway/Route 16 Station] to be
undertaken at that time. MassDOT and the MBTA plan to shortly commence the preliminary
work that will be necessary to restart planning, design and environmental review in earnest when
the funds become available in 2016.”
With the start of FFY2016 less than a year away (October 1, 2015), MassDOT should be
referencing the Route 16 phase of project in its annual and monthly status reports, as it does with
the Community Path, another non-SIP commitment. Also, the MBTA and the GLX Project Team
should ensure that final design of the College Avenue station is completed in such a way as to
accommodate the continuation of the Green Line to Route 16. (I’m pleased to note that the
statement in the 2013 Annual Status Report that “Completion of Phase 4 [College Avenue
Station] also represents completion of the Green Line Extension project” does not appear in the
2014 Annual Status Report.)
Petition to Delay the Green Line Extension Project
The Petition to Delay the Green Line Extension, filed with the Annual Status Report, is in some
ways a formality, given that MassDOT announced in 2011 that it would be unable to meet the
December 31, 2014 legal deadline for completing the Green Line Extension to Medford Hillside.
However, I find the Petition to Delay unacceptable for two reasons: it lacks evidence that the
interim offset projects it proposes will achieve the required emission reductions equal to or
greater than the emission reductions that would have been achieved had the GLX project not
Kenneth J. Krause - 2014 SIP Annual Report
SIP 2014 - Page 83
been delayed, and there is no assurance that the proposed offset project will be in place by
December 31, 2014, as required.
Interim Offset Project #1 – increasing off-peak service on the Green Line and on five bus
routes in Somerville and Medford – is the most sound of the three proposed measures, as it will
provide the most practical alternatives to auto travel and also occurs within the GLX corridor.
Interim Offset Project #2 – the purchase of 142 new hybrid electric vehicles for The Ride
paratransit service – is valuable in theory, but there is no evidence that these vehicles can or
will be in place by the required date of December 31, 2014. MassDEP doesn’t even typically
issue its certification letter on the SIP Annual Status Report until March, April or even May of the
following year; how can MassDOT solicit bids for, purchase, and get on the road 142 new hybrid
electric vehicles if 10 weeks from the implementation deadline, MassDEP has not approved the
Petition to Delay and the proposed interim offset projects?
Interim Offset Project #3 – additional park-and-ride spaces in Beverly and Salem – is by far the
weakest of the proposed measures and the one with the most questionable emission reduction
projections. Central Transportation Planning Staff data show the added garage capacity will
result in a reduction of 30,372 vehicle miles traveled in 2015. Divided by 245 calendar working
days, that equates to about 125 miles per day. Given that round-trip driving distances from
Beverly and Salem North Station are 44 and 41 miles, respectively, the 125 miles of daily VMT
reduction equals approximately three round-trips removed from the road per day by people
choosing to park-and-ride the commuter rail rather than drive to Boston. Surely the removal of
three round-trips per day will not register significant emissions reductions. Further, there is no
assurance that the destination of drivers who park in the garage will be North Station; they could
be headed north on the commuter rail line or to any other inbound station, or to a destination
within walking distance of the garage.
Lastly, it is unclear whether the new Beverly and Salem parking garages are even eligible for
submission as interim offset projects, because they are the result of other legal contracts signed
years ago. Their openings in August and October 2014 appear to have made them convenient
additions to the list of GLX interim offset projects.
Given the shortcomings of the interim offset projects, I suggest that MassDEP reject the Petition
to Delay as submitted, and require MassDOT to propose more effective interim offset projects,
which would include considering:

An increase of off-peak service on the Route 90 (Somerville-Medford) and Route CT2
(Somerville-Cambridge-Boston) bus routes

The addition of more diesel-electric locomotives on the Lowell, Haverhill and Fitchburg
Line commuter rail trains that travel through the GLX corridor

Additional bicycle parking facilities at the Wellington, Sullivan, Assembly, Porter Square
and Davis Square heavy rail stations, and the West Medford commuter rail station.
Finally, MassDEP’s certification/approval of the GLX Petition to Delay should require MassDOT
to supply, in its Annual Status Report, data on the emissions reductions achieved through the
interim offset projects. If the emissions reductions are falling short of those that would have been
achieved through the GLX implementation, MassDEP should require MassDOT to propose new
or additional interim offset projects for the duration of the delay.
Kenneth J. Krause - 2014 SIP Annual Report
SIP 2014 - Page 84
These interim offset projects take on increasing importance as the GLX implementation
schedule is again seeing delays, and it is crucial that they provide the required emission
reductions.
Red Line/Blue Line Connector Design
I was disappointed to read in the Annual Status Report that on October 8, 2013, MassDEP
approved a request made by MassDOT in July 2011 to revise 310 CMR 7.36 to remove the
requirement for MassDOT to complete the design of the Red Line/Blue Line Connector.
The need to link the only MBTA heavy rail lines that do not intersect has never been greater. The
corridor served by these two lines continues to experience explosive growth, particularly in new
jobs and housing created or under development in Cambridge, South Boston, and East Boston.
Further, the recent selection of Everett as the location for the Boston area casino further
illuminates the importance of improving mobility and public transit service near this destination.
In addition, a strong effort is being made to bring the 2024 Olympics to Boston. One selling point
of bringing the Games to Boston is that it will spur significant investment in upgrading the region’s
public transportation system, which will be essential for the Boston area to accommodate the tens
of thousands of Olympic visitors.
Having the design complete for the Red/Blue Connector – an immensely valuable project
integral to the efficiency of the MBTA system and its ability to meet increasing ridership
demands – will put it near the head of the list of system improvements that could be funded
should Boston’s Olympic bid be successful.
Lastly, I encourage MassDEP to remain vigilant in monitoring the state’s progress toward
fulfilling its SIP obligations, and to be a vocal advocate for the state legislature to continue
working toward a sustainable funding mechanism in support of all of the commonwealth’s many
transportation needs. Without such support from MassDEP, the environmental and health
benefits expected from these projects might never be realized.
Thank you for your consideration.
Ken Krause
50 Mystic St.
Medford, MA 02155
781-396-0920
cc:
David W. Cash, Commissioner, MassDEP
Richard Davey, Secretary of Transportation
Clinton Bench, Chair, Boston Region MPO
Dr. Beverly Scott, General Manager, MBTA
Kenneth J. Krause - 2014 SIP Annual Report
SIP 2014 - Page 85
From:
To:
Cc:
Subject:
Date:
Kevin M Cuddeback
Ciborowski, Matthew (DOT); Grafe, Jerome (DEP)
info@medfordgreenline.org
MassDOT SIP Public Comment (2014 Status Report & GLX Delay Offsets)
Tuesday, October 14, 2014 10:52:36 AM
Dear Sirs,
I believe that the MassDOT State Implementation Plan 2014 Status Report does not
go far enough in offsetting the delay until 2020 of the Somerville-Medford portion of
the Green Line Extension.
While an increase in off-peak buses that connect Somerville-Medford to rapid transit
is welcome, the real problem is infrequent service during rush hour, such that local
people cannot create a reliable commute that involves "less car".
I also do not see how an under-used new Garage in Beverly (early reports were that
only 100 spots out of 500 were being used on a daily basis) or a similar garage in
Salem will do enough to divert trips from car to transit.
Certainly, the first, best, choice is to further accelerate Phases 3 and 4 of the Green
Line Extension itself.
Second best, rather than sprinkling a few buses around the area to produce small
headway improvements and still-near-random service headways at non-rush times, I
believe it would be better to pick two routes to be the "rush hour winners",
producing a bus service "worth walking to" because it has "clockface" service of
every 12minutes or every 15minutes. This is the "most like" a light rail service, and
is the only fitting subsitute for a GLX delay
I'd nominate the 94 and 88 buses for this "concentrated" rush hour service addition.
In the alternative, Please consider creating a full-time new bus, such as the 96L that
would travel Medford Sq to Davis (as usual) but then follow the 88 route to
Lechmere, or adding just one or two buses to the 94 and 87 during rush hour
Sincerely,
Kevin Cuddeback
West Medford.
SIP 2014 - Page 86
From:
To:
Subject:
Date:
Kevin Donovan
Allam, Sreelatha (DOT); jerome.grafe@massmail.state.ma.us; Friends of the Community Path
Comments- SIP, GLX Petition to Delay, Interim Offsets
Tuesday, October 14, 2014 6:14:25 PM
Dear Sreelatha Allam and Jerome Grafe,
Thank you for this opportunity to comment on the annual State Implementation Plan (SIP) Transit
Commitments report ( http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf .
I am pleased that MassDOT is proceeding with the GLX implementation.
However, I do not agree with MassDOT’s recommendation to stop the design of the Red/Blue
connector and eliminate it from the SIP. I also voice my concerns here about the proposed GLX
interim offsets to produce the stated air quality benefits:
20% increase in off-peak vehicle trips per hour for all Green Line services: I hope that the proposal to
increase “all Green Line services” requires a specific increase in service to Lechmere station; not just
to the Green Line on average, or as a whole.
20% increase in off-peak bus service in the GLX corridor: MBTA should collect data to verify this mode
shift and associated air quality benefits. Please add more service to the #90 bus and the #85 bus.
Also please add bus priority sensors and signal prioritization to traffic lights in Somerville, Medford, and
Cambridge.
The purchase of 142 new hybrid vehicles for the RIDE should not be double -counted also as SIP
commitments, since it is already required to meet GreenDOT carbon emission reduction goals; for
compliance with Executive Order 44; and for compliance with the Global Warming Solution Act and
Green Communities Act benchmarks.
The addition of 374 Park and Ride Spaces in Salem and 378 more commuter parking spaces at
Beverly Station should not be permitted as for GLX Interim Offsets, because the parking garages were
already under contract (in addition to not providing benefits to the area of the GLX).
Please instead do these interim offsets, due to their health and air quality benefits and regional
potential:
1. MassDOT/MBTA to complete the design and full construction of the Community Path extension (CPX).
This will also ensure that future administrations do not carve the CPX from the GLX project.
2. MassDOT/MBTA to design and construct a GLX Twin Cities path spur from the CPX to Twin Cities
Plaza.
