Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan – Transit Commitments
2013 Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
January 17, 2014
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
January 17, 2014
Kenneth L. Kimmell
Commissioner
Massachusetts Department of Environmental Protection
One Winter Street
Boston, MA 02108
Dear Commissioner Kimmell:
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 1, 2013). 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 September 12, 2013.
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
State Implementation Plan – Transit Commitments
2013 Annual Status Report
Agency Responses to Public Comments
I.
MassDOT Certification
II.
List of Public Comments Received
III.
Agency Responses to Public Comments
IV.
2013 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
OFFI CE OF T RANSPORTATI ON PLANNI NG
MEMORANDUM
TO:
Kenneth L. Kimmell
Commissioner
Department of Environmental Protection
FROM:
David J. Mohler
Executive Director
MassDOT Office of Transportation Planning
DATE:
January 17, 2014
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 2013 Annual SIP Status Report (by format and date)
Written Testimony
Date
Title
9/12/2013
9/12/2013 Staff Attorney
9/16/2013
9/18/2013
9/18/2013 Transportation Chair
9/19/2013
9/19/2013 Co-Presidents
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013
9/19/2013 State Representative
9/19/2013
9/19/2013
9/20/2013
9/20/2013
9/20/2013
9/20/2013 Alderman
First Name
Last Name
Rafael
Matthew
Elisabeth
John
Ken
Mares
Danish
Bayle
Kyper
Krause
Nina
Resa
Kevin
Hayward
Ted
Christopher
Susan
John
Ellin
Kate
Matthew
Jennifer
John
John
Robert
Todd
Alex
Spencer
Garfinkle
Blatman
Donovan
Zwerling
Bach
Ferry
Hamilton
Wilde
Reisner
Sackton
Steele
D
Macdougall
Roland Elliot
Reardon
Van Hoosear
Epstein
Sherman
Karen
Timothy
Lee
Mark
Max
Lee
Susan
Courtney
Molloy
Toomey
Auspitz
Nahabedian
Morrow
Auspitz
Hamilton
O'Keefe
Affiliation
Green Line Advisory Committee for Medford
Conservation Law Foundation
Additional Authors
Carolyn Rosen, William Wood
Sierra Club, Massachusetts Chapter
Friends of the Community Path
Alan Moore, Lynn Weissman
Massachusetts General Court
State Senator Patricia Jehlen; State Representative Denise Provost;
State Representative Carl Sciortino
Massachusetts House of Representatives
City of Somerville
Comments Received on the MassDOT 2013 Annual SIP Status Report (by format and date)
Oral Testimony
Date
Title
9/12/2013 Staff Attorney
9/12/2013
9/12/2013
9/12/2013
9/12/2013
9/12/2013
First Name
Rafael
Alan
Ellin
Carolyn
William
Wig
Last Name
Mares
Moore
Reisner
Rosen
Wood
Zamore
Affiliation
Conservation Law Foundation
Friends of the Community Path
Somerville Transportation Equity Partnership
Green Line Advisory Committee for Medford
Green Line Advisory Committee for Medford
Additional Authors
Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan - Transit Commitments
2013 Annual Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
January 17, 2014
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 2013 Annual Status Report (the Status Report) submitted to the Massachusetts
Department of Environmental Protection (DEP) on July 1, 2013 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 September 19, 2013,
following two public meetings (both held on September 12, 2013) 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 extension of the Green Line to Somerville and Medford, although
comments were also received on the other State Implementation Plan (SIP) projects, as well as
on non-SIP issues. MassDOT staff have 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.
information and detail on the regulation (310 CMR 7.36) can be viewed at:
http://www.massdot.state.ma.us/SIP.
Additional
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
January 17, 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 by Governor Patrick
but sufficient to continue the construction of the Green Line Extension project – and many
other MassDOT/MBTA efforts – and to hopefully secure federal New Starts funding for the
project.
Interim Offset Mitigation Measure Recommendations
Many of the comment letters submitted in response to the Status Report included suggestions
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. Given the substantial air quality
benefit projected to be generated by the opening of the Green Line Extension, MassDOT and
the MBTA have struggled to develop a set of mitigation measures that will meet the necessary
air quality target within the time allotted for their implementation (prior to December 31,
2014). We appreciate the public patience that has been shown as our analysis and
brainstorming have continued, and we hope to release a final package of mitigation measures
shortly.
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. Comments from the
annual report are addressed in this document, but MassDOT ceased reporting on the parking
space commitment as of the annual report.
Massachusetts Department of Transportation
January 17, 2014
Page 2
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.
MassDOT and the MBTA are currently renovating Orient Heights Station (estimated
completion winter/spring 2013) and are preparing to renovate Government Center
Station (estimated start winter/spring 2013).

DEP is unable to effectively police MassDOT on the implementation of the SIP projects.
MassDOT feels that the partnership currently in place between the two agencies is an
effective one. MassDOT will defer to DEP for any further comment on this matter.

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, while 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 2013, the Green Line Extension (GLX) project
advanced as follows:
•
Construction began in January, including bridge widening activities at Harvard Street
Railroad Bridge (Medford) and Medford Street Railroad Bridge (Somerville); utility
relocation/replacement; retaining and noise wall work; and track work. This work is
anticipated to be completed in 2015.
•
Advanced Preliminary Engineering was completed in September, with additional
design packages completed in November. This design will form the basis for future
cost and schedule updates, as well as the next New Starts submittals.
•
The MBTA continues to advance the real estate acquisition process.
•
In September, the MBTA submitted a New Starts Update (for FY2015) to the Federal
Transit Administration (FTA); supplemental financial information was then
Massachusetts Department of Transportation
January 17, 2014
Page 3
submitted in November. Based on its review of these materials, the FTA will ‘rate’
the project. That rating, along with a project summary, will be included in the
annual New Starts Report to Congress, which is anticipated to be released in
February 2014.

The proposed Green Line Extension terminus at College Avenue in Medford does not
meet the SIP requirement for the Green Line to be extended to ‘Medford Hillside.’
MassDOT and the MBTA are therefore in violation of the SIP.
As we have stated before, MassDOT and the MBTA feel confident not only that College
Avenue offers the best balance of benefits and impacts of any potential station location
in the immediate area of Medford Hillside, but that it also fulfills the commitment by the
Commonwealth for the Green Line Extension to reach Medford Hillside and to serve the
Medford Hillside neighborhood. MassDOT believes that a terminus at College Avenue
not only serves the Medford Hillside area but also promises to draw riders to the Green
Line and create a sense of place at the new station.
The current design for the College Avenue Station will create an active use at the
intersection of Boston and College Avenues, incorporating a south-facing plaza. The
scale of the station will respect the character of the residential buildings in nearby
neighborhoods, and will be of modest size and include simple detail.
A pedestrian walkway will link the entry plaza of the station to the nearby Burget
Avenue neighborhood, and an accessible vehicular drop-off/pick-up area will be located
along the Boston Avenue edge. The selection of materials for fencing, walls, paving,
seating, and planted areas will be sensitive to the area’s context and will be used to
visually reinforce the location of station entry points and support overall wayfinding in
the station area.
The position of MassDOT and the MBTA on the Medford Hillside issue is supported and
has been reinforced by multiple regulatory agencies responsible for overseeing the SIP,
including the Massachusetts Department of Environmental Protection. The current
project configuration has also been embraced by the Federal Highway Administration,
Federal Transit Administration, and U.S. Environmental Protection Agency in their
approval of the Regional Transportation Plan for the Boston Region Metropolitan
Planning Organization (November 30, 2011).
For all of these reasons, we believe that a College Avenue terminus meets the
requirements of the SIP. The Green Line Extension to Union Square and to College
Avenue is the Green Line Extension that MassDOT and the MBTA are implementing
now. In addition, the Boston Region MPO voted in June 2012 to add funding to design of
the Mystic Valley Parkway/Route 16 station. This funding becomes available in 2016,
and MassDOT and the MBTA will begin working on this effort as that timeframe draws
closer.
Massachusetts Department of Transportation
January 17, 2014
Page 4

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.

As MassDOT and the MBTA commence on a long shutdown of Government Center
Station, mitigation measures for that shutdown should include:
o Free out of system transfers for patrons choosing to walk between stations
o Shuttle buses connecting downtown stations
o An underground concourse between Downtown Crossing and State Street
stations.
Beginning of March 2013, the MBTA will shut Government Center Station for an
anticipated two years in order to fully rehabilitate and renovate the station, which must
be brought to modern operational, accessibility, and design standards. During that
time, the MBTA will endeavor to effectively mitigate the disruption and inconvenience
caused to its customers by the closure of the station. In particular, the MBTA will be
implementing a free shuttle bus route connecting Haymarket, State and Bowdoin
stations with Government Center during the closure.
The MBTA considered an out-of-system transfer policy – in which riders could walk
between stations and then re-enter the MBTA system without paying again – for the
duration of the renovation project. While such a transfer would benefit some riders
(those without day, week, or monthly passes), the great majority of customers can make
the connections typically afforded by Government Center Station within the rest of the
downtown MBTA rapid transit network. Implementing out-of-system transfers for those
without an unlimited pass cannot reasonably be done with the automated fare
collection system. A paper transfer would be labor-intensive, would increase
operational costs for the MBTA, and would likely increase fare evasion and other forms
of cheating. In the end, after careful consideration, the MBTA decided that out-ofsystem transfers would not be effective or prudent.
Given the complexity and expense of the undertaking, it would be not be feasible to
implement an underground concourse between Downtown Crossing and State Street
within a two-year period.
Massachusetts Department of Transportation
January 17, 2014
Page 5