3. Provide free transit and Hubway programs during the delay. This will also provide a financial incentive
for timely project completion
4. Accelerate other regional bicycle/pedestrian paths and facilities equal to 50% or more of the GLX air
quality benefits, to reach the GLX’s environmental benefits and also fulfill the above goals,
5. Reject any additional diesel rail stops on commuter rail lines through the area. Diesel rail pollutes
communities most during when starting from a stop. Diesel emission are classified by WHO as a Class
1 carcinogen just like smoking and asbestos.
6. Deploy new cleaner diesel commuter rail locomotives for the Fairmount Line and GLX corridors.
Thank you.
Kevin Donovan
42 Marshall St
Somerville MA 02145
-Kevin Donovan
Mobile: 603 703 3057
SIP 2014 - Page 87
Work: 603 669 3100
SIP 2014 - Page 88
From:
To:
Subject:
Date:
Leonard H. Tower Jr.
Allam, Sreelatha (DOT); Grafe, Jerome (DEP); friendspath@yahoo.com
Comments- SIP Red/Blue Connector, GLX Petition to Delay, Interim Offsets
Tuesday, October 14, 2014 5:52:12 PM
Dear Sreelatha Allam and Jerome Grafe:
Thank you for this opportunity to comment on the annual State
Implementation Plan (SIP) Transit Commitments report (
http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf. I
am pleased that MassDOT is proceeding with the GLX implementation.
I do not agree with MassDOT’s recommendation to stop the design of the
Red/Blue connector and eliminate it from the SIP. THE CONNECTOR IS A
VITAL IMPROVEMENT TO THE SUBWAY SYSTEM, AND WILL OFF LOAD A LOT OF RUSH
and NON-RUSH HOUR TRAFFIC FROM THE GREEN AND RED LINES, AND AIRPORT
TRAFFIC FROM THE SILVER LINE.
IT WILL ALSO REDUCE TRIP TIMES INVOLVING THE RED AND BLUE LINES.
I am also concerned about the proposed GLX interim offsets to produce
the stated air quality benefits:
* 20% increase in off-peak bus service in the GLX corridor: MBTA should
collect data to verify this mode shift and associated air quality
benefits. PLEASE ADD MORE SERVICE TO THE #90 BUS AND THE #85 BUS.
Also please add bus priority sensors and signal prioritization to
traffic lights in Somerville, Medford, and Cambridge.
* 20% increase in off-peak vehicle trips per hour for all Green Line
services: I hope that the proposal to increase “all Green Line
services” requires a specific increase in service to Lechmere
station; not just to the Green Line on average, or as a whole.
* The purchase of 142 new hybrid vehicles for the RIDE should not be
double-counted also as SIP commitments, since it is already required
to meet GreenDOT carbon emission reduction goals; for compliance with
Executive Order 44; and for compliance with the Global Warming
Solution Act and Green Communities Act benchmarks.
* The addition of 374 Park and Ride Spaces in Salem and 378 more
commuter parking spaces at Beverly Station should not be permitted as
for GLX Interim Offsets, because the parking garages were already
under contract (in addition to not providing benefits to the area of
the GLX).
Please instead do these interim offsets, due to their health and air
quality benefits and regional potential:
* MASSDOT/MBTA TO COMPLETE THE DESIGN AND FULL CONSTRUCTION OF THE
COMMUNITY PATH EXTENSION (CPX). This will also ensure that future
administrations do not carve the CPX from the GLX project.
* PROVIDE FREE TRANSIT AND HUBWAY PROGRAMS DURING THE DELAY. THIS WILL
ALSO PROVIDE A FINANCIAL INCENTIVE FOR TIMELY PROJECT COMPLETION
* ACCELERATE OTHER REGIONAL BICYCLE/PEDESTRIAN PATHS AND FACILITIES
EQUAL TO 50% OR MORE OF THE GLX AIR QUALITY BENEFITS, TO REACH THE
SIP 2014 - Page 89
GLX’S ENVIRONMENTAL BENEFITS AND ALSO FULFILL THE ABOVE GOALS,
* Deploy new cleaner diesel commuter rail locomotives for the Fairmount
Line and GLX corridors.
* Reject any additional diesel rail stops on commuter rail lines
through the area. Diesel rail pollutes communities most during when
starting from a stop. Diesel emission are classified by WHO as a
Class 1 carcinogen just like smoking and asbestos.
* MassDOT/MBTAto design and construct a GLX Twin Cities path spur from
the CPX to Twin Cities Plaza.
Thank you.
Leonard Tower Jr.
36 Porter Street - Apt. 2
Somerville, MA 02143-2313
SIP 2014 - Page 90
From:
To:
Cc:
Subject:
Date:
Linda Carrubba
Grafe, Jerome (DEP)
""Alessandro""; """Isabella Ferrari"""
GLX Mitigation
Friday, October 10, 2014 4:52:00 PM
Hello,
I wanted to provide a comment on the GLX mitigation proposals. As someone who
walks to work & uses public transit mostly on weekends, I very strongly support
increased off peak service on bus lines such as the 80 and the 88. There is nothing
worse than taking the green line to Lechmere and having to stand around in the
cold for a half hour waiting for the next bus. It can be very cold at the Lechmere
stop!
Thanks,
Linda
-----------------------------Linda Carrubba
20 Wesley St.
Somerville, MA 02145
SIP 2014 - Page 91
From:
To:
Subject:
Date:
Matthew Danish
sreelatha.allam@dot.ma.us; Grafe, Jerome (DEP)
Public comment on petition to delay Green Line extension project
Tuesday, October 14, 2014 2:11:58 PM
To whom it may concern:
I would like to join in sharing the Conservation Law Foundation's criticism of
proposed mitigation measures. The parking spaces at the newly constructed garages
in Salem and Beverly do not and shall not count as air pollution mitigation in lieu of
the Green Line Extension for several reasons, above and beyond the excellent points
made by the CLF.
First of all, parking spaces do not count as air pollution mitigation, ever. Parking
spaces induce driving, and driving causes exhaust fumes that waft over the entire
region. You should never count any parking supply construction as air pollution
mitigation, ever again. It was wrong to do so in the past.
Number two, according to recent news articles, the parking garages are not being
used significantly. So even if they did contribute to air quality (which they don't)
they would be considered ineffective. The construction of those two garages was a
complete waste of money that is only hurting the communities of Salem and
Beverly, at great taxpayer expense. You cannot claim them as mitigation for the
Green Line Extension delay, in Somerville and Medford.
Here is a list of suggestions that will work towards the goal of helping air quality in
the communities of Somerville and Medford during the delay of the Green Line
Extension project:
Increased bus service on existing routes, as DOT proposes.
Increased Green Line service to Lechmere, as DOT proposes.
Creation of new bus route that primes the Green Line Extension route,
precisely, by attempting to duplicate the future line as much as possible on
surface streets.
Consideration and acquisition of the zero-emission battery-powered buses such
as those procured by WRTA this year, for use on local routes.
Installation of additional Hubway stations.
Funding of safer on-street bicycle and pedestrian infrastructure in the vicinity
of the Green Line Extension, including but not limited to:
Protected bicycle tracks,
Raised crosswalks at key intersections,
Fully tabled intersections at high-pedestrian-traffic locations,
Curb extensions and rapid-response flashing beacons at known sites of
danger to pedestrians crossing,
Further study and walking audits to learn what else is needed,
Curb extensions at bus stations to help load and unload passengers
efficiently, and
Additional funding to bring all crosswalks and intersections up to modern
accessibility standards, including but not limited to curb ramps with high
contrast tactile plates as well as audible pedestrian signals.
Removal of McCarthy Overpass in favor of an at-grade solution, and rightsizing the McGrath Highway to a proper city street of no more than 4 general
purpose travel lanes.
SIP 2014 - Page 92
All or several of these suggestions are welcome to be used.
Thank you,
Matthew Danish
SIP 2014 - Page 93
October 6, 2014
David W. Cash
Commissioner
Department of Environmental Protection
One Winter Street
Boston, MA 02108
RE: 2014 State Implementation Plan Transit Commitments Status Report
Dear Commissioner Cash:
The Conservation Law Foundation (“CLF”) has reviewed the State Implementation Plan
(“SIP”) Transit Commitments Status Report filed on July 22, 2014 (“2014 SIP Status Report”).1
We are pleased that the Commonwealth continues to advance SIP projects and appreciate the
progress that has occurred during the last year. At the same time, however, CLF remains
concerned about the continued estimated project delays and the lack of sufficient expenditure of
funds to ensure that all of the remaining SIP projects are completed on schedule or as close to it
as still possible. The Commonwealth’s legal obligation to complete these projects is binding
under the federal Clean Air Act and pursuant to the settlement agreement in CLF v. Romney et
al., United States District Court for the District of Massachusetts, Civil Action No. 05-1048
(hereinafter, CLF v. Romney); the projects are crucial to achieving attainment of ambient air
quality standards, and are vital to the health and mobility of the area’s residents.
The SIP requires that status reports be filed annually to ensure that projects do not fall
behind schedule and the necessary steps are taken so that compliance with the Clean Air Act is
not delayed in the event that challenges arise. We urge the Massachusetts Department of
Transportation (“MassDOT” or “Department”), the Massachusetts Department of Environmental
Protection (“DEP”), and the U.S. Environmental Protection Agency (“EPA”) to take all
necessary actions to respond to the remaining delays, reduce them, and avoid the need for
additional future delays. This should include the provision and implementation of detailed and
expedited project schedules, and, where necessary and permissible, identification and
implementation of further interim emission reduction offset projects or measures. See 310 CMR
7.36(4). More detailed comments on each of the projects discussed in the SIP Status Report and
the need for interim offset projects or measures are provided below.
1
Annual SIP Status Reports are due on July 1st of every year. See 310 C.M.R. 7.36(7). This year’s report was
submitted late on July 22, 2014; as a result, MassDOT failed to comply with the state and federal reporting
obligation.
SIP 2014 - Page 94
Green Line Extension
Since last year’s SIP status report was released, the Commonwealth made significant progress on the
Green Line Extension project. In March of 2014, the Green Line Extension was recommended for
$100 million in funding in President Obama’s FY2015 budget. In July of 2014, the MBTA received
a letter from the Federal Transit Authority approving a Letter of No Prejudice, which allows critical
construction work to commence prior to approval of the New Starts application for federal funding.