Beyond the Red Line/Blue Line Connector, MassDOT should complete all ‘missing’ transit
connections including the North-South Rail Link. Environmental justice communities in
East Boston and Revere would greatly benefit from connections to jobs in Boston and
Cambridge.
During the 1980s and 1990s, the Commonwealth considered a number of major
expansions of the MBTA system (sometimes known as ‘mega-projects’). Other than
design of the Red Line/Blue Line Connector and construction of the Green Line
Extension, none of these projects became SIP commitments (although elements of some
projects were included in Administrative Consent Orders), and none of them advanced
into rigorous design. Many of them cleared some level of environmental review. All
were conceived during an earlier era when either the availability of public funding for
infrastructure was much greater or the appreciation of the MBTA’s and
Commonwealth’s considerable financial challenges was much lower.
The ideas for these projects were originally developed decades ago. Even if the
Commonwealth had an unlimited supply of capital funding at its disposal, MassDOT
would argue that all of these project concepts should be rigorously re-evaluated to see if
they still make sense, address known mobility needs, and are politically and locally
viable. Given the financial constraints facing MassDOT and the MBTA and the demands
of funding the Green Line Extension project and other outstanding commitments, it
seems highly unlikely that MassDOT and the MBTA would take on any other major
public transit projects of the scope of the ‘mega-projects’ without significant additional
federal financial support.
Massachusetts Department of Transportation
January 17, 2014
Page 6
II. FAIRMOUNT LINE IMPROVEMENT PROJECT

Can MassDOT provide a more concrete timeline for the construction and 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. MassDOT agreed to fund a peer review on the current design specifications
and drawings, noise and vibration analysis, site alternatives analysis, feasibility study
and needs assessment, to be performed by a firm selected by the objecting abutters
(Polaris Consultants). The results of the peer review are currently being evaluated by
the MBTA. The MBTA will be able to develop a new schedule for completion of Blue Hill
Avenue Station after assessing the results.
Massachusetts Department of Transportation
January 17, 2014
Page 7
III. CONSTRUCTION OF 1,000 NEW PARKING SPACES

In order to comply with the SIP requirement, one thousand additional parking spaces
have to be constructed rather than merely provided.
MassDOT previously addressed this issue in 2011. See:
http://www.massdot.state.ma.us/Portals/17/docs/sip/SIP-Response2011_1-7.pdf

Is the interim offset measure for the delay of this requirement (additional Saturday bus
service on the Route 111) still operating?
Even though the MBTA is no longer required to mitigate the delay in the opening of the
Wonderland garage project – due to the completion of the garage – the additional
service on the 111 is well-used and has been maintained to date by the MBTA.

Due to the multi-use nature of the Waterfront Square development at Wonderland, the
number of parking spaces actually available for users of the MBTA’s public transit system
will be smaller than predicted and promised, and therefore too small to contribute to SIP
compliance. The MBTA must ensure that enough space is dedicated for commuter
parking, and must install and enforce such a system. If an agreement [between the
MBTA and the developers of Waterfront Square] is in place, that agreement must be
made public.
MassDOT understands this concern, and has been proactive in addressing it. The MBTA
has worked closely with the private developer over the lifespan of this project, and has
entered into an agreement that specifies the number of spaces that will be available for
transit users once the development is open. As the plans for the private development
around Wonderland Station are not yet finalized and the development project not yet in
construction, the agreement has not been implemented. Over the long term and to
ensure that the spaces promised to MBTA users are, in fact, reserved and available for
MBTA riders, the MBTA and the private developer will enforce the agreement within the
garage, through signage, dedicated spaces, and internal gates. Similar situations have
been handled at numerous other MBTA parking facilities, including Lynn Station, Route
128 Station and Mystic Center (Wellington).
As the private development around Wonderland Station evolves, the allocation of
parking spaces may be adjusted between the MBTA and the private developer. If this
were to occur, MassDOT and the MBTA would ensure that an equal number of parking
spaces were provided at new facilities in order to keep to the overall 1,000-space
commitment. A letter between the MBTA and the City of Revere on this topic is
attached to this document.
Massachusetts Department of Transportation
January 17, 2014
Page 8
IV. RED LINE/BLUE LINE CONNECTOR

The proposal by MassDOT to amend the Transit System Improvement Regulations on the
subject of the Red Line/Blue Line Connector is inherently flawed, and should be rejected.
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 two facts:
1) 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.
2) The SIP regulation requires MassDOT to replace the air quality benefit of any
project as part of the substitution process, and the final design of the Red
Line/Blue Line Connector has no air quality benefits. Therefore, no substitution
is warranted.
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. The U.S. Environmental Protection Agency must still approve the SIP revision
after an opportunity for public comment. MassDOT is not currently aware of the timing
for the EPA-led public comment process.

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 strongly rejects 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, such as those referenced in the
comment letter. 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
Massachusetts Department of Transportation
January 17, 2014
Page 9
Line/Blue Line Connector is the only one with a substantial tunneling component, which
presents its own set of schedule/cost risks.
The comment letter makes comparisons with the South Coast Rail project, and the cost
estimates developed during the environmental review process for that project. The
specific circumstances of that project make a lower contingency appropriate. Should
MassDOT have elected to use that same contingency for the Red Line/Blue Line
Connector planning process, it would have been an unwise choice, given that the South
Coast Rail project does not require tunneling through a centuries-old urban settlement,
as the Red Line/Blue Line Connector does.

I deplore the fact that wealthy special interests were able to block the Red Line/Blue Line
Connector each time it has been proposed.
In planning for its transportation investments, MassDOT does not give special attention
to any particular group of constituents over any other, and wealth and privilege do not
buy favor in the planning processes for MassDOT projects. The planning process for the
Red Line/Blue Line Connector project was no different, and a range of individuals and
groups participated in the development of the Draft Environmental Impact Report for
the project. Such accusations demean MassDOT, its staff, and the many members of the
public who gave their time and ideas to the Red Line/Blue Line planning process.
Massachusetts Department of Transportation
January 17, 2014
Page 10
V. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD

The Commonwealth does not provide enough information about the funding plan for the
Green Line Extension project. [We] renew our request for MassDOT to complete, and
make publically available, a detailed funding plan for the project. Please describe how
the Transportation Finance Act of July 2013 will address the MBTA’s budgetary needs
and remove the financial obstacles to constructing the Green Line Extension.
The funding strategy for the Green Line Extension remains the same as it has been
throughout the project: to pursue federal funding through the federal New Starts
discretionary funding program – a competitive program for which the Commonwealth
must apply for funding – and to match that funding with Commonwealth dollars.
MassDOT and the MBTA are pleased that the Green Line Extension project was selected
by the FTA in 2012 for approval into the Preliminary Engineering phase of the New
Starts process.
At present, the proposed financing plan for the Green Line Extension project calls for
FTA to fund 50% of the capital costs of the project, with the Commonwealth expected to
pay operating costs, finance costs, and the remaining 50% of the capital costs. To date,
greater than $617 million in Commonwealth funding has already been committed to the
Green Line Extension project. This represents over 86% of the total state capital funding
anticipated to be needed for the project.
As part of the application to FTA for Preliminary Engineering, MassDOT was required to
present a plan to address the MBTA’s ongoing operating deficit issues and provide
sufficient capital funds for the state share of the project costs. In turn, this would make
it possible for FTA to consider funding a portion of the Green Line Extension project. In
July 2013, the Massachusetts General Court passed legislation, which was then signed
by Governor Patrick, to provide ongoing funding to address transportation needs in the
Commonwealth (https://malegislature.gov/Laws/SessionLaws/Acts/2013/Chapter46).
The legislation improved the MBTA’s financial condition and will enable it to better fund
ongoing operations and maintenance, debt service, and capital costs, including a
significant reduction in its established State of Good Repair needs.
With passage of this legislation, the MBTA was able to provide FTA with an updated
financial plan for the Green Line Extension project in November 2013. This plan
describes the financial capacity of the MBTA to undertake the Green Line Extension
project while also maintaining the existing MBTA system and meeting its ongoing
financial commitments, including addressing its State of Good Repair backlog. This
latest Green Line Extension project financial plan, submitted to the FTA, can be found at
the State Transportation Library at 10 Park Plaza, 2nd Floor, Boston.
Massachusetts Department of Transportation
January 17, 2014
Page 11

What is the most current schedule, by phase, for the construction of the Green Line
Extension project? When can people expect to see construction in various locales, and
when can they expect to ride the extended Green Line?
Construction of the Green Line Extension project is currently underway with the
initiation of Phase 1, consisting of the reconstruction of the Harvard Street Railroad
Bridge in Medford and the Medford Street Railroad Bridge in Somerville, as well as the
demolition of MBTA-owned facilities at 21 Water Street in Cambridge. This work began
in 2013 and is expected to be complete in 2015.
Phase 2/2A (constructing the Green Line from the (new) Lechmere Station to
Washington Street and Union Square Stations) is projected to begin in the
spring/summer of 2014. The bulk of construction is anticipated to be completed in late
2016. Phase 2/2A of the Green Line Extension is currently anticipated to open for
service in mid-2017.
Phase 3 (constructing a new maintenance and storage facility for Green Line vehicles) is
scheduled to commence in January 2016. The vehicle facility is scheduled to be
complete six months prior to the scheduled date for the completion of Phase 4 (see
below), in order to support revenue service to College Avenue Station. The full build-out
of the vehicle facility is not needed to support Phase 2/2A passenger service. The
required time to acquire and relocate the current tenants at the site identified for the
location of the vehicle facility dictates the need for additional schedule flexibility in this
phase.
Phase 4 (constructing the Green Line from Washington Street Station to College Avenue
Station) is scheduled to be open for service before July 2019, based on the latest project
projections and risk assessments. This schedule assumes FTA approval of utility
relocation activities at certain locations ahead of the issuance of a Full Funding Grant
Agreement (by which FTA commits to participate in the costs of the project), but
assumes that most of the construction work will not be done until after the issuance of
the Full Funding Grant Agreement. The precise date of FFGA award is unknown at this
time.
These schedules are currently under review as part of the completion of the application
to FTA for the Green Line Extension project.

The Interim Offset Measures for the Green Line Extension project’s delay are a vital tool
for improving air quality while the project continues to advance. Please provide an
update on the status of the analysis and decision making for the selection of the
measure. We feel strongly that all proposed measures must be modeled for air quality
impact, and that a strong public involvement process must be included in the selection.
Specifically, we request that the following measure be included in the final mitigation
measure package:
Massachusetts Department of Transportation
January 17, 2014
Page 12
Additional Green Line services to Lechmere
Improved pedestrian connections in the Green Line Extension corridor
Removing the elevated portions of the McGrath Highway
Instituting free Hubway memberships for corridor residents, and the expansion of
the Hubway program
o Plan for the Urban Ring, and implement early-action transportation
improvements in the Urban Ring corridor, specifically via new bus routes between
Kendall and Sullivan stations
o Improvements to existing traffic congestion areas in Medford and Somerville,
including Route 16, Winthrop Avenue and Boston Avenue in the vicinity of the
proposed station.
o
o
o
o
MassDOT received many recommendations for potential interim offset mitigation
measures for the Green Line Extension project, and qualitatively evaluated all of them
against a series of criteria. The criteria were selected to collectively measure the
practicality, operational viability, cost, potential to improve air quality, potential for
municipal support, and timing of implementation of each of the recommended ideas. In
particular, MassDOT is working closely with the MBTA to determine whether there are
mitigation measures that the MBTA could implement given its existing operating
constraints. This evaluation is posted online at the Green Line Extension website
at: http://www.greenlineextension.org/documents.html.
As mentioned earlier in this document, MassDOT and the MBTA anticipate being able to
release a final proposed package of mitigation measures shortly.

Interim Offset Measures for the Green Line Extension project’s delay must be
implemented in the project corridor of Cambridge, Somerville, and Medford. We firmly
believe that any mitigation project should be executed within the proposed corridor of
the Green Line Extension project to mitigate for the environmental impact on our
communities.
The purpose of the State Implementation Plan in general, and the specific projects
affiliated with the SIP in particular, is to improve regional air quality. MassDOT will
focus on implementing interim offset measures in the most prudent way possible to
meet regional air quality goals. However, MassDOT will attempt, whenever reasonable,
to implement measures that would also improve air quality directly in the project
corridors.

The full design and construction of the extension of the Somerville Community Path
should be included in the costs and scope of the Green Line Extension project, or included
as an interim offset measure for the delay. This includes the “missing link” between
Inner Belt and Northpoint/Lechmere. DEP should influence MassDOT to include the
construction of the Community Path as part of the Green Line Extension project.
Massachusetts Department of Transportation
January 17, 2014
Page 13
MassDOT has long committed to developing final designs for extending the Somerville
Community Path between Lowell Street in Somerville and Inner Belt Road in Somerville.
This has been done in collaboration with the City of Somerville and advocates for the
Path, so that the final design of the Path extension will be effectively integrated with the
Green Line Extension. MassDOT will also fund the construction of infrastructure that
must be shared between the Green Line Extension and the Path, including retaining
walls and bridge structures.
Connections on the southern end of the proposed Path extension have been discussed
extensively with the City of Somerville and with Path advocates, and MassDOT
understands both the desire to extend the Path into the Lechmere area and longstanding municipal goals to develop the Inner Belt area of Somerville with greater
density and more employment. At this point, MassDOT is unable to take on the
financial responsibility for building a bridge connection (often called the “Urban Ring
Bridge” or “Northpoint/Inner Belt Bridge”) between the Inner Belt neighborhood and
the Northpoint/Lechmere neighborhood.
The Community Path design (Lowell Street to Cambridge) continues to advance with the
overall Green Line Extension project design and has been included in the construction
phasing plans under review. The MBTA and the City of Somerville are negotiating a
Memorandum of Agreement to establish ultimate ownership and maintenance
responsibility, and confirming the design criteria to be used. MassDOT and the MBTA
anticipate that the MOA will be executed during the winter of 2014.

DEP should ask MassDOT to clarify its plans, formalize a schedule, and devote planning
resources to the Mystic Valley Parkway station, corresponding with the Boston MPO’s
decision to fund the station. We continue to be disappointed that the communityselected terminus for the Green Line Extension project (Route 16 / Mystic Valley
Parkway) has not been advanced at this time. Further planning and design funding for
this station becomes available in 2016. When will MassDOT and the MBTA begin
working on this effort?
In June 2012, the Boston Region MPO voted to ’program’ – commit for spending federal Congestion Mitigation and Air Quality Improvement funds for the 2016 planning
year as part of the regional Transportation Improvement Program. This will allow for
further design and environmental work 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.