That was a significant milestone and success for the project, as any work performed now on the
Green Line Extension will be eligible for federal funding retroactively, if the MBTA is awarded
New Starts funding. In addition, in May of 2014, the MBTA agreed to include the construction of
the Somerville Community Path in the Green Line Extension Project. These are big steps towards
completion of this SIP requirement.
Nevertheless, the Green Line Extension project unfortunately continues to be plagued by
delays, which MassDOT has not fully explained. In its 2011 SIP Status Report, MassDOT
reported that the Commonwealth would not meet the SIP deadline of December 31, 2014 for the
Green Line Extension project. MassDOT stated that the new estimates for the delays of the
Green Line Extension project stem from a risk assessment that was performed based on the
results of a FTA Project Management Oversight Consultant Risk Assessment Workshop (“Risk
Assessment”). See 2011 SIP Status Report at 17. In its 2012 and 2013 SIP status reports,
MassDOT estimates that service to College Avenue Station will open by July 2019. The Risk
Assessment, however, states in its executive summary that the “schedule risk modeling points to
a revenue service date that could slip from October 2015 to the range of March 2017 to
December 2017” (emphasis added). See Risk Assessment Green Line Extension Report dated
August 1, 2011, at i. Although CLF has raised this issue before, MassDOT provides no
explanation for the additional nineteen months delay in its petition to DEP, its 2011, 2012, and
2013 SIP status reports, or otherwise, which violates the Transit System Improvement
regulations. See 310 C.M.R. 7.36(4)(c). Regardless of the reporting requirement, this new
timeline is clearly inconsistent with the SIP and the 2006 CLF v. Romney settlement agreement.
As a result of these delays, the Commonwealth is required to implement interim offset
projects or measures, which are required to achieve emissions reductions equal or greater than the
emissions reductions that would have been achieved had the project not been delayed. See 310
C.M.R. 7.36(4)(b). To this end, MassDOT recently proposed additional off-peak bus service along
existing routes serving the GLX corridor as well as a 20% increase in off-peak Green Line service to
Lechmere Station. Additionally, MassDOT has proposed to purchase 142 new hybrid electric
vehicles for The RIDE. Finally, MassDOT seeks to achieve significant portion of the air quality
benefits required during the delay of the GLX through park and ride spaces at the Salem and Beverly
intermodal facilities. While all of these measures are beneficial transit projects, they do not all meet
the requirements for interim offset projects and measures as defined by the SIP. Please see CLF’s
comment letter on MassDOT’s petition to delay dated October 6, 2014 for more details.
2
SIP 2014 - Page 95
Prior to proposing these specific interim offset measures, MassDOT accepted
recommendations for interim offset projects and measures from the public and worked with the
Central Transportation Planning Staff (“CTPS”) and the MBTA to calculate the reductions
NMHC, CO, NOx associated with projects and measures under consideration. MassDOT should
continue to involve the public in the identification and selection of additional interim offset
projects or measures required. CLF together with other stakeholders, in a letter dated September
22, 2010, provided a list of suggested interim offset projects and measures to MassDOT, many of
which were analyzed, which could serve as a starting point. Preference should be given to
projects or measures located in the neighborhoods that are intended to benefit from emissions
reductions attributable to the Green Line Extension project.
Repeating the previous five years’ SIP Status Report omission, the 2014 SIP Status
Report also does not provide adequate information about the Commonwealth’s funding plan for
the Green Line Extension. See 310 C.M.R. 7.36(7)(a). CLF hereby renews, once again, its
request that MassDOT complete and make publicly available a detailed funding plan for the
Green Line Extension Project. The funding plan should cover the fifty percent state match
required if the project receives federal funds through New Starts as well as the complete
projected capital costs of the project in case no federal funding is obtained. The 2012 SIP Status
Report stated that while the Green Line Extension project is “in many ways, an excellent
candidate for the New Starts Program,” “the fundamental financial realities facing the MBTA”
are a real hindrance to obtaining federal funding. See 2012 SIP Status Report at 20. It is CLF’s
understanding that the Transportation Finance Act, which passed on July 24, 2013, addressed the
MBTA’s budgetary needs sufficiently and thereby removed this obstacle.
CLF continues to be troubled by the proposed segmentation of the Green Line Extension
Project. This makes even less sense if one considers MassDOT’s proposed delays of the project
and that the Boston Region Metropolitan Planning Organization has included the segment of the
Green Line Extension between College Avenue and Route 16 in its three most recent
Transportation Improvement Programs. To comply with the SIP, MassDOT must construct an
extension of the Green Line “from Lechmere Station to Medford Hillside” by December 31,
2014. See 310 C.M.R. 7.36(2)(j)1. The Green Line Extension Project, as proposed, does not
comply with the SIP, since Medford Hillside’s well-documented historical boundaries do not
include the location of the proposed terminus at the intersection of College Avenue and Boston
Avenue.2 Any interim offset project or measure selected for the delay the project should
therefore include the full air quality benefits expected from the extension to Route 16.
2
For a more detailed explanation of this issue, please see CLF’s comments on the Draft and Final Environmental
Impact reports for the project available at
http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.
pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf
respectively.http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5
3
SIP 2014 - Page 96
Fairmount Line Improvement Project
CLF was excited to experience the opening of three of the four new stations on the
Fairmount Line last year. This year, CLF was delighted to see that, after the successful
implementation of a pilot project, the MBTA recently announced that the new fare structure for
the Fairmount Line will be permanent. Travel between any two stations on the Fairmount Line,
with the exception of a trip of the full length of the line in either direction, i.e., between
Readville and South Station, are now permanently the same fare as a subway trip. This
represents another huge step forward in making the Fairmount Line an affordable and practical
alternative for low-income residents in the corridor and will be crucial to this project’s success.
Although many aspects of the Fairmount Line Improvement project have now been
completed, unfortunately, one station continues to be delayed. While three years ago the MBTA
anticipated construction of the Blue Hill Avenue Station to start by May of 2012, this year’s
update states that “it is unlikely that the Blue Hill Avenue Station will be completed before 2016
at the earliest.” See 2014 Status Report at 4. Last year’s update, predicted a completion date of
2015, which means there is now an additional delay of one year and that essentially no progress
was made over the past twelve months. While CLF understands the nature of the challenges the
MBTA and MassDOT have experienced in this area, we expect a more concrete timeline for the
completion of the final station at the earliest possible date. CLF appreciates that, in response to
the this delay, MassDOT continues to run two interim offset measures: shuttle bus service from
Andrew Square to Boston Medical Center and increased weekday bus service on the Route 31
bus which serves Mattapan and Dorchester.
Construction of 1,000 New Parking Spaces
MassDOT failed to include the 1,000 new parking spaces required by the SIP in its 2013
and 2014 Status Reports. While MassDOT has succeeded in bringing this SIP requirement close
to completion, there have been significant changes since MassDOT stopped reporting and there
is some potential of further changes. As a result, DEP should require MassDOT to continue
reporting on this requirement until the full accounting of parking spaces is settled.
Since last year, 102 surface parking spaces in Beverly that MassDOT counted towards
fulfilling of this requirement have been eliminated and were replaced with parking spaces in the
new garage, which opened on August 2, 2014. MassDOT has never reported on this
development as part of a SIP annual update.
_20100615.pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf
respectively.
4
SIP 2014 - Page 97
Likewise, in response to CLF’s comments, MassDOT provided more details of an
agreement that specifies the number of spaces that will be available for transit users at South
Garage adjacent to Wonderland Station. The MBTA has guaranteed the City of Revere access to
additional parking spaces in South Garage, in furtherance of the Waterfront Square development
at Revere Beach, that if exercised would reduce the spaces available for satisfying the SIP
commitment from 612 to 271 or less. MassDOT has provided no details on how the loss of over
three hundred parking spaces would be compensated.
We therefore urge DEP to require MassDOT to continue reporting on this requirement in
SIP status updates until there is full clarity that it has been completed and how it has or will be
satisfied.
Blue Line Platform Lengthening and Station Modernization
MassDOT failed to include the Blue Line Platform Lengthening and Station
Modernization project in its 2012, 2013, and 2014 status reports. CLF disagrees with
MassDOT’s continued claim that its obligations under this SIP commitment are complete by
virtue of implementing six-car train service despite the failure to modernize all Blue Line
stations. The SIP requires both Blue Line platform lengthening and station modernization. See
310 CMR 7.36(2)(g) (“Before December 31, 2008, construction of the following facility shall be
completed and opened to full public use: Blue Line Platform Lengthening and Modernization.”
(emphasis added)). MassDOT’s failure to report on this commitment therefore violates the law.
Furthermore, both components of this project are necessary to achieve the increased ridership
and attendant improved air quality required under the Clean Air Act through the SIP. Increased
ridership is a function of available capacity, access, and attractiveness of service. Modernization
of old, inaccessible, uncomfortable, and otherwise non-user friendly stations and facilities leads
to increased ridership and thus to improved air quality.3
The failure to modernize all Blue Line stations is a continuing violation of the SIP, which
required that Blue Line station modernization be completed by December 31, 2008. As of
October of 2014, the following stations have been modernized: Aquarium, Beachmont, Revere
Beach, Suffolk Downs, Wood Island, Wonderland, Maverick, State, and Orient Heights. The
difference in appearance of the stations that have been completed speaks volumes for the
importance of this requirement.
3
See, e.g., Stacey Falzarano, Richard Hazlett, and Thomas Adler, Quantifying the Value of Transit Station and
Access Improvements for Chicago’s Rapid Transit System (Transportation Research Board Paper No. 01-2987, Jan.
2001).
5
SIP 2014 - Page 98
We are pleased that construction at the Government Center station is in progress. The
delays in modernizing the Government Center and Bowdoin Blue Line stations are significant
and the reasons for them largely unspecified. DEP should therefore require continued status
update reports and interim offset projects or measures to compensate for the delay. MassDOT,
in turn, should make every effort to hasten the completion of this overdue commitment.
CLF remains pleased that all work has been completed to accommodate six-car trains and
that eighty-two new Blue Line vehicles have been in service since September 15, 2008. This is a
major achievement. The increased capacity on the Blue Line is already relieving overcrowding
and improving quality of service for riders. When coupled with full modernization of the Blue
Line, CLF is confident that even more riders will be attracted to the service and this increased
capacity will be well-utilized.