MassDOT and the MBTA have given mitigation money to Tufts University, and this
information must be made public immediately.
Massachusetts Department of Transportation
January 17, 2014
Page 14
A noise analysis to measure the baseline (e.g. existing) and projected future noise levels
from the Green Line Extension corridor was conducted by MassDOT as part of the
development of the Environmental Assessment (EA) for the Green Line Extension
project, per the National Environmental Policy Act (NEPA). This comparison of baseline
and future conditions for noise found that mitigation – techniques employed to reduce
noise and/or vibration – must be provided in certain areas of the Green Line Extension
corridor where noise or vibration levels are expected to increase due to the introduction
of the Green Line. One location in which the noise level was projected to increase is the
site of the Tufts Science and Technology Center building on Colby Street in Medford. In
this area, the construction of the Green Line Extension requires the relocation of the
existing MBTA Commuter Rail tracks closer to the Science and Technology Center, thus
increasing the noise level experienced by users of the building. In accordance with NEPA
and the Green Line Extension EA, the MBTA is working with Tufts (and other land
owners for whom future noise is projected to increase over NEPA threshold levels) to
implement the required mitigation.
For the Tufts University’s Science and Technology Center, this mitigation includes an
upgrade of the existing windows, and the installation of sound insulation improvements
in the building. Coincidentally, the building is currently being renovated by Tufts
University, and the MBTA is working with Tufts to allow the required mitigation to be
performed during this renovation process, in order to avoid two consecutive
renovations. This saves the MBTA money as well as minimizing impacts on the users of
the building. Currently, the MBTA is in the process of establishing and negotiating a final
price for the incorporation of these improvements into the ongoing renovations. This is
the only mitigation activity required to be provided by the MBTA to Tufts University as
part of the Green Line Extension.
This type of collaboration to support the provision of mitigation – mitigation committed
to by MassDOT in the planning and environmental review phases of the Green Line
Extension project – is a standard, accepted, and above-board part of any construction
project.
Massachusetts Department of Transportation
January 17, 2014
Page 15
cf>'\,
The City of Revere Massachusetts
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City Hall
281 Broadway
Revere, MA 02151
(781) 286-8110
(781) 286-8199 Fax
Daniel Rizzo
Mayor
Office of the Mayor
Jonathan R. Davis
Actmg General Manager
Mass Bay Transportation Authority
10 Park Plaza
Boston, MA 02116
Re: Parking Space Allocation in South Parking Garage at Wonderland
Station, Revere Pursuant to City ofRevere/MBTA Lease of Parcel H
Dear Mr. Davis:
Pursuant to the letter dated April 5, 2012 from Mary Beth Mello, Regional Administrator
of Federal Transit Administration (the "FTA") (the "FTA Letter"), I am writing to confirm our
understanding regarding the allocation of parking spaces at the MBTA's South Parking Garage
at Wonderland Station (the "SPG"). With your agreement as set forth herein, this letter will
update the Side-Letter Agreement between the City of Revere (the "City") and the MBTA, dated
as of March 2011 (the "SLA," copy attached), which addressed certain issues surrounding the
allocation of parking in the SPG pursuant to the Parcel H Lease and Development Agreement
between the City and the MBTA, dated as of March 2, 2009 (the "Lease").
Based upon the breakdown of funding sources for the SPG outlined in the FT A Letter,
tht City i& in ag1t!emt!11t lhat its share of SPG parki11g spaces, which shall be made available al
fair market rates in order to support the Wonderland TOD, shall reflect its ' proportionate share of
funding contribution toward the total SPG project cost. With an estimated 1465 total parking
spaces to be created in the SPG, the City agrees to an allocation of 443 SPG spaces, as set forth
in the FTA Letter. In addition, in order to preserve the maximum development opportunity on
Parcel H (and a maximum return to the MBT A in ground lease payments), which required 600
parking spaces under the terms of the Lease, the City and the MBT A further agree to an
allocation of up to 75 "shared" SPG spaces (as further defined below) and an additional
allocation of up to 82 surface lot parking spaces to be located on MBT A owned property located
adjacent to Parcel H. All of the parking spaces referenced above are to be allocated to the City in
support of the Wonderland TOD and the City is prepared to move forward with the necessary
documentation required under the Lease on this basis.
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The City is aware of the issues surrounding the Mass DOT commitments under the State
Implementation Plan (the "SIP"), which currently include a substantial portion of the net new
commuter parking spaces at the SPG. The City understands that there are only 102 SPG spaces
that would be initially available to support the TOD. However, as we have also discussed, the
MBTA is currently moving forward with a number of parking garage and commuter parking
supply expansion projects, which will result in an increase in MBTA commuter parking spaces
in the Commonwealth. In particular, the parking garage projects in the cities of Beverly and
Salem are moving forward and are currently projected to be in construction by 2012/2013.
When these two parking garages are completed, they are projected to add a sufficient supply of
net new commuter parking spaces to the inventory ofMBTA commuter parking spaces in the
Commonwealth to allow Mass DOT to propose a substitution of these spaces for the Wonderland
spaces that are currently identified in the SIP. This substitution by Mass DOT would require the
concurrence of DEP.
The availability of parking spaces in the SPG to the City in support of the Wonderland
TOD, as set forth above, is further conditioned by certain outstanding obligations by the MBTA
and Mass DOT concerning the Green Line extension project. Although these issues are currently
under deliberation at the MBTA and Mass DOT, their outcome may impact the timing and
availability of the Beverly and Salem garage spaces for purposes of substitution of SPG spaces
under the SIP.
Thus, in summary, the City and the MBTA have agreed to the following allocation of
parking at Wonderland Station in support of the TOD, consistent with the level of financial
contribution breakdown and other issues discussed above.
A. Upon the substantial completion and opening of the SPG in 2012, and for the period
required for the resolution of the SIP issues described above, which we have discussed are
anticipated to be resolved in the 2018-2020 time-frame, the City will have the following parking
program allocation available in support of the Wonderland TOD:
*up to 102 parking spaces in the SPG, at current market rates, upon the opening of the
SPG;
*up to 75 "shared" parking spaces, available from approximately 6 p.m. to 6 a.m., at
current market rates, upon the opening of the SPG;
*up to 423 surface parking lot spaces on MBTA controlled property located adjacent to
Parcel H, at current market rates, upon the opening of the SPG;
B. Upon the resolution of the SIP issues described above in this letter, the City will have
the following parking program allocation available in support of the Wonderland TOD:
*up to 443 parking spaces in the SPG, at current market rates;
*up to 75 "shared" parking spaces in the SPG, available from approximately 6 p.m. to 6
a.m., at current market rates;
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*up to 82 surface parking lot spaces on MBTA controlled property located adjacent to
Parcel H, at current market rates.
I am extremely grateful to you and all of the FT A, Mass DOT and MBTA staff working
to make this Wonderland Station project a model for a successful TOD. I understand and believe
that we would not have made the progress that we have made to date on the project had it not
been for the willingness of all of the interested parties to work together in a cooperative manner.
I hope that this letter accurately states our understanding on this parking issue and if you are in
agreement with this summary, could you please execute the duplicate original copy of this letter
and return it to me for our files? Thank you again for your attention, cooperation and support on
this very important project for the City of Revere.
AGREED AND ACCEPTED:
MASSACHUSETTS BAY TRANSPORTATION AUTHORITY
•
an R. Davis
g General Manager
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APPROVED AS TO FORM
Mary Beth Mello
Peter Butler
Wendy Lee
David Mohler
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Clinton Bench
Mark Boyle
Ronald Ross
Andrew Brennan
Phil Jean
Paul Rupp
Doug McGarrah
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U.S. Department
of Transportation
Federal Transit
Administration
REGION I
Connecticut, Maine,
Massachusetts,
New Hampshire,
Rhode Island, Vermont
Volpe Center
55 Broadway Suite 920
Cambridge, MA 02142-1093
617-494-2055
617-494-2865 (fax)
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Jonathan R. Davis
Acting General Manager
Massachusetts Bay Transportation Authority
Ten Park Plaza
Boston, MA 02116
Re: Wonderland South Parking Garage Project
Dear Mr. Davis:
The Federal Transit Administration (FTA) is in receipt of your February 24, 2012 letter
regarding the allocation of parking spaces at the Wonderland South Parking Garage (SPG). The
SPG is nearing completion and the Massachusetts Bay Transportation Authority (MBTA) is
seeking FTA approval to enter into a lease agreement with the City of Revere. As proposed, 996
of the 1,465 spaces in the SPG would be reserved for MBTA riders, with the remaining 469
spaces leased to the City of Revere at current market rates. An additional 75 spaces would also
be made available to the City during off peak hours, between 6:00PM and 6:00AM.
In March 2010, FTA issued a Finding of No Significant Impact (FONSI) for the construction of
a new nine-story, 1,963 space parking garage, train station lobby, and busway shelter adjacent to
the MBTA Blue Line Wonderland rapid transit station in Revere, MA. The SPG is a critical
element of an overall Transit Oriented Development (TOD) initiative that is underway in the
City of Revere with significant financial support provided by the MBTA, MassDOT and other
state agencies. Shared use of the SPG by transit riders and the City in support ofits
redevelopment efforts was a matter that the MBTA and the City discussed and sought FTA
concurrence on. Since the City's share of the total cost of the SPG was approximately 30%,
FTA did not object to the MBTA's December 30, 2009 letterrequesting permission to lease up
to 600 or 30% of the available SPG spaces at current market rates to the City. FTA's
concurrence in these plans, however, predated the bid opening whereby the cost of the project
exceeded available funding and necessitated a reduction in the number of floors from 9 to 7 and
number of spaces from 1,963 to 1,465.
Currently, SPG total project costs of $49,304,064 are financed by: (1) FTA - 46.66%; (2) MBTA
- 22.92%; and (3) City of Revere - 30.26%. The permanent allocation of 469 spaces to the City
as requested by the MBTA exceeds the pro rata share of the City's contribution. While the FTA
is supportive of the MBTA's interest in balancing the need for transit parking against its need to
generate new revenue streams, the number of SPG spaces that can be made available to the City
for redevelopment purposes cannot exceed 443 or approximately 30% of the total. Furthermore,
the leasing of these 443 spaces is predicated upon the Commonwealth's ability to satisfy its SIP
(State Implementation Plan) commitments. Lastly, FTA does not object to the MBTA making
up to 75 SPG spaces available to the City during off peak hours, between 6:00PM and 6:00AM,
at current market rates.
While a parking lease agreement between the MBTA and the City will reduce the number of net
new transit spaces from 612 to 271, FTA does not consider this change to conflict with the
Findings in the Environmental Assessment (EA) or the FONSI issued by FTA on March 15,
2010.
Please let us know if you have any questions.
Sincerely,
fi~ f>-ad'-- H~
Mary Beth Mello
Regional Administrator
Deval L. Patrick, Governor
1irnothy P. Murray, Lt. Governor
Richcird A Davey. MassDOT Secretary & CEO
Jonathan R. Davis. Acting General Mc1nager
and Rail & Transit Administrator
.i~·l!ll!.[l.QQI
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;ail & Transit Division
February 24, 2012
Regional Administrator Mary Beth Mello
Federal Transit Administration - Region One
55 Broadway
Cambridge, MA 02142
Wonderland South Parking Garage Project
RE:
Dear Regional Administrator Mello:
As you are aware, the MBTA is developing, in conjunction with the City of Revere, the South
Parking Garage (SPG) currently under construction at the Wonderland Station in Revere. The project
has been a cooperative project with the City for several years in an attempt to provide our customers
with better, more convenient access to the station as well as to support the proposed Transit Oriented
Development (TOD).
An Environmental Assessment (EA) document was prepared and released to the public for
review and comment in January 2010. The FTA issued a Finding of No Significant Impact (FONS!) for
the project on March 15, 2010, which effectively concluded the NEPA review of the project.
The EA presented a Purpose and Need that had three basic components:
•
•
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Create additional parking for MBTA customers to attempt to address projected demand on the
station in the planning horizon year of 2030;
Develop parking to be leased to the City of Revere to support the TOD project, which would in
turn, provide the MBTA with a steady revenue stream due to the leased parking; and
Improved pedestrian circulation and customer access, including an improved path of travel for
customers with disabilities.
As you know, the cost of the total project exceeded available funding, and as a result, after the
bids were opened, the MBTA reduced the scope of the project by, among other things, reducing the size
of the garage from 1,963 spaces on 9 floors to 1,465 spaces on 7 floors. With fewer spaces, the MBTA
must now determine which spaces are allocated between the two pressing elements of the project
purpose, that is, the need to provide more transit access for our customers and the need to ensure that
the TOD project is financially viable and will provide the MBTA with the reliable revenue stream of
$245,000 per year to support its operations.
As was discussed with your staff, the City of Revere is proposing it enter into an agreement with
the MBTA, in which the City was allowed to lease:
•
•
•
Up to 469 SPG spaces, at current market rates;
Up to 75 SPG "shared" spaces, available from approximately 6 p.m. to 6 a.m. at current market
rates; and
Up to 56 surface Jot spaces on MBTA controlled surface parking lots adjacent to Parcel Hat
current market rates.
Leading the Nation in Transportation Excellence
Massachusetts Bay Transportation Authority
Ten Park Plaza. Suite 391 O. Boston, MA 021 16
www.mbta.rnm
This agreement between the City of Revere and the MBTA is further described in the attached
letter. The letter describes the timing of the elements of the agreement and how the spaces would be
managed so as to not violate the requirements of the State Implementation Plan (SIP).
The 469 spaces that the City of Revere would lease represent 32% of the spaces in the SPG. The
MBTA feels this is an appropriate ratio because the City of Revere funded nearly one third of the costs of
the total capital costs of the project. The following table represents the cost of the SPG and the sources
of revenue that funded the project. As demonstrated by this table, the financial contribution to the SPG
made by the City of Revere is directly proportional to the percentage of parking spaces they are
requesting.
JfA
Federal Funding
MBTA Funding
City of Revere Funds
ARRA Funding
Federal Earmarks
MBTA Revenue Bonds
MORE Grants
Local Match for
Earmark
$22, 700,000
$305,548
$11,300,000
$10,000,000
TOD Grants
$4,922,129
$76,387
46.04%
0.62%
22.92%
20.28%
0.15%
46.66%
22.92%
30.42%
9.98%
Under this scenario, the MBTA will realize an increase of 245 in the number of transit customer
parking spaces. In 2008, the Central Transportation Planning Staff (CTPS) completed systemwide
demand projections for the entire MBTA service area. In that report, ridership demands as well as
parking projections were made of each park and ride facility in the MBTA system.2 According to this
CTPS report, the average weekday parking demand (unconstrained) in the year 2030 was 3,050.3
Currently, the MBTA owns and controls 1,273 spaces or 42% of the future parking demand. The SPG as
it was presented in the EA would have resulted in the MBTA owning and controlling 1,885 spaces, or
62% of the projected demand. If the MBTA were to enter into the agreement proposed by the City of
Revere, the MBTA would own and control 1,518 parking spaces, or 50% of the parking demand. T~e
attached table identifies the number of parking spaces and the percent of parking demand that each
scenario would have resulted in.
The SPG would have never provided all of the spaces to meet the anticipated parking demand.
While the proposal put forth by the City of Revere would reduce the number of spaces that would
ultimately be available to transit customers, that proposal would still result in new spaces being added
for transit, and these spaces increase the MBTA's ability to meet parking demand over today's scenario.
Capital Costs are for the SPG only. The costs of the busway and roadway work represent a separate
project and do not factor into these calculations.
2
Projections of Parking Demand, Kiss-and-Ride Passengers and Ridership for MBTA Commuter Boat, Express
Bus, Commuter Rail and Rapid Transit SeTVices prepared by CTPS, December 2008
Ibid, Table 6
The MBTA is rarely if ever able to build new parking that provides 100% of future demand.
Constraints on space, environmental impacts, available real estate, roadway configurations or costs
frequently cause us to build parking facilities that provide additional parking but perhaps less than what
are optimally desired 20 or 25 years into the future. The MBTA must balance these other constraints
against our desired project ~ize.
In the case of the SPG, the MBTA is balancing the need for parking against the MBTA's need to
generate new revenue streams and develop strong and sustainable developments adjacent to our
stations. Each of these ideas was an important part of the Purpose and Need laid out in the EA and no
single element trumped one of the others.
The Wonderland private development is an important revenue stream for the MBTA. The TOD
project clearly needs to have on site and permanent parking available to support its hotel and
commercial office space tenants. That TOD project results in $245,000 to the MBTA annually and $80
million in funding to the MBTA over the life of the lease. Additionally, the TOD project brings with it
other benefits to the area such as well planned and appropriately sited development that allows our
customers to access the station without relying on a single occupant automobile. Encouraging these
sustainable communities is an expressed goal of the MBTA and the FTA. Focusing solely on the needs of
customers who drive to the station will perversely result in a lost opportunity to encourage strong nonauto development at the station.
Under the proposal put forth by the City of Revere, the SPG would continue to meet the project's
Purpose and Need that was laid out in the January 2010 EA, albeit to a lesser degree than what was
originally anticipated. The proposal put forth by the City of Revere continues to meet the projects
Purpose and Need and does not conflict with the Findings in the EA nor does it conflict with the FONSI
issued by the FTA.
If you would like, I would be glad to meet with you to discuss these issues in person and to
further discuss the' Wonderland SPG Project. MBTA Staff and representatives of the City of Revere are
available to provide you with additional details on this request if needed. We believe so strongly in the
value and benefits of this project that we would appreciate an opportunity to speak with you about it
directly.
Sincerely,
Jonathan R. Davis
Acting General Manager and Rail & Transit
Administrator
cc:
The Honorable Edward Markey, Congressman
The Honorable Daniel Rizzo, Mayor of Revere
Secretary Richard A. Davey, MassDOT
Side-Letter Agreement
Richard A. Davey, General Manager
Massachusetts Bay Transportation Authority
10 Park Plaza
Suite 3910
Boston, Massachusetts 021 I 0
Re: MBTA Lease of"Parcel H" at
Wonderland Station to the City of Revere
Dear Mr. Davey:
This letter sets forth the understanding between the MBTA and the City of Revere (the
"City") regarding the allocation of parking spaces at the MBTA's South Parking Garage at
Wonderland Station (the "SPG") pursuant to the Lease and Development Agreement, dated as of
March 9, 2009 and amended by the Amendment to Lease and Development Agreement, dated as
of March_, 2011 (together, the "Lease").
The SPG is currently under construction under a contract between the City and the
selected general contractor (Suffolk Construction), on behalf of the MBTA for the benefit of the
MBTA's commuter parking supply and to support the City's transit oriented development project
known as Waterfront Square at Wonderland Station (the "TOD").
The City and the MBTA acknowledge that upon completion of the SPG, in accordance
with the current design plans currently projected for June, 2012, the SPG will contain an
estimated 1465 parking spaces of which, 612 have been designated as "net new commuter
parking spaces" for Mass DOT's compliance with requirements for the expansion of commuter
parking contained in the State Implementation Plan (the "SIP"). Of the remaining 853 parking
spaces, I 02 SPG spaces shall be made available, at then current market rates, to the City's
Redeveloper (as defined in the Lease) to support the TOD ifthe SPG when completed, contains
1465 SPG parking spaces. In the event the SPG when completed contains fewer SPG parking
spaces, 612 of such spaces must be,_ designated "net new commuter parking spaces" and the
number of spaces available to the City's Redevelopment will be adjusted accordingly. The City
will work with the Redeveloper to provide up to an additional 498 surface parking spaces,
located in close proximity to the TOD, at then current market rates, in support of the TOD as
may be required by the City's Redeveloper.
The MBTA acknowledges that additional SPG parking spaces , beyond the initial
estimated I 02 spaces, may be required by the City's Redeveloper to support the TOD. After the
initial opening of the SPG and a reasonable period for assessment of the SPG's utilization by
commuters, the MBTA agrees to work with the City on a program to allocate any available,
unused SPG spaces to support the TOD.
A0854863. DOC; I
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The MBT A further acknowledges that additional MBTA commuter parking spaces in
other locations in the Commonwealth may be delivered in the near future. In order to address the
projected need for up to an additional 498 SPG parking spaces to support the TOD, the MBTA
agrees to work with Mass DOT on a program to substitute additional commuter parking spaces
as and when they become available, for the SPG's 612 commuter parking spaces identified in its
SIP compliance submission to the Department of Environmental Protection ("DEP"). The City
and the MBTA further agree that, subject to FTA 's approval and DEP's acceptance of the
substitution of commuter parking spaces as described above, the MBTA will make available up
to an additional 498 parking spaces in the SPG, at then current market rates, to the City's
Redeveloper in support of the TOD. These additional spaces in the SPG will be made available
on a schedule to be prepared by the MBTA and submitted to the City on or before March 31,
2012 (the "Parking Schedule"). In the event the Parking Schedule does not include 498 spaces
(as that number may be adjusted based on the as-built size of the SPG), the MBTA and the City
shall meet to discuss potential impacts on the Redeveloper's Construction Schedule which in
tum may impact the terms of the Lease.
In the event of any conflict between the terms of this Side Letter Agreement and the
Lease, the conflicting term of this Side Letter Agreement shall govern.
:·., . .
If this Side Letter Agreement accurately sets forth our understanding with respect to the
future allocation of a portion of the parking spaces at the SPG, please execute a duplicate copy of
this document and return it to me for our files. Thank you for the MBTA's conti~ed partnership
with the City on developmentthe Wonderland Station TO~.~:
j ..
s ,c ·ety
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AGREED AND ACCEPTED:
A0854863.DOC; I
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l
"EXECUTIVE OFFICE OF.TRANSPORTATION .TRANSIT COMMITMENT
SUBMISSIONS ASSOCIATED WITH THE STATE ·IMPLEMENTATION PLAN
PUBLIC HEARING DATED SEPTEMBER 12, 2013
DEPT•.OF -ENVIRONMENTAL .PROTECTION
and
MASSACHUSETTS OFFICE OF TRANSPORTATION
SUBMITTED ·Bv
Green Line Advisory Committee for Medford (GLAM)
c/o 25 Bussell Road
Medford, ·Mass. 02155
StJBMITIED.TO
Katherine Fichter
Mass. ·oept. of Transportation
Office of Transportation Planning
Room 4150
Ten Park Plaza
Boston, Mass. 02116
and
Mr. Jerome Grafe
Mass ·DEP
Bureau of Waste Prevention
One Winter Street
Boston, Mass. 02018
September 12, 2013
'
Public Comments on State Implementation Plan - Transit Commitments 2013
Annual Status Report
These public comments written and submitted by the Green Line Advisory Committee for
Medford (GLAM) are focused on that portion of the Transit System Improvements
pertaining to the transit system known as the Green line extension from Lechmere to
Medford Hillside. These comments are based upon documents known as the State
Implementation Plan -Transit Commitments 2013 Annual Status R~port.
Based upon our participation within the Mass DOT citizen participation process over the
last year, these public comments are essentially our r~port card on Mass DOT and the