Red Line/Blue Line Connector
Since the last annual SIP status report, DEP approved MassDOT’s request to revise 310
CMR 7.36 to remove the requirement for MassDOT to complete the design of the Red Line/Blue
Line Connector (“Connector”). CLF opposed this amendment due to the reasons repeated below.
Since such a revision to the SIP has to be approved by the USEPA before it goes into effect, CLF
appreciates that MassDOT is continuing to report on this SIP requirement. CLF hereby requests
to be notified when and if the Commonwealth seeks approval of this amendment from the
USEPA.
The Commonwealth included in its 2008 revised SIP the design of the Connector,
recognizing and relying on the associated air quality benefits. Three years ago, only three years
after the revised SIP was approved, MassDOT denied that the same project has any merit and
sought to remove it from the SIP claiming that it does not help the state meet national ambient air
quality standards. In its request to DEP, MassDOT reasoned that there are no air quality benefits
associated with the design of a transit project, calling it a “purely procedural requirement,” which
begs the question why the Commonwealth would have included the Connector in the revised SIP
in the first instance. In any event, the Commonwealth should be precluded from arguing now
that the design of a transit project has no calculable air quality benefits.
Moreover, there can be no dispute that there are air quality benefits associated with
designing a transit project. For a transit project to be constructed, it has to be designed first.
Frequently, funding becomes available for a transit project only after it has been designed. As a
result, air quality benefits can be calculated by applying a discounted percentage of those the
constructed project would produce. This percentage can take the estimated likelihood of
construction, at the time of the inclusion in the SIP, into consideration. In 2006, the
Commonwealth estimated that the Connector would reduce emissions of carbon monoxide by
156 kilograms, nitrogen oxides by 4 kilograms, and volatile organic compounds by 9 kilograms
6
SIP 2014 - Page 99
per day. See DEIR, Appendix E, at 3-16 and Central Transportation Planning Staff (“CTPS”),
“Description of Modeling Assumptions and Analysis Methodology for the State Implementation
Plan Transit Commitment Projects Current and Proposed Substitutions,” December 28, 2006,
revised March 15, 2007 (“2006 SIP Analysis”). Even if discounted by ninety percent, the design
of the Connector would still provide emission reductions of 15.6 kilograms for carbon monoxide,
0.4 kilograms for nitrogen oxides, and 0.9 kilograms for volatile organic compounds per day.
The fact that these air quality benefits from the Connector were previously not included
in the air quality model for the revised SIP does not make the project any less of an obligation.
The EPA approved the revised SIP expecting that the estimate for the revised SIP is leaving the
Commonwealth some room for error—the Connector helped to create that necessary buffer.
Thus, it is not permissible for the Commonwealth to simply remove that project now. Despite
MassDOT’s grim prognosis of the availability of federal funding, increasingly only projects that
are shovel-ready are eligible to apply when federal funding opportunities arise. Thus designing a
transit project, more than anything else, raises its chances of ever being built.
It is also worthy to note that, in an attempt to justify its request to simply be relieved from
an important SIP requirement, although only a few years have passed, MassDOT three years ago
for the first time claimed that the cost of designing the Connector has gone up significantly. See
MassDOT Request to Amend Transit System Improvement Regulations dated July 1, 2011
(“Request”) at 3. MassDOT explained that the design costs, which are typically ten percent of
the total construction costs, have increased because the ultimate construction costs of the project
were estimated to “far outstrip” the cost projections in place at the time that the SIP regulation
was promulgated. Id. MassDOT listed a number of factors that may have contributed to an
increase in the estimated cost of the Connector. See id. at 3-4. Among those, MassDOT
admitted to budgeting a much more conservative contingency for the most recent cost estimate,
but failed to disclose that it also included a higher inflation rate. Likewise, MassDOT did not
explain that it used less favorable assumptions to estimate the cost of the Connector than any
other transit project it currently is planning. But without markups, the raw-cost estimate for
construction of the Red Line/Blue Line Connector is about $336 million rather than the $748
million figure MassDOT relied upon to support its request. See Red Line/Blue Line Connector
Project 10% Design Cost Estimate, Basis of Estimate, at 1. At the time of the SIP revision, in
July of 2008, the Commonwealth’s estimate was $290 million for construction of the project.
Specifically, the total cost estimated for the Connector included a forty percent
contingency (up from a twenty percent contingency applied in earlier planning stages of this
project) and an inflation rate of 4.2% (although construction cost changes currently are at two
percent or under as is general inflation, and inflation is not expected to increase significantly any
time soon). To make matters worse, these add-ons are not applied equally to every project
MassDOT is planning. As a comparison, for the ongoing South Coast Rail Project, MassDOT
applied a lower contingency (31.70% instead of 40%), a lower inflation rate (3.25% instead of
7
SIP2014- Page 100
4.20%), and a lower design cost estimate (13.44% of present construction cost not including the
contingency instead of 14% of present construction cost plus the contingency which translates
into 19.6% without the contingency). See South Coast Rail, Alternative Description Technical
Report at 4-53 (September 2009). Thus, a careful review of MassDOT’s numbers reveal that the
“dramatic increase” in project costs it describes in its letter is also a result of the application of a
particularly and deliberately conservative budgeting approach for the Red Line/Blue Line
Connector.
Amending the SIP would relieve the Commonwealth from an obligation to design a
critical transit project that has great potential to help Massachusetts comply with the NAAQS
without proposing any other project to take its place. Any concerns with the lack of immediate
funding for this project could be addressed by either substituting the project or amending the SIP
to provide for a deadline extension.
Conclusion
The continued projected delays and the insufficient interim offset measures for the Green
Line Extension, the delayed construction of one new station on the Fairmount Line, the failure to
report on the 1,000 additional park and ride parking spaces serving commuter transit facilities,
and the continued delay of the Blue Line Platform Lengthening and Modernization raise serious
concerns regarding the lawfulness of MassDOT’s activities and its compliance with the SIP.
DEP must therefore provide greater oversight and order MassDOT to comply with all the
requirements of the SIP and MassDOT must allocate all needed funding and take all necessary
steps to complete the SIP commitments as quickly as possible.
Thank you for the opportunity to comment.
Sincerely,
Rafael Mares
Senior Attorney
cc
Sreelatha Allam
MassDOT
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston, Massachusetts 02116
8
Jerome Grafe
MassDEP
Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
SIP 2014 - Page 101
elf
conservation law foundation
9
SIP2014- Page 102
October 6, 2014
David W. Cash
Commissioner
Department of Environmental Protection
One Winter Street
Boston, MA 02108
RE: MassDOT Petition to Delay Green Line Extension Project
Dear Commissioner Cash:
The Conservation Law Foundation (CLF) has reviewed the Petition to Delay (Petition)
dated July 22, 2014, that the Massachusetts Department of Transportation (MassDOT) submitted
to the Department of Environmental Protection (DEP or the Department). In its Petition,
MassDOT requests to delay the Green Line Extension (GLX) Project, a State Implementation
Plan (SIP) requirement. We write to make you aware of the fact that one of the offset measures
proposed for the GLX Project does not meet the SIP’s requirements and therefore does not
qualify as such, and that the emissions reductions for another measure were inadvertently
overestimated and cannot be applied to the whole time period of the delay. As a result, the set of
proposed measures does not meet the emission reductions that would have been in place due to
the GLX Project by December 31, 2014. The baseline applied to determining the amount of
emission reductions required in the first place is also too low because it does not include the
complete extension of the Green Line as required by the SIP. We therefore respectfully request
that you deny the Petition pursuant to 310 CMR 7.36(4)(c) and require MassDOT to resubmit a
petition to delay with adequate interim offset projects and measures without delay.
Measures Proposed
MassDOT has proposed additional off-peak bus service along existing routes serving the
GLX corridor as well as a 20% increase in off-peak Green Line service to Lechmere Station.
Additionally, MassDOT has proposed to purchase 142 new hybrid electric vehicles for The
RIDE. Finally, MassDOT seeks to achieve significant portion of the air quality benefits required
during the delay of the GLX through park and ride spaces at the Salem and Beverly intermodal
facilities. While all of these measures are beneficial transit projects, they do not all meet the
requirements for interim offset projects and measures as defined by the SIP.
Parking Garages
MassDOT is seeking to count park and ride spaces at intermodal parking garages in the
downtowns of Beverly and Salem as interim offset measures to make up for the delay of the
GLX. Specifically, according to the Petition, MassDOT seeks to count 378 parking spaces from
SIP 2014 - Page 103
the recently constructed Beverly garage and 374 spaces from the Salem garage.1 MassDOT can
meet the SIP requirement to put in place interim offset projects or measures by implementing
projects or measures “that are not otherwise required by any contractual or other legal
obligation, state or federal law or regulation, including without limitation 310 CMR 7.36 and
310 CMR 7.38, or by any state or federal enforcement action.” 310 CMR 7.36(4)(b) (emphasis
added).
Both of the parking facilities, however, were already long under contract with
construction companies at the time they were proposed as interim offset projects and measures
for the GLX. On September 12, 2012, the MassDOT Board of Directors approved a $21.7
million contract with Suffolk Construction Company for the Beverly parking facility (MBTA
Contract No. CMR-62 entitled “Beverly Depot Parking Garage, Beverly, Massachusetts).2 Only
a few months later, on December 5, 2012, the MassDOT Board of Directors also voted
unanimously to approve a $32 million contract with Consigli Construction Company to build the
Salem garage (MBTA Contract No. CMR-92, entitled “Salem Station Improvements and Parking
Garage, Salem, Massachusetts”).3 Pursuant to the contract, the Beverly parking facility was
constructed and opened up only eleven days after the Petition was filed with DEP on August 2,
2014. Likewise, pursuant to its contract, the Salem garage will be completed shortly by October
10, 2014, or a little later this month, possibly even before the completion of this comment period.
As a result, neither the Beverly nor Salem park and ride spaces are eligible to be counted as an
interim offset project or measure for the delay of the GLX.