proposed Green Line project process. GLAM's comments build upon our observations
and experiences since our comments regarding the 2012 Annual Status Report. Our
.Public comments submitted on S~ptember 12, 2013 are as follows:
The SIP report in the Green Line section (page 19) refers to the status of the federal
NEPA lawsuit as brought by plaintiffs, Carolyn Rosen and Dr. William Wood, and GLAM.
In GLAM's SIP comments last year, the Mass DOT was cautioned that there was
consideration of such legal action due to Mass DOT's lack of intent to address civil rights
violation in the public participation process concerning the Environmental Assessment
(EA) and public health issues concerning the Green Line project.
Mass DOT in its stated position on the lawsuit as reported in the 2013 annual SIP report
has decided with the assistance of the Mass. Attorney General's office to stake their
defense on the conservative U.S. Justice Scalia's decision of 1992 in the case of Lujan
v. Defenders of Wildlife, 112 S. Ct. 2130. The decision in Lujan turned back the clock on
environmental gains in the courts and has since limited the ability of environmental
groups such as the Sierra Club in broadening the definition of standing for the fullest
protection of the ecosystem. In other words, Mass DOT decided to take an anti
environmental approach, an ironic environmental _position for such a liberal state.
GLAM on the other hand has taken the more liberal approach of Supreme Court Justice
St~phen Breyer on ecosystem protection and disability rights. A new civil rights that
must be explored in the courts in the direction as stated by Chief Justice John Roberts
last year in his speech at Rice University when identifying fundamental principles
underlying what constitutional protection is and applying it to new issues. Under ADA
law we have rights not to be injured by environmental impacts in the area. The
fundamental principle of disability rights is in not being harmed by state actions. And as
we have contended in _past SIP _public comments the failure of Mass DOT to provide
public health studies concerning diesel particulate matter (DPM) and its impact from this
major action is a concrete and imminent harm.
By taking such action an environmental stand, Mass DOT and groups such as itself has
played into the political hands of conservative Republicans at the national level who are
currently attacking the credibility of research the EPA has depended upon in setting its
air quality standards. By not taking research studies seriously, as we have pointed out
in our lawsuit, concerning the impact of noted carcinogens, such as diesel particulate
matter (DPM), and not seriously applying the practicality of that research to studies and
to remedies on projects such as the proposed Green Line Extension with an
interdisciplinary approach concerning the health impact of this specific carcinogen on
2
vulnerable populations such as the disability community, the Mass DOT has unwittingly
played .in.to the hands of .t he anti .environmentalist.by .taking .on the .role of .t he anti
environmentalist themselves in dismissing such studies.
In performing the analysis for the environmental assessment, the project proponent,
Mass DOT, failed to determine local air quality data on DPM, which is now required in
the environmental justice guidelines by the Federal Transit Administration
(FTA). 1 The FTA states "Grantees will want to make sure that aggregating results at the
regional level does not obscure critical local details." Hence Mass DOT overrode the
guidelines of the Environmental Justice population in the planning and NEPA process
and in particular those with disabilities affected by carcinogens such as DPM. The
project pro_ponent should have determined Diesel Particulate Matter (DPM) data local to
the project that would have a local impact. By failing to do so, it failed to assess
potential environmental impacts, both direct and indirect, or to identify mitigation
measures that could be taken to protect all of the disability community and other
communities affected.
Mass DOT instead took a page out of Benito Mussolini's philosophy that the train must
run on time to keep process flowing. The fact is that the train has never .run on time as
evidenced in the SIP reports. And for us as plaintiffs it has never been about keeping
the process train running on time for process sake.
The strength of NEPA, as a procedural statue, comes in its procedures concerning the
public decision making process around environmental information that must be of the
highest quality and accurate in its scientific analysis. When the root of the decision
making tree (the procedures) become rotted in its approach to civil rights participation, it
then infects the fairness of the public decision making process when those procedures
are violatec:t especially when they specifically impact civil rights laws such as the
Americans with Disabilities Act (ADA) and Title VI. We believe constitutional laws super
cede procedural statue because equal rights in participation and decision making is the
cornerstone of this country's government, not in keeping the train running on time.
We believe the standing in this case comes from the contention that Mass DOT violated
The National Environmental Polfcy Act (NEPA) of 1969, as amended, [42 USC§ 43214347] and that Mass DOT violated public engagement of the Green Line Extension
{GLX) project leading up to the preparation of the Environmental Assessment for NEPA
review based upon rules and regulations of the Americans with Disabilities Act (ADA), an
accompaniment to the Civil Rights Act of 1965 and upon rules and regulations of Title VI.
And that these civil rights violations led to constitutional infringements used by Mass
DOT to deprive these civil rights protected groups of their rights to be represented, to
fully know and to participate in government decisions equally as required by United
States Constitution's, Thirteenth Amendment, Section 1. and subsequent violation of the
Americans with Disabilities Act of 1990, Section 504 of the Rehabilitation Act of 1973,
and the Department of Transportation's implementing regulations at 49 CFR Parts 21,
27. 27 and 38 and Title VI.
Mass DOT was put on notice of the Praintiffs environmentar concerns and constitutionar
infringement positions well before the above referenced complaint was instituted. Mass
DOT failed to address these concerns of injury in fact and quality of life issues which are
1
FTA EJ Webpage, Page 4, .Environmental FAQs, Section 13
3
guaranteed by the constitution. We contend that the Mass DOT bullied the due process
to G.LAM members .reque.s.t to .separate out diesel particulate matter impact damage in
air quality and health impact studies with a result that now we may not find out for
decades the true impact of the health impacts upon ourselves and for others who cannot
afford to come forward.
For GLAM the Green Line lawsuit has always been a David and Goliath case as it can
costs $150k to $250k to judicate for the plaintiffs, something many working and low
income people such as in GLAM's membership cannot afford in protecting their
environmental interests and civil rights. A lawsuit of which we are aware is innovative
and precedent setting in bringing civil rights laws into application with environmental law.
In the FTA OCR's Title VI compliance review final report, dated October 2011, Mass
DOT was found deficient in ei.ght of twelve Title VI compliance requirements of which
Inclusive Public Participation was among the deficiencies noted. The ADA compliance review appears not yet to have been released although the FTA has noted issues within
its Preliminary Engineering (PE) approval letter dated June 11, 2012 regarding ADA and
lingering issues continuing on Title VI.
In Massachusetts v. Watts, 716 E 2d 946, 947, 13 ELR 20893 (1st Cir. 1983), then
Judge Breyer of the First District Court made a key finding concerning irreparable harm
when NEPA violations occur. "... NEPA is designed to influence the decision making
process; its aim is to make government officials notice environmental considerations and
take them into account. Thus, when a decision to which NEPA obligations attach is
made without the informed environmental consideration that NEPA requires, the harm
that NEPA intends to prevent has been suffered."
We contend that within the NEPA statute that irreparable harm as been done within the
decision making process of the proposed Green Line Extension project in the form of
ADA civil rights violations and now as evidenced in the Compliance Review final report
for Title VI and PE concerning public participation plan deficiencies.
In Sierra Club v. Marsh, 872 F. 2d 497, 498, 19 ELR 20931, (1 st Cir. 1989), where it
.was held .tbat an .EIS was .required, .then Justice.Breyer.rejected the view .that irreparable
environmental injury meant only physical harm. He states, "We did not (and would not)
characterize the harm described as a "procedural" harm, as if it were a harm to
procedure (as the district court apparently considered it). Rather, the harm at stake is a
harm to the environment, but the harm consists of the added risk to the environment that
takes place when governmental decision makers make up their mind without have
before them an analysis .(with .prior public comment) of the likely affects of their decision
upon the environment. NEPA's object is to minimize that risk." And we contend that
when civil rights are violated as with the ADA or Title VI within the NEPA process this is
an irr~parable harm to the environment and its human environment and not harm to
procedure.
NEPA embodies the Plaintiffs environmental civil rights by requiring agencies to analyze
and discl.o.se .information .relev.aat to a decision, .and .to .inv.olve .the diverse public .in its
decision-making process. Mass DOT failed to acknowledge or analyze diesel impacts to
local air quality and they have not identified diesel hot spot areas with identified
mitigation. Mass DOT has not separated out diesel particulate matter (DPM) impacts ill
their analysis from ambient particulate matter pollution in the EA. They have arbitrarily
4
and capriciously chosen which location they would chose to analyze instead of
.identifying D.PM .measurements along the .length of the corridor and its cumulative effects
within the ecosystem nexus. In performing the analysis for the EA, Mass DOT we
contend failed to determine local air quality data around DPM. By failing to do so, it failed
to assess the intensity of potential environmental harm impacts, or to identify mitigation
measures that could be taken.
The federal court has dismissed GLAM's issue as GLAM could not afford a retainer of
$150k to $250k to fight their issue. Ms. Carolyn Rosen and Dr. William Wood's portion
of the lawsuit has not been decided but is under review. The court has agreed that the
College Avenue terminus is the mandated site for the proposed Green Line under the
SIP of which we did not disagree as the final place since our contention is over civil
rights participation of the protected class communities of ADA and Title VI and the fullest
extent of environmental protection. Why the state Attorney General never wanted to
mitigate Title VI and the ADA and the Governor's Executive Order pertaining to those
rights prior to their need to vilify Justice Br.eyer's pro environmental position and civil
rights protection we cannot understand.
These comments are respectfully submitted by Carolyn Rosen and Dr. William Wood
and GLAM's Executive Committee.
··-
~
~
Chairperson
/
G~
5
From:
To:
Cc:
Subject:
Date:
Attachments:
Emily Long
Fichter, Katherine (DOT); jerome.grafe@state.ma.us
cooke.donald@epa.gov; Rafael Mares
CLF Comment Ltr - Re: 2013 SIP Transit Commitments Status Report
Thursday, September 12, 2013 3:47:52 PM
CLF 2013 SIP Status Report Comment Letter Sep 2013 Final.pdf
Dear Ms. Fichter and Mr. Grafe:
Attached please find a copy of CLF’s comments on the 2013 State Implementation Plan Transit
Commitments Status Report. If you have any questions, please feel free to contact Rafael Mares.
Thank you for your attention to this matter.
Sincerely,
Emily Long
Emily Long
Program Assistant
Conservation Law Foundation
62 Summer Street
Boston, MA 02110
P: 617-850-1719
E: elong@clf.org
For a thriving New England
September 12, 2013
Katherine S. Fichter
Massachusetts Department of Transportation
Office of Transportation Planning
10 Park Plaza, Room 4150
Boston, Massachusetts 02116
Jerome Grafe
Massachusetts Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street
Boston, MA 02108
RE: 2013 State Implementation Plan Transit Commitments Status Report
Dear Ms. Fichter and Mr. Grafe:
The Conservation Law Foundation (“CLF”) has reviewed the State Implementation Plan
(“SIP”) Transit Commitments Status Report filed on July 1, 2013 (“2013 SIP Status Report”).
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. This is
particularly important in light of recent evidence demonstrating a significant association between
ozone exposure and cardiovascular mortality.1
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
1
See Michael Jerrett, PhD, et al., Spatial analysis of Air Pollution and Mortality in California (American Journal of
Respiratory and Critical Care Medicine, June 2013).