The unambiguous purpose of this SIP provision is to ensure that all interim offset projects
and measures provide additional air quality improvements as mitigation during the period of
delay of one of the transit improvement projects required by 310 CMR 7.36 in order to make up
for the gains promised but postponed. The regulation recognizes that at any given time the
Commonwealth may have many transportation projects and measures in the works regardless of
any delay of a SIP project, but that such prior improvements cannot provide any additional air
quality benefits and should therefore not count. The regulation therefore includes a long list of
permutations of possible prior obligations that disqualify a proposed project or measure.
Contracts signed prior to approval of a proposed interim offset measure, such as those with
construction companies, clearly disqualify a proposed measure, even if they contain standard
language that allows one party to cancel the contract for a penalty. Otherwise, the drafters of the
1
The technical memorandum associated with the Petition assumes a utilization rate of 80%, but it does not describe
how the MBTA will be able to ensure that these parking spaces are reserved for transit riders. Without such
reservation, any emission reductions are speculative.
2
See Meeting Notes for September 12, 2012, pp. 15-17 at
www.mbta.com%2Fuploadedfiles%2FAbout_the_T%2FBoard_Meetings%2FMassDOT%2520Minutes%25209%25
2012%25202012.docx
3
See MassDOT Board Meeting Notes for December 5, 2012, pp.10-11 at
https://www.massdot.state.ma.us/Portals/0/docs/infoCenter/boards_committees/boardDirectors/minutes_120512.pdf
2
SIP 2014 - Page 104
regulation would have seen no need to specifically call out contractual obligations in addition to
legal obligations, laws, regulations, and enforcement actions in the SIP.
Practically speaking, the requirement that no prior contractual obligation be in place prior
to approval of an interim offset project or measure by DEP does in no way preclude counting
parking garages or other infrastructure projects. As a matter of fact, the SIP specifically
mentions them as an option. 310 CMR 7.36(4)(b). In this instance, for example, MassDOT had
plenty of time to build a parking garage near a transit location as an interim offset measure since
it was aware of the delay of the GLX since at least 2011. The fact that MassDOT nevertheless
did not propose the garages as an interim offset measure until both garages were close to
completed only further underlines the reality that they were not intended as new projects
mitigating the delay of the GLX, but rather were exactly the type of existing projects that the SIP
disqualifies.
The RIDE Vehicles
MassDOT has also proposed to replace 142 The RIDE vehicles. The RIDE currently
uses Ford Crown Victoria model cars for part of its fleet. These vehicles will be replaced with
142 Ford Fusion hybrid vehicles. The vehicles currently in use are already beyond their useful
life and would have been replaced in any case within two to three years by the MBTA’s own
admission.4 The delay of the GLX, however, is expected to last four to five years. As a result,
this proposed interim offset measure will have to be replaced after the first two to three years,
since the air quality benefits would have existed without it after that time period.5
In addition, the technical memorandum associated with the Petition applies an incorrect
miles per gallon rate for the emission reductions estimate for the project. It wrongly assumes
that a hybrid Ford Fusion consumes 47 miles per gallon. See p. 6 of the technical memorandum.
However, according to the United States Environmental Protection Agency and the
manufacturer, a hybrid Ford Fusion has a city rate (which for an electric hybrid is higher than
highway) of 44 miles per gallon and a combined city/highway rate of 42 miles per gallon.6 This
lower rate will reduce the emission reductions of the measure somewhat during the time period
4
Andrew Brennan, MBTA’s Director of Environmental Affairs, stated that these vehicles will be replaced regardless
in 2016. Statement at meeting with GLX supporters on July 24, 2014. See also p. 54 for MBTA CIP for (FY15
through FY19), which has $7 million budgeted for The RIDE vehicle procurement in FY18, which begins on July 1,
2017.
5
It is important to note here that purchasing non-hybrid vehicles at that time would not be cost effective for the
MBTA. If one compares the combined city/highway rating of 26 mpg for a regular Ford Fusion to 42 mpg
combined rating for the hybrid Ford Fusion and considers the cost difference of under $6,000, i.e., $21,510 (MSRP
for regular SE 2 liter automatic, four-wheel drive) v. $27,280 (MSRP for hybrid SE automatic four-wheel drive), the
hybrid vehicle will be cheaper after only about 20,000 miles driven. It can be reasonably expected that The RIDE
vehicles will be used for many more miles.
6
See, e.g., http://www.fueleconomy.gov/feg/Find.do?action=sbs&id=34312&id=34088
3
SIP 2014 - Page 105
of the delay this project is available. The air quality benefits from this measure should therefore
be recalculated7 and only applied to the first two to three years of the GLX delay.8
GLX Emissions Budget
Before MassDOT identified interim offset projects and measures for the delay, the
emissions reductions expected from the GLX were estimated for 2015, since the GLX is required
to be in place by December 31, 2014 pursuant to the SIP. On information and belief, as a
baseline, the Central Transportation Planning Staff (CTPS) used the Green Line Extension to
College Avenue (and Union Square), rather than the GLX as required to Medford Hillside (and
Union Square). The appropriate benchmark for determining whether the air quality benefits of
the interim emission reduction offset projects and measures meet this required standard,
however, is the expected emissions reduction from the complete SIP project, which includes the
extension of the Green Line to Union Square and Medford Hillside, not just the shortened
extension to College Avenue. To comply with the SIP, MassDOT must construct an extension
of the Green Line “from Lechmere Station to Medford Hillside” by December 31, 2014. See 310
C.M.R. 7.36(2)(j)1. The Green Line Extension Project to College Avenue alone does not
comply with the SIP since Medford Hillside’s well-documented historical boundaries do not
include the location of the proposed terminus at the intersection of College Avenue and Boston
Avenue.9 The Petition should therefore be revised to include the full extension to Route 16 as a
baseline.
Conclusion
MassDOT has failed to propose sufficient interim offset projects and measures consistent
with the SIP. One of the proposed measures, the additional park and ride spaces in Beverly and
Salem, is not in compliance with the SIP requirement that such projects or measures cannot
already be under an existing contractual obligation. It will therefore have to be replaced
completely. This measure was expected to produce almost half of the air quality benefits of the
set of measures currently proposed by MassDOT. A second proposed interim offset measure, the
purchase of new The RIDE vehicles, will result in lower emission reductions than estimated due
7
We appreciate that CTPS apparently is already in the process of recalculating the air quality benefits of this
measure based on CLF’s recommendation.
8
In order to achieve any emission reductions from this project, it is critical that the old vehicles are removed from
service. This issue was highlighted in a recent Office of the Inspector General report, MassDOT’s Fleet Operations
(July 2014). See pages 14-15 at http://www.mass.gov/ig/publications/reports-andrecommendations/2014/massachusetts-department-of-transportations-fleet-vehicle-operations-july-2014.pdf.
9
For a more detailed explanation of this issue, please see CLF’s comments on the Draft and Final Environmental
Impact reports for the project available at
http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.
pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf
respectively.
4
SIP2014- Page 106
to the application of an incorrect miles per gallon rate in the calculation of its air quality benefits.
Moreover, this measure can only be applied for the first two to three years of the GLX Project
delay, the remaining time the old vehicles would have still been in use.
Therefore, and for the all the reasons stated above, we respectfully request that DEP deny
MassDOT’s Petition pursuant to 310 CMR 7.36(4)(c). Instead, in addition to the extra off-peak
service on the Green Line and five selected bus routes, MassDOT should be required to propose
new interim offset projects or measures without delay. Such projects or measures will need to be
in full compliance with the SIP and meet or exceed the emission reductions expected from the
complete Green Line Extension to Union Square and Medford Hillside.
Sincerely,
Rafael Mares
Senior Attorney
cc
Sreelatha Allam
Massachusetts Department of Transportation
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston, Massachusetts 02116
Jerome Grafe
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
5
SIP2014- Page 107
HOUSE OF REPRESENTATIVES STATE
HOUSE. BOSTON, MA 02133-1054
CARLO BASILE
REPRESENTATIVE
Chair
Veterans and Federal Affairs
1ST SUFFOLK DISTRICT
EAST BOSTON
ROOM 174, STATE HOUSE
TEL: (617) 722-2877
FAX: (617) 626-0736
October 14,2014
Mr. David W. Cash, Commissioner
Department of Enviromnental Protection
One Winter Street,
Boston, MA 02108
Re: State Implementation Plan-Transit Commitments 2014 Status Report
Dear Commissioner Cash:
East Boston strongly opposes the request ofMassDOT to be relieved of the long standing
requirement to complete the design of the Blue Line-Red Line Connector which was initially
developed as a major environmental remediation obligation of the Big Dig.
Of the transit commitments included in the 1990 MOU none was more important than the
proposed direct connection between the MBTA Blue Line and Red Line at Charles Station. This
project would greatly enhance transit access to the Massachusetts General Hospital for all of the
Blue Line communities, including East Boston. Residents of our community have to walk half a
mile from the Bowdoin Street Station to reach the Mass General Hospital. The Blue Line-Red
Line connection would also provide significantly improved transit service between East Boston
and the many important high tech destinations in Cambridge, such as Kendall Square and
beyond.
The Blue Line-Red Line connection would also provide to the entire MBTA system in the form
of congestion relief for both the Park Street and Govermnent Center Stations which must
accommodate Blue Line passengers bound for Mass General Hospital and Cambridge. These
passengers now must change at Govermnent Center, take the Green Line to Park Street and then
board the Red Line. By bypassing both of these congested stations, the Blue Line-Red Line
connection would benefit the entire MBTA system.
SIP2014- Page 108
Specifically, East Boston requests that DEP rescind its decision of October 8, 2013 that approved
MassDOT's request to eliminate the Blue Line-Red Line Connector design as an obligation, and to
immediately inform the U.S. Environmental Protection Agency of its reversal oflast year's vote.