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). Such further interim offset projects or measures should be identified through a
transparent and thorough community public participation process. In addition, CLF repeats its
request that DEP require a mid-year status report to be filed by MassDOT by December 31,
2013, on the Fairmount Line Improvements, the Green Line Extension, the construction of 1,000
additional parking spaces, the design of the Red Line/Blue Line Connector, and the Blue Line
Platform Lengthening and Modernization, since all of these projects, despite significant progress,
remain behind schedule. 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.
Green Line Extension
Since last year’s SIP status report was released, MassDOT and the MBTA have received
full federal environmental approval for the Green Line Extension project. The Federal Transit
Administration (“FTA”) released a Finding of No Significant Impact (“FONSI”) for the project.
In December of 2012, a groundbreaking was held in Somerville for the Green Line Extension.
MBTA has also secured a construction manager/general contractor earlier this summer. 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. MassDOT provides no explanation for the additional nineteen months
delay in its petition to DEP, its 2011 and 2012 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.
2
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). In the past, 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 any interim offset projects or measures. CLF together with
other stakeholders, in a letter dated September 22, 2010, provided a list of suggested interim
offset projects and measures to MassDOT. CLF was pleased to see that MassDOT considered
and analyzed many of these suggestions, but unfortunately not all of them. Specifically, the
following feasible and effective suggestions were not analyzed, or at least such analysis was not
reflected in a public document: signal prioritization for buses on high usage streets in Somerville,
Medford, and Cambridge; improved pedestrian crosswalks and signal timing at Monsignor
O’Brien Highway and Land/Gilmore bridge; removing elevated portions of the McGrath
highway and converting a portion of the right of way to bike/bus only lanes; and instituting free
or reduced Hubway bicycle memberships for residents within half a mile of future Green Line
stations. These interim offset projects and measures should be analyzed so that they can be
considered as options for implementation.
Ultimately, all interim offset projects and measures should be located in the
neighborhoods that are intended to benefit from emissions reductions attributable to the Green
Line Extension project. While CLF recognizes that keeping the interim offset projects and
measures in the same neighborhoods as the delayed transit commitment is not a legal
requirement of the SIP, we strongly believe that failing to adhere to this approach would be
patently unfair. CLF therefore strongly recommends that all interim offset projects and measures
considered be located in and serve the Somerville, Medford and Cambridge neighborhoods that
are adjacent to the extension of the Green Line. All interim offset projects and measures shall
achieve emission reductions equal to or greater than the emission reductions that would have
been achieved had the project not been delayed.
Repeating the previous three years’ SIP Status Report omission, the 2013 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). 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 hope that the
3
Transportation Finance Act which passed on July 24, 2013 will address the MBTA’s budgetary
needs sufficiently and thereby remove this obstacle.
CLF continues to be troubled by the proposed segmentation of the Green Line Extension
Project and its assertion that “[c]ompletion of Phase 4 also represents completion of the Green
Line Extension project.” 2013 SIP Status Report at 20. 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 two 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 welldocumented 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.
Fairmount Line Improvement Project
CLF was excited to experience the opening of three of the four new stations on the
Fairmount Line this year. It was an honor and pleasure to attend the ribbon-cutting on July 17,
2013. CLF was also delighted to see the implementation of a pilot project through which the
MBTA introduced a new fare structure for the Fairmount Line. 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, will now have the same $2 fare as a subway
trip as a pilot project that will last for at least two years. This represents a 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 two years ago the MBTA
anticipated construction of the Blue Hill Avenue Station to start by May of 2012, last year’s and
this year’s update state that “it is unlikely that the Blue Hill Avenue Station will be completed
before 2015 at the earliest.” See 2012 Status Report at 5 and 2013 Status Report at 5. While
2
For a more detailed explanation of this issue, please see CLF’s comments on the Draft and Final Envir onmental
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
_20100615.pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf
respectively.
4
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
Status Report based on the mistaken assertion that this requirement has been completed. While
MassDOT has succeeded in bringing this SIP requirement close to completion, CLF cannot agree
that the Commonwealth has fulfilled it.
Last year, CLF commented that due to the multi-use nature of the Waterfront Square
development at Wonderland, the number of parking spaces actually available for users of the
MBTA’s public transit system will be smaller than predicted and therefore too small to
contribute sufficiently to SIP compliance. South Garage was constructed adjacent to the
Waterfront Square development at Revere Beach, which will include new retail outlets,
residential units, offices and a hotel. In addition to the existing public beach, these new
buildings constitute a significant draw for automobile traffic. There is therefore a strong need to
ensure that sufficient parking is reserved for MBTA customers. As planned, South Garage
includes parking for MBTA customers, but not all spaces in the garage are reserved for transit
riders. See MBTA South Garage Environmental Assessment (dated January 11, 2010) at 1-2.
The only way to ensure that a parking garage that serves more than just a commuter transit
facility consistently has enough space available for transit riders is to reserve a specific number
of parking spaces for MBTA customers at all times and implement a system, such as parking
ticket validation, which enforces such restriction. From the MBTA’s website, it continues to
appear, however, that no such plans have been put into place for South Garage. See
http://www.mbta.com/schedules_and_maps/subway/lines/stations/?stopId=15415&lat=42.41396
3&lng=-70.990986 (last visited September 3, 2013). The contribution of sufficient transit
commuter parking spaces from South Garage to meet the SIP requirement can therefore not be
guaranteed.
In response to CLF’s comments last year, MassDOT acknowledged that this concern is
valid. See Agency Response to Public Comments to 2012 Status Report, p. 8. The MBTA
apparently has worked closely with the private developer and has entered into an agreement that
specifies the number of spaces that will be available for transit users. Id. at 8. This agreement
should be made available to the public. MassDOT also stated that to ensure that the spaces
dedicated for MBTA users are, in fact, reserved and available for MBTA riders, the MBTA and
private developer will enforce the agreement within the garage, through signage, dedicated
spaces, and internal gates. Id. Until such signage, dedicated spaces, and internal gates are in
5
place, however, MassDOT should continue to report on this SIP requirement in its status reports,
and should not count all of the parking spaces in the garage towards its fulfillment.
In addition to South Garage at Wonderland, MassDOT is also counting almost four
hundred existing parking spaces in Beverly, Dorchester, Newton and Quincy towards this transit
commitment. To comply with the SIP requirement, however, 1,000 additional parking spaces
have to be constructed rather than merely provided. See 310 CMR 7.36(2)(h)2 (“Before
December 31, 2011, construction of the following facilities shall be completed and opened to full
public use:…1000 new park and ride parking spaces serving commuter transit facilities…”)
(emphasis added). The parking spaces near the Beverly commuter rail station, at least, appear
only to have been opened to the public but were not newly constructed.
MassDOT in its response to CLF’s comments last year admitted that the SIP regulation
uses the term “construction.” Id. Nevertheless, it ceased to provide updates on this requirement
and has not committed to the construction of the remaining spaces. Instead it relies on its own
interpretation of the intent of the regulation rather than its actual language, which is not
permissible.
We therefore urge DEP to require MassDOT to address these issues and to continue
reporting on this requirement in SIP status updates until there is full clarity that it has been
completed. In addition, until all of the 1,000 additional parking spaces are constructed, opened
to, and reserved for transit commuters, an interim offset project or measure should be put in
place. MassDOT previously implemented increased Saturday bus service on MBTA Route 111
as an interim offset; this measure should be reinstated.
Blue Line Platform Lengthening and Station Modernization
MassDOT failed to include the Blue Line Platform Lengthening and Station
Modernization project in its 2012 and 2013 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
6
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
September of 2013, the following stations have been modernized: Aquarium, Beachmont,
Revere Beach, Suffolk Downs, Wood Island, Wonderland, Maverick, and State. The difference
in appearance of the stations that have been completed speaks volumes for the importance of this
requirement.
We are pleased that construction at the Orient Heights Station continues to be in progress.
This project will make the station fully accessible to all passengers as well as make large scale
improvements to modernize the station. The work includes installation of a new overhead
pedestrian bridge, four elevators and two escalators, new mechanical and power systems, a
renovated Train Operations Building and improvements to the bus access areas. CLF is
particularly pleased that the Orient Heights Station Project has been designed to be consistent
with MassDOT′s “GreenDOT” policy. The MBTA has indicated that it expects the station to be
reopened in mid-October of 2013 and the project to be completed by the spring of 2014.
Likewise, CLF appreciates that the modernization of the Government Center station is scheduled
to begin in 2014.
The delays in modernizing the Orient Heights, 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.
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).
7
Red Line-Blue Line Connector
The Commonwealth included in its 2008 revised SIP the design of the Red/Blue Line
Connector (“Connector”), recognizing and relying on the associated air quality benefits. Two
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
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. DEP
should therefore reject MassDOT’s flawed logic and should not amend the Transit System
Improvement Regulations, as recently proposed.4
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.
4
CLF has commented separately on the proposed amendment of the Transit System Improvement Regulations both
orally at a September 13, 2012 public hearing and in writing in a letter dated September 14, 2012.
8
Thus designing a transit project, more than anything else, raises its chances of ever being built.
One new opportunity for potential funding, for example, which CLF raised in its comments last
year, to the best of our knowledge, the Commonwealth has not pursued it yet. The
Commonwealth should request that the owners and developers of the proposed casino at Suffolk
Downs contribute significantly to the Connector as a condition precedent to proceeding with
their project.
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 two 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
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.
9
Amending the Transit System Improvement Regulations 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 regulations to provide for a deadline extension.
To evaluate any potential substitution, DEP should require MassDOT to remodel the air quality
benefits expected from the projects in the revised SIP and then compare them to those of the
remaining transit system improvement projects without the Connector. For the reasons stated
above, we respectfully request that DEP not amend the Transit System Improvement
Regulations, as currently proposed and require MassDOT to continue to include this project in its
SIP update reports.
Conclusion
The continued projected delays for the Green Line Extension, the delayed construction of
one new station on the Fairmount Line, the claim that all the 1,000 additional park and ride