Thank you,
CARLO BASILE
State Representative
CC: Speaker Robert DeLeo
Senator Edward Markey
Senator Elizabeth Warren
Congresswoman Katherine Clark
SIP2014- Page 109
33 Broad Street I Suite 300 I Boston, MA 02109
Tel: 617-502-6240 I Fax: 617-502-6236
WWW .ABETIERCITY.ORG
BOARD MEMBERS
Mrchael Cantalupa ·
(CI1atnnal1}
Edward Ladd •
{Vtce Chatr)
Theodore Oatrs ·
{Vtce Clla1r)
Kathryn West •
(Vice Cha11
Susan Woll-.off •
(Treasurer)
October I4, 20I4
Sreelatha Allam
MassDOT Office of Transportation Planning
I 0 Park Plaza, Room 4I50
Boston, MA 02II6
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Via e-mail: sreelatha.allam@dot.state.ma.us
Jerome Grafe
MassDEP Bureau of Waste Prevention
One Winter Street
Boston, MA 020 I8
jerome.grafe@state.me.us
Re: MassDOT Transit System Improvements: SIP - 20I4 Annual Status Report and Petition to
Delay the Green Line Extension Project
Dear Ms. Allam and Mr. Grafe:
t
We are pleased to comment on the Transit System Improvements State Implementation Plan
Ann ual Status Report and the Green Line Extension Petition to Delay.
A Better City has consistently supported the need to complete the Red Line/Blue Line Connector.
The proposed extension of the Blue Line to connect to the Red Line at Charles Station offers some
obvious benefits for users of the transit system by relieving congestion in the central
subway and by providing better connectivity between the Red Line and Blue Line corridors,
particularly between Cambridge and the northwest and the North Shore along the Blue Line. This
connection would take advantage of the available capacity of the Blue Line while reducing
congestion at the Park Street and Government Center stations.
Advancing the planning and design of worthwhile transit projects such as this while awaiting a
commitment of funds for the next major step is a prudent strategy that we hope that the state will
reinstate for this project and adopt for other important projects.
Revision to the State Implementation Plan that would eliminate the requirement to complete Final
Design for this project has been recommended by MassDOT, but approval of this revision is still
pending at the U.S. Environmental Protection Agency. We urge MassDOT and the Department
of Environmental Protection reconsider its decision to approve this revision and withdraw its
recommendation to the EPA.
Regarding the Green Line Extension to Somerville and Medford, we understand and agree with the
reasons for delay in the construction and operation of this important project. And we concur with
the importance of implementing interim mitigation measures for the period of delay between the
current SIP implementation deadline of December 3I, 20I4 until completion and operation of the
project, now estimated for final completion of Phase 4 at some point in 2020 or beyond.
MassDOT and the MBTA has selected and analyzed three interim offset measures: I) additional
off-peak service on existing bus routes 80, 88, 9I, 94, and 96 as well as a 20% increase in off
peak Green Line service to Lechmere; 2) purchase of I42 new hybrid electric vehicles for The
Ride; and 3) additional Park and Ride spaces at the Salem and Beverly Intermodal Facilities.
These measures are estimated to produce a daily reduction of over 47,000 vehicle miles traveled,
which exceeds the estimated daily VMT reduction for operations of the Green Line Extension
during its planned but delayed initial operations starting in 20I5.
While this analysis is impressive, the mitigation measures are not required to be implemented in
the Green Line Extension Corridor as only measure (1) above is so located. We would like to
suggest an alternate option for analysis that would include increased, more frequent bus service in
TRANSPORTATION • lAND DEVELOPMENT • ENVIRONMENT
SIP 2014- Page 110
Cambridge and Somerville that would connect service from Lechmere Station on the Green Line
to the Orange Line at Sullivan Square and the Red Line at Kendall Square as well as points in
between. The travel time and ridership of this service could be enhanced by completion of the long
discussed viaduct between the Inner Belt area of Somerville to Lechmere Station. The benefits of
this service could be further enhanced with its extension beyond Kendall to Longwood and
Ruggles Station.
We urge you to evaluate and consider implementation of these improvements as an alternative to
those suggested in the Green Line Extension Petition to Delay.
Richard A Dimino
President and CEO
6143/1 siplto14
SIP 2014- Page 111
HOUSE OF REPRESENTATIVES
STATE HOUSE, BOSTON 02133-1008
ROBERT A. DELEO
Speaker
ROOM 356
OFFICE PHONE
(617) 722-2500
October 9, 2014
The Honorable David W. Cash, Commissioner
Department of Environmental Protection
Commonwealth of Massachusetts
1 Winter Street -2nd Floor
Boston, Massachusetts 02108
Dear Mr. Commissioner Cash:
I write to request the Department of Environmental Protection (DEP) to reconsider the requirement
that the Department ofTranspmtation (MassDOT) complete the design of the Blue Line-Red Line Connector.
Last year DEP approved MassDOT's request to remove its obligation to complete this project, and I believe it is
important that DEP inform the U.S. Environmental Protection Agency of its revised position. As you know,
the Blue Line-Red Line Connection is vital to many of my constituents and our neighbors on the North Shore.
The justifications for this cmmection project are numerous, but I believe the most telling is that
relative to access to medical care. As you may know, the number of hospital and primary care centers on the
North Shore has dropped dramatically in recent years. This situation has left an aging population in my district
of Winthrop and Revere with few medical options. By cmmecting the Blue and Red Lines, we would provide
these citizens with easy access to Massachusetts General Hospital and with points northwest along the Red
Line. The Blue Line-Red Line Connection would also provide greatly enhanced public transportation service
for Winthrop, Revere and other north shore communities to Cambridge and Kendall Square.
Finally, I believe it is important to state that I am fully supportive of the proposed connection
project because Ibelieve it is a missing link in our transit system, creating connectivity between all of the rapid
transit lines. In addition, the Blue-Red Connector will greatly improve access for Blue Line tiders to the entire
MBTA system.
Thank you for your consideration of my thoughts on this matter. As always, please contact me if I can
offer any additional infom1atimo1;,.,assistance.
SIP2014- Page 112
CITY
OF CAMBRIDGE
Community Development Department
BRIAN P. MURPHY
Assistant City Manager for
Community Development
October 14, 2014
David W. Cash
Commissioner
Department of Environmental Protection
One Winter Street Boston, MA 02108
RE: MassDOT Petition to Delay Green Line Extension Project
Dear Commissioner Cash:
The City of Cambridge is pleased to offer comments on the Petition to Delay dated July
22, 2014, submitted by the Massachusetts Department of Transportation (MassDOT) to
the Department of Environmental Protection. The City asks that the petition to delay
the Green Line Extension (GLX) be denied on the basis that the list of projects offered by
the state to mitigate the air quality benefits of the proposed delay do not meet the
State Implementation Plan (SIP) requirements. We ask that MassDOT be required to
submit a revised list of projects that includes a new contract bus service connecting
Sullivan Square, Lechmere, Kendall Square and Longwood Medical Areas that will
provide significant new transit access in this important corridor which would have
experienced air quality benefits had the Green Line project not been delayed and that
plays a vital transportation and economic development role in the state.
Regarding the list of measures proposed by MassDOT we have noted that, although
worthwhile, some ofthe project benefits should not be counted toward the emissions
benefits required under the SIP. Based on information that we have been provided,
both the Salem and Beverly park and ride spaces were under contract to be completed
prior to being proposed as interim off-set measure, and therefore should not be
counted as part of this list. MassDOT has also included the replacement of 142 RIDE
vehicles with Ford Fusion hybrids. These vehicles were already beyond their useful life
and slated to be replaced in the next year or two. Therefore, only the portion of the air
quality benefit within the next year or two may be included in the list.
344 Broadway
Cambridge, MA 02139
Voice: 617 349-4600
Fax: 617 349-4669
TTY: 617 349-4621
www.cambridgema.gov
Given that the proposed projects by MassDOT would not fulfill the air quality benefits
required by the GLX under the SIP,Cambridge would again like to propose that
MassDOT and the MBTA consider establishing a new service connecting Sullivan Square,
Lechmere, Kendall Square and the Longwood Medical Area. This service could be
contracted to a private service provider- given current limitations on the MBTA's ability
to provide additional peak-hour service- and begin, even modestly, by the end of this
year as required by the SIP. Such a service would fill a gap in current service by
connecting key transportation and economic centers and providing options for
sustainable travel.
Given the short time frame remaining for implementing new projects to meet the SIP
deadline MassDOT will be required to quickly submit substitution projects for the park
SIP 2014- Page 113
and ride parking spaces and the first year or two of the air quality benefits of the new
RIDE vehicles. We hope that MassDOT seriously considers our proposal for new bus
service connecting Sullivan Square to Longwood Medical area via Lechmere and Kendall
Square, and that DEP deny this petition as presented. Thank you again for the
opportunity to comment on this significant project. If you have any questions on this
matter, please contact Bill Deignan at 617-349-4632 or wdeignan@cambridgema.gov.
Sincerely,
Director of Environmental and Transportation Planning
Page 2 of2
SIP2014- Page 114
Massachusetts Port Authority
One Harborside Drive
East Boston, MA 02128-2909
Telephone (617) 568-5000
www.massport.com
October 14'", 2014
Ms. Sreelatha Allam
MassDOT
Office of Transportation Planning, Room 4150,
Ten Park Plaza
Boston, :NIA 02216
Mr. Jerome Grafe
MassDEP
Bureau ofWaste Prevention
One Winter Street
Boston, MA 02018
RE: Annual Update and Status Report for Transit Projects
Dear Ms. Allam and Mr. Grafe:
I am writing regarding the Massachusetts Department of Transportation (MassD01) annual
update and status report for transit projects required by 310 CMR 7.36 (2) (£) through G) and on the
petition to delay the Green Line Extension Project pursuant to 310 CMR 7.36(4). The MassDOT
submitted the update, status report and petition to MassDEP on July 2, 2014.
The proposed Red Line-Blue Line Connector would be a significant addition to the NIBTA
Rapid Transit System. This project would link the only two lines that do not currently intersect
within the rapid transit system. As such, the pro ject would setve to supplement access to and from
residences and employment centers in East Boston. In the long term, this connection would also
setve to relieve demands on tl1e Silver Line set-vices to East Boston and Chelsea. Given that tl1e
EPA has not taken any action to waive the commitment, MassDOT might consider completing the
design of tl1e project while investigating innovative finance options for its implementation.
With respect to the Green Line Extension to Sometville and Medford, I commend
MassDOT for advancing tl1e implementation of tl1is important addition to the regional transit
network. The project will result in significant improvements in travel options and air quality. The
request to delay the Green Line Extension is not sutprising in light of the project's many design,
geo-technical, and finance challenges. I urge tl1at the project proceed so benefits can be achieved as
soon as possible.
Thank you for the opportunity to comment on tl1ese projects. Please let me know if you
have any questions.