parking spaces serving commuter transit facilities have been constructed, the failure to
acknowledge that the Green Line Extension as planned does not comply with the SIP, the request
to eliminate the requirement to design the Red Line/Blue Line Connector, 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
Staff Attorney
cc
Donald Cooke
Air Technical Unit
US Environmental Protection Agency - Region 1
5 Post Office Square, Suite 100
Mail Code OEP05-2
Boston, MA 02109
10
From:
To:
Subject:
Date:
Matthew Danish
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
2013 State Implementation Plan
Monday, September 16, 2013 7:58:37 PM
To whom it may concern:
It is disappointing to see MassDOT try to renege the Red/Blue
connector design pledge. The Red/Blue connector is important for the
residents of East Boston and also for taking pressure away from the
four central transfer stations, particularly Government Center-Park
Street. I suggest that the design pledge be maintained into the
future, but in the mean time some other possibilities ought to be
considered. The cheapest and easiest workaround, especially with the
Government Center shutdown pending, is to implement an out-of-system
transfer that at least allows Blue Line riders to access the Red Line
at Downtown Crossing or at Park Street. Another, albeit more
difficult, possibility would be to explore an underground concourse
connecting Downtown Crossing to State Street station, along Washington
Street, starting from approximately Bromfield Street and extending
north about a half-block. It may also be a good idea to explore
various kinds of bus connections which serve the Red/Blue connecting
market, for example, Maverick to Charles, or a complement to the
Silver Line serving Chelsea which also serves East Boston more
usefully.
Regarding the Green Line extension, it is clear that the deadline will
not be met, therefore some make -up projects ought to be considered.
Free access to Hubway is one idea for residents in the vicinity of
future stations. Also free bus passes. And at least, consider putting
additional trips onto the bus routes which serve the neighborhoods in
the vicinity of future stations. A new route which attempts to
replicate at least some of the future GLX service could be a useful
tool for both providing mitigation and beginning the process of route
priming: putting the forces into motion which generate ridership, so
that on opening day there will be a strong constituency already
prepared to use the GLX as a travel mode, instead of having to build
it up for several months.
Regarding the parking lots at commuter rail stations: I realize that
this is past and done, but I would like to make a comment: it was a
major mistake to put "parking lots" of any sort as an air quality
mitigation method. Parking lots induce automobile traffic, induce car
exhaust, and air pollution knows no boundaries. Unfortunately, the
1000 new parking space mandate has produced some very bad urban design
at and around commuter rail stations. Those communities will be
suffering for years because of added traffic and exhaust, and those
parking lots will plague any effort to improve the surroundings of the
stations. A better idea would have been to require the development of
walkable, mixed-use communities around appropriate commuter rail
stations. Those could have formed the seeds of cleaner, less
automobile-dependent neighborhoods, of a cleaner, less
automobile-dependent region, and that is ultimately the key to better
air quality and less pollution.
Matthew Danish
Boston resident
From:
To:
Subject:
Date:
Elisabeth Bayle
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
Public comment on State Implementation Plan (SIP) Transit Commitments 2013 Status Report - Green Line
Extension
Wednesday, September 18, 2013 9:06:48 PM
As a Medford resident and homeowner in Medford Hillside who has been actively attending Green
Line Extension meetings and commenting at almost every public opportunity since 2006, I have to
express my extreme disappointment at the dim prospects for building the Green Line Extension to
Route 16, which MassDOT determined through an exhaustive (and exhausting) process was the
preferred build alternative for the terminus out of several that were studied.
The SIP Requirement is stated as follows (p. 10): “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...”
The current SIP Status Report estimates completion to the temporary College Avenue terminus
(which does not reach Medford Hillside) by end of July 2019.
Meanwhile many thousands of area residents are going without the promised affordable, clean,
efficient transportation and cleaner environment that they need and deserve. I hope that some
remedy for this regrettable situation can be found.
I continue to emphatically support the funding of the Green Line Extension project, and, in
particular, funding to continue planning for the Mystic Valley Parkway/Route 16 terminus to be built
with all deliberate speed.
While the entire Green Line Extension offers long overdue transportation improvement to multiple
communities, the Route 16 terminus is critical to its success for the following reasons:
1. The Green Line Extension project is legally mandated to serve Medford Hillside, and the
Route 16 terminus does so, whereas the “temporary” terminus at College Ave. does not. (The
College Ave. terminus will exacerbate the air quality issues in Medford Hillside by drawing
additional traffic through its residential areas to get to that station – completely counter to
the aims of the Extension project to improve air quality.)
2. The Route 16 terminus offers robust opportunities for much-needed transit-oriented
development in an environmental justice community, whereas the aptly named College Ave.
station is surrounded by Tufts-owned land with no opportunity for such development.
3. The Route 16 terminus extends frequent, affordable, non-polluting public transportation to a
much greater population, including parts of Medford, Somerville, and Arlington, which is why
over 2,000 residents of those communities signed a petition in favor of the station when
MassDOT was deliberating over the various build alternatives.
Due to the substantial and unfortunate delays in the project, I may be too old to enjoy its benefits,
but I know the Green Line Extension to Mystic Valley Parkway/Route 16 will be an essential
ingredient in building a much healthier and more productive future in Medford Hillside and
surrounding communities for generations to come. I urge you to continue strong support for this
project, accelerating timelines wherever possible and maximizing funding sources such as New
Starts.
Best regards,
Elisabeth Bayle
34 Emery St.
Medford, MA 02155
Supporting links:
For research thoroughly documenting the location of Medford Hillside, please see
https://www.box.com/shared/t499nbnoa8.
To review the results of the excellent, community-based visioning study on the opportunities for
transit-oriented development near the Route 16 station site done by the Metropolitan Area
Planning Council, see their final 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.
To see the petition with signatures from residents supporting the Route 16 station, see
http://www.petitiononline.com/petitions/MGNA16/signatures.
From:
To:
Subject:
Date:
Attachments:
John
Fichter, Katherine (DOT); jerome.graff@state.ma.us
Red-Blue Connector: Proposed Amendments to 310 CMR 7.36
Wednesday, September 18, 2013 11:13:12 PM
2013-09-18 Sierra Club - Red-Blue Connector.doc
2012-09-24 Sierra Club on Red-Blue.doc
Ms. Kate Fichter, MassDOT
Office of Transportation Planning
Ten Park Plaza, Room 4150
Boston, MA 02116
Mr. Jerome Grafe
Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street, 6^th Floor
Boston, MA 02108
Re:Proposed Amendments to 310 CMR 7.36
Central Artery Mitigation Transit Commitments
The Massachusetts Chapter of the Sierra Club wishes to reiterate its
strong and continuing support for the remaining Air Quality Mitigation
Transit Commitments, which the Commonwealth has agreed to as part of its
1990 settlement as a condition for building the Central Artery/Tunnel
Project.We remain opposed to the Massachusetts Department of
Transportation’s renewed attempt to abandon the final design process for
the Red Line/Blue Line Connector between Government Center and Charles
stations, which would finally provide a direct connection between these
two transit lines and obviate the need for a pair of awkward transfers
in its badly congested downtown core.
I am resubmitting the comments that we prepared one year ago when
MassDOT was similarly applying to be released from this
requirement.Little has changed, and the need for this connection remains
as critical now as it was then.Indeed, the added congestion that is sure
to occur at the three remaining subway transfer stations during the
upcoming two -year shutdown of Government Center to bring it into
compliance with the Americans with Disabilities Act will only further
demonstrate the need for more—not less—connectivity among our four
transit lines.
Thus we feel it is unconscionable for the state to abandon this
Commitment, and once again we urge the Massachusetts Department of
Environmental Protection to do its duty and retain this requirement.
Respectfully submitted,
John Kyper, Transportation Chair
Sierra Club, Massachusetts Chapter
Enclosure
Massachusetts Chapter
September 18, 2013
Ms. Kate Fichter, MassDOT
Office of Transportation Planning
Ten Park Plaza, Room 4150
Boston, MA 02116
Mr. Jerome Grafe
Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street, 6th Floor
Boston, MA 02108
Re: Proposed Amendments to 310 CMR 7.36
Central Artery Mitigation Transit Commitments
The Massachusetts Chapter of the Sierra Club wishes to reiterate its strong and continuing support
for the remaining Air Quality Mitigation Transit Commitments, which the Commonwealth has agreed to
as part of its 1990 settlement as a condition for building the Central Artery/Tunnel Project. We remain
opposed to the Massachusetts Department of Transportation’s renewed attempt to abandon the final
design process for the Red Line/Blue Line Connector between Government Center and Charles stations,
which would finally provide a direct connection between these two transit lines and obviate the need for a
pair of awkward transfers in its badly congested downtown core.
I am resubmitting the comments that we prepared one year ago when MassDOT was similarly
applying to be released from this requirement. Little has changed, and the need for this connection
remains as critical now as it was then. Indeed, the added congestion that is sure to occur at the three
remaining subway transfer stations during the upcoming two-year shutdown of Government Center to
bring it into compliance with the Americans with Disabilities Act will only further demonstrate the need
for more—not less—connectivity among our four transit lines.
Thus we feel it is unconscionable for the state to abandon this Commitment, and once again we urge
the Massachusetts Department of Environmental Protection to do its duty and retain this requirement.
Respectfully submitted,
John Kyper, Transportation Chair
Sierra Club, Massachusetts Chapter
Enclosure
10 Milk Street Suite 632 Boston MA 02108 tel: 617.423.5775 fax: 617.423.5858 www.sierraclubmass.org
Massachusetts Chapter
September 24, 2012
Mr. Jerome Grafe
Department of Environmental Protection
Bureau of Waste Prevention
One Winter Street, 6th Floor
Boston, MA 02108
Re: Proposed Amendments to 310 CMR 7.36
Central Artery Mitigation Transit Commitments
The Massachusetts Chapter of the Sierra Club strongly supports the remaining Air Quality Mitigation Transit
Commitments, which the Commonwealth has agreed to as part of its 1990 settlement as a condition for building the
Central Artery/Tunnel Project. For those who live or work in the city and depend on public transportation every
day, they remain as vital now as when they were first negotiated. We firmly believe that enlightened, responsible
transportation policy, especially in a compact, congested urban area, should discourage use of the private automobile
and encourage the utilization of more benign alternatives like transit, walking and bicycling.
Thus we are appalled by the Massachusetts Department of Transportation’s proposal to turn its back on yet
another of the Mitigation Transit Commitments still outstanding under the State Implementation Plan: It seeks to
abandon the final design process for the Red Line/Blue Line Connector that would extend the MBTA’s Blue Line
under Cambridge Street to Charles station, which would at last provide a direct transfer between these two transit
lines.
The Sierra Club has long advocated for the proposed Red/Blue connection between Bowdoin Square and
Charles. We believe that this link would be of great benefit to the passengers who regularly travel these two transit
lines, as well as to riders on the other lines who must use the downtown transfer stations. For those who depend
upon the Red Line or the Blue Line, the benefits are the most obvious: Travelers coming from Cambridge, Dorchester or Quincy would have to endure one less transfer to reach the Airport. Residents of East Boston and Revere visiting Massachusetts General Hospital or its many associated clinics and doctors’ offices