Sincerely,
Thomas P. Glynn
Chief Executive Officer
SlP 2014 - Page 115
From:
To:
Subject:
Date:
Tom Lamar
Allam, Sreelatha (DOT); jerome.grafe@massmail.state.ma.us
Comments- SIP, GLX Petition to Delay, Interim Offsets
Tuesday, October 14, 2014 3:38:29 PM
To Sreelatha Allam and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan
(SIP) Transit Commitments report
(http://www.massdot.state.ma.us/Portals/17/docs/sip/SIPUpdate9-14.pdf ). As
someone who lives near the elevated I-93 viaduct in Somerville, as well as the cutthrough traffic in Somerville induced by the Central Artery/Tunnel project, I am
pleased to see that the Green Line Extension (GLX) project finally moving forwards.
However, I have comments and concerns about the proposed interim offset
measures.
I strongly support the proposed off-peak increases in Green Line and bus
service, and would welcome further increases in off-peak bus service along the
GLX corridor. In addition to providing interim air-quality benefits, this will help
"prime" the corridor for when the GLX finally arrives.
I am strongly opposed to counting the addition of 374 Park and Ride spaces in
Salem and 378 Park and Ride spaces in Beverly towards the GLX interim
offsets for several reasons.
The parking garages were already under contract before the GLX interim
offsets were proposed, so they should be ineligible.
The primary highway route from Salem and Beverly into Boston is US-1,
not I-93, and US-1 is further away from the GLX route. Therefore, any
car traffic diverted to transit by this project will result in minimal benefits
in air quality for GLX communities.
Thus far, the Beverly garage has only had a 20% utilization rate,
underperforming expectations (
http://www.salemnews.com/news/local_news/article_b4a2f117-15655d59-8f59-3c542bacbfdf.html?mode=jqm ). If this garage is counted
toward GLX interim mitigation, all relevant air quality calculations should
be based off of actual utilization data, not overly optimistic projections.
The Salem News article above suggests that many of the users of the
garage are not new transit users, but rather already used transit and
parked at other stations or private lots, or considered walking. DEP
should ensure that the projects are actually diverting commuters who
would have otherwise driven, not just "cannibalizing" existing transit
ridership.
Instead of the parking garages, I urge you to pursue any of the following interim
offsets:
MassDOT/MBTA to complete the design and full construction of the Community
Path Extension (CPX). I appreciate that the CPX is already intended to be
completed in sync with the GLX; however, I would prefer to see it formally
included in the SIP.
This will ensure that the CPX is actually completed.
According to a MAPC study, the CPX will "provide emissions reductions
equivalent to removing 552 cars from the road per year".
SIP 2014 - Page 116
Even though the CPX will not be fully constructed for several years, it will
still reduce emissions somewhat as the early phases open.
MassDOT/MBTA should design and construct a path spur from the CPX to Twin
Cities Plaza.
Accelerate other regional shared use paths, such as the Mystic River Paths.
Subsidize MBTA passes, and Hubway memberships or Hubway expansions, in
the GLX corridor communities.
Thank you for your consideration.
Tom Lamar
66 Adams St, Somerville MA 02145
SIP 2014 - Page 117
2014 SIP Public Meeting Summary
State Implementation Plan Public Meeting Massachusetts
Department of Environmental Protection and the
Massachusetts Department of Transportation
October 2, 2014 – 2:00 PM to 3:30 PM
October 6, 2014 – 5:00 PM to 6:30 PM
Massachusetts Department of Environmental Protection
One Winter Street Washington Street
Conference Center Boston, MA
Attendees at October 2 Session:
Nancy Farrell, Moderator
David Mohler, Deputy Secretary for Policy, Massachusetts Department of Transportation
(MassDOT)
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection (DEP)
Stephen Woelfel, Director of Strategic Planning, MassDOT
Sreelatha Allam, MassDOT Office of Transportation Planning
Jerome Grafe, DEP
Maureen Kelly, Central Transportation Planning Staff (CTPS)
Rafael Mares, Conservation Law Foundation (CLF)
Anne McGahan, CTPS
Sharon Webber, Director of Transportation Programs, DEP
Wig Zamore, Somerville Transportation Equity Partnership, Mystic View Task Force,
and Somerville resident
Attendees at October 6 Session:
Nancy Farrell, Moderator
David Mohler, Deputy Secretary for Policy, Massachusetts Department of Transportation
(MassDOT)
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection (DEP)
Sreelatha Allam, MassDOT Office of Transportation Planning
Christine Kirby, DEP
Jerome Graf, DEP
Sharon Weber, DEP
Natalie Raffol, CTPS
Fred Salvucci
John Vitagliano, Winthrop Resident
Lynn Weissman, Friends of the Community Path
1
1
8
SIP 2014 - Page 118
2014 SIP Public Meeting Summary
Introduction
Moderator Nancy Farrell opened the annual meeting on the 2014 annual report on the
State Implementation Plan (SIP). Nancy Seidman, Assistant Commissioner, Bureau of
Waste Prevention, DEP, provided background on the overall regulatory context of the
SIP and public process requirements.
This meeting addresses two documents, dated July 22, 2014, that were submitted by
MassDOT to DEP: the annual update and status report on the SIP and a petition to delay
the Green Line Extension project. These documents were submitted pursuant to
subsection (7) and subsection (4) of 310 CMR 7.36, the Transit System Improvements
regulation. Revisions to this regulation were effective December 2006. The U.S.
Environmental Protection Agency (EPA) approved the revised regulation into the SIP in
July 2008.
Under subsection (7) of the regulation MassDOT is required to submit an annual update
and status report on all uncompleted SIP requirements and submit that report to DEP.
DEP is then required to hold a public meeting and take public comments. Within 120
days of this meeting, MassDOT is required to summarize and respond to all comments.
Within 60 days of MassDOT’s submission and response to comments, DEP is required to
determine whether the public process requirements of the regulation have been met.
Subsection (4) of the regulation addresses project delays and requires interim emission
offset measures of equal or greater air quality benefit during the delay. MassDOT has
petitioned DEP to delay the Green Line Extension project beyond its required completion
date of December 31, 2014. DEP is required to conduct a public review and release a
finding on the petition thereafter, allowing sufficient lead time for MassDOT to
implement interim offset measures.
Written testimony will be accepted until 5:00 PM on October 14, 2014. Written
testimony may be sent to Sreelatha Allam, MassDOT Office of Transportation Planning,
Room 4150, Ten Park Plaza, Boston, MA 02116 or Sreelatha.Allam@state.ma.us; and
Jerome Grafe, DEP, One Winter Street, Boston, MA 02018 or
Jerome.Grafe@state.ma.us.
Ms. Seidman noted that DEP’s certification letter regarding MassDOT’s 2013 SIP report
was issued on March 17, 2014. DEP determined that MassDOT met public process and
annual reporting requirements of the regulation in 2013.
Status Report
David Mohler, Deputy Secretary for Policy, provided a summary of the status of the
outstanding SIP commitments:
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Red Line - Blue Line Connector Project
MassDOT’s petition to remove the requirement to design the Red Line - Blue Line
Connector project has been approved by DEP and is now being reviewed by the EPA for
an amendment to the SIP.
Fairmount Line Improvement Project
MassDOT continues to provide mitigation for delays on the Fairmount Line
Improvement project. A public meeting was held in September regarding the Blue Hill
Avenue Station. MassDOT is moving forward on that portion of the project. The final
design for the new station is expected by March 2015. Construction will begin in the fall
of 2015 and it is anticipated that the station will open in 2017.
Green Line Extension Project
MassDOT has committed to fund the Community Path project as a part of the Green Line
Extension project; the Community Path project is not a mitigation measure.
Phase 1 of the Green Line Extension project is now under construction. Phase 1 includes
the Harvard Street Bridge in Medford and Medford Street Bridge in Somerville, as well
as the demolition of a building at 21 Water Street in Cambridge. The first Construction
Manager/General Contractor (CM/GC) contract was awarded to JF
White/Skanska/Kiewit.
A $118 million contract to purchase 24 new vehicles for the Green Line was approved in
May 2014. The vehicles will be delivered in 2017 and 2018.
MassDOT is anticipating a full funding grant agreement (FFGA) by the end of this
calendar year, which would secure a federal commitment to fund 50% of the project’s
$1.992 billion budget through the New Starts Program. MassDOT is working now with
the Federal Transit Administration to finalize the project’s finance plan and New Starts
application.
MassDOT has filed a petition to delay the Green Line Extension project. MassDOT must
have mitigation measures in place by December 31, 2014, the time that the service on the
new line was supposed to begin. The proposed mitigation measures are to add off-peak
service to bus routes #80, 88, 91, 94, and 96; purchase 142 new hybrid-electric vehicles
for THE RIDE; and provide Park & Ride spaces at the Beverly and Salem garages.
Oral Testimony – October 2 Session
Rafael Mares, Senior Attorney, Conservation Law Foundation
Mr. Mares complemented MassDOT on progress made on the Green Line Extension
Project, including the advancements toward securing New Starts funding and the
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inclusion of the Community Path project. He also expressed that he was pleased that the
fare structure piloted on the Fairmount commuter rail line has been made permanent.
Mr. Mares raised an issue regarding the interim offset measures for the Green Line
Extension project. First, he noted that the fuel economy figure used to calculate the air
quality benefits of the measures should have been 42 miles per gallon (mpg) (as set by
the EPA), rather than 47 mpg. He expressed appreciation that those air quality benefits
are being recalculated now. Secondly, he noted that providing parking spaces at the
Beverly and Salem garages does not qualify as an offset under the SIP regulations
because the provision of those spaces has been a contractual obligation since 2012. As
such, another offset measure should be put in place, he said.
Lastly, he urged MassDOT to continue reporting on the 1,000 New Parking Spaces
requirement to make clear to the public which parking spaces will be counting toward the
requirement. He noted that parking spaces in the new Beverly garage are counting toward
the commitment, and that a possible hotel development near Wonderland Station in
Revere could reduce the number of parking spaces available for transit riders.
The Conservation Law Foundation will also be submitting written testimony.
Wig Zamore, Somerville Transportation Equity Partnership, Mystic View Task Force,
Somerville resident
Mr. Zamore gratefully acknowledged the progress made on the Green Line Extension
project and the Community Path project, noting the environmental benefits that these
projects will produce for the community.
He then commented on the proposed interim offset measures for the Green Line
Extension project. He expressed approval of the purchase of new vehicles for THE RIDE.
He also noted that the addition of bus service may only be effective in providing
environmental benefits if the buses are close to full occupancy. He suggested adding offpeak service on the CT2 bus route as it provides important service to the Longwood
Medical Area, particularly for people who work later shifts in the hospitals.
Another alternative, he suggested, would be to expand the Hubway bike share system
with consideration of synergies with the MBTA’s transit services. He noted that the
Beacon Street/Hampshire Street corridor in Somerville is a particularly busy bicycling
corridor. This would also support MassDOT’s mode shift goal, he noted.
Mr. Zamore then expressed concern about the expansion of the use of diesel-fueled transit
vehicles, such as diesel multiple units (DMUs), to new corridors and densely populated
areas. Diesel emissions, he noted, are the primary source of black carbon in the United
States. He noted that black carbon is a major pollutant of concern relative to climate
change and that it is a carcinogen that causes lung cancer.
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He suggested that as the MBTA replaces its old locomotives with less polluting new
ones, that it give priority to deploying the new locomotives on the Fairmount commuter
rail corridor, particularly because of the environmental justice areas along the corridor
and because of the dense-development that is expected to occur around the new stations.
The Green Line corridor should be the next in priority, he said.
Mr. Zamore complemented the MassDOT staff who have been working on the Green
Line Extension project.
Oral Testimony – October 6 Session
Fred Salvucci
Mr. Salvucci appreciates the moving forward of the Green Line Extension project and
applauded the current administration for advancing the project. Despite this, Mr. Salvucci
expressed concern about completion estimates identified in March. Due to “slippage,” he
believes more mitigation is appropriate.
Mr. Salvucci praised the new The Ride vehicles, but noted that they needed to be
replaced anyway. It is thus inappropriate to credit these improvements towards mitigation
for delays in the Green Line Extension project. Vehicles should always be replaced early,
rather than in later years, he said.
Parking spaces in Salem are also not appropriate to count towards mitigation, he said.
These parking spaces are a separate project, developed in response to the agreement in
1990 between Mr. Salvucci (then state transportation secretary) and Doug Foy (then
president of the Conservation Law Foundation) for various transit improvements to
follow the Central Artery/Tunnel project.
One aspect of mitigation Mr. Salvucci finds appropriate is the CT4 urban bus connection
between Kenmore Square, Kendall Square, Lechmere Station, and Sullivan Square. The
frequency of Green Line trains to Lechmere should also be improved. A slight or great
improvement in frequency and similarly frequent bus service to connect Kenmore
Square, Kendall Square, and Sullivan Square would result in a substantial increase in
ridership, he said. A student of Mr. Salvucci’s did a thesis project on the CT4 bus route,
and with such a projected increase in ridership, Mr. Salvucci feels it has serious potential
for mitigation.
Mr. Salvucci also referenced the private shuttle Easy Ride, which is commissioned by
multiple Kendall Square employers, including MIT. A private shuttle could run from as
far as Central Square to Lechmere, allowing a connection to the commuter rail at North
Station. The CT4 bus could initially be contracted out to Easy Ride so that service would
be on the ground by January 1, 2015. After an initial one to two years to get the service
running and analyze the use, the service can be bid out. This option would get around the
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MBTA’s constraints of limited drivers and vehicles and limited capacity to maintain the
vehicles. Mr. Salvucci recommends that this option be adopted.
Mr. Salvucci then addressed the design of the Green Line Extension. He cited that
MassDOT Secretary Richard Davey agreed with Somerville Mayor Joseph Curtatone to
have the Green Line Extension designed to connect Innerbelt Road over to North Point
Boulevard. This connection requires a bridge, as the Fitchburg commuter rail line is in
the path. This bridge would make service at Lechmere Station and Sullivan Square more
effective. Currently, Lechmere is cut off by McGrath Highway. The bridge would serve
as a mitigation effort until Lechmere is relocated. Mr. Salvucci clarified that the
mitigation should not just include designing the bridge, but building it as part of the
Green Line Extension project. He believes that building the bridge and Green Line as one
project would be most effective, as different contractors would not be in each other’s
way.
Mr. Salvucci noted that community groups have suggested that the proposed extension to
the Community Path be included as part of the project. He believes the project will have
little air quality value, but that if this connection is not built now, it will be very difficult
to build in the future. He also mentioned that two tracks are needed on Grand Junction,
not just one as some in Cambridge argue. Mr. Salvucci believes constructing the path as
well as two tracks in this section now is vital, or else the opportunity will be lost.
Another comment Mr. Salvucci expressed about the Community Path is that it needs to
be lowered to a 25 ft. bridge, rather than 45 ft. bridge, as only serious bikers will be able
to cross at such a steep height.
Regarding the Red Line - Blue Line Connector project, Mr. Salvucci believes that it is a
mistake to drop this project. He also believes the state must commit to build, not just
design the project, as design does not have mitigation value. He urges that the
construction bid be taken for design/build. He sees the project being integrated into the
construction of Longfellow Bridge and with the Mass Eye & Ear garage. This presents an
opportunity to orderly construct all projects.
Mr. Salvucci then cited several reasons as to why this connection is needed:
1. The Silver Line is at full capacity and will worsen as the Innovation District
grows. Logan Airport will increasingly rely on the Blue Line. A report by Mr.
Salvucci’s students showed that the Blue Line is the best way to reach the
airports from all directions, except from the south on the Red Line.
2. Making East Boston one stop away from Charles Street, MGH and Kendall
Square greatly increases the transit-oriented development (TOD) potential in
East Boston. He cited Assembly Square as a TOD model. The connection
would dramatically change the potential for development at Wonderland or
Suffolk Downs.
3. The Blue Line connection can be used as mitigation for the delays in the
Green Line Extension project. The connector will relieve transfer congestion
between Government Center and Park Street.
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4. The Blue Line is the only line operating below capacity, meaning it is the only
one that stands to receive better ridership in the near term if it is properly
connected. This is the best opportunity to reduce greenhouse gas (GHG)
emissions.
Mr. Salvucci then discussed the greater implications of air quality, referencing
agreements made during the Central Artery/Tunnel project. He believes that with new
congestion caused by the development of the Innovation District, more measures for
analyzing air quality must be used, not simply vehicle miles travelled (VMT) or vehicle
hours travelled.
Mr. Salvucci will also submit written comments.
John Vitagliano – Winthrop Resident
Mr. Vitagliano supports the Red Line - Blue Line Connector project and opposes the
Green Line Extension project. He first expressed concerned regarding the official notice
of the hearing, stating that there should have been a reference to the proposed removal of
the Red Line/Blue Line Connector project in the notice. He believes more people from
the community would have come to the meeting if they were aware this project was being
discussed.
Mr. Vitagliano’s main argument was that the Red Line – Blue Line Connector would
open up the Cambridge job market to residents of the North Shore. Without this
connector many residents have to take automobiles to reach these jobs. The connector
would result in a regional benefit, opening up Boston and Cambridge to the communities
whose residents now commute along Route 1, by making transit more attractive. Mr.
Vitagliano also agrees with Mr. Salvucci that the connector would decongest transfer
traffic at Park Street.
Mr. Vitagliano expressed concern that not completing the connector would lead to
questions about the state’s credibility. The connector was originally proposed as part of
mitigation for the Central Artery/Tunnel as a way to transform the transportation network
for Massachusetts, and following through with MassDOT’s recommendation may make
the public look negatively upon the future public commitments to transportation.
Mr. Vitagliono will also submit written comments.
Lynn Weismann -- Friends of the Community Path
Ms. Weismann’s first comment was regarding the meeting notice, which was posted
online. She only found the notice as a scanned PDF, which made it difficult to forward
and to copy and paste from. She also did not find it on the website, only as a stand-alone
link. This could partially account for the low attendance at the meeting, she said.
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Ms. Weismann also provided a comment on the process, stating her belief that the
October 14th deadline for comments was not long enough.
Ms. Weismann is concerned about the parking lots in Salem and Beverly as counting
toward mitigation for delays in the Green Line Extension project, as those parking spaces
would have been built regardless. The spaces also do not benefit Somerville, which has
the most air quality impacts during this mitigation period. She also believes the hybrid
vehicles for The Ride were going to be purchased anyway, just at a later date.
Ms. Weismann suggested increasing bus service to Assembly Square, mentioning that
MBTA bus route 90 does not run very often. Service should cater to peak hours and
shopping hours.
Regarding the Red Line – Blue Line Connector project, Ms. Weismann proposed
constructing a tunnel that could serve as a walkway with room left for train service. This
would alleviate cost concerns by eliminating the need to buy new trains in the immediate
future.
Ms. Weismann believes that mitigation efforts should be increased now that the final
completion date for the Green Line Extension is in the summer of 2021. She is excited
about the Community Path, but afraid that the new administration may not be committed
to constructing it. Ms. Weismann proposed codifying the path as a mitigation project. She
noted that the path would be a permanent project, which may be more desirable for
mitigation than temporary projects. The path also crosses through environmental justice
neighborhoods and is connected to 11 other paths, resulting in 48 miles of contiguous
path network. This provides regional connectivity through some of the densest areas of
Massachusetts.
An MAPC study from June 2013 estimates 3 million trips per year on the Community
Path as well as significant reductions in VMT and carbon dioxide emissions, the
equivalent of moving 50,052 cars off the road. Ms. Weismann believes Somerville needs
off-road pathways, as it has the most square miles of roadway than any other community.
The path is vital to providing a place away from particulates for people walking and
biking.
Ms. Weismann is also interested in the creation of a spur from the Community Path into
the Twin Cities Plaza area. The spur could potentially connect to the Grand Junction trail.
The Twin Cities area currently lacks connection to the Community Path as residents of
East Cambridge and Somerville have to go to Lechmere or up and across McGrath
Highway to Washington Street. Creating this connection could be mitigation for the
delays in the Green Line Extension project and in the future promote mode shift by
creating a continuous path. Ms. Weismann would also like to see the path connect to the
refrigerator building in this section.
Friends of the Community Path will be submitting written comments.
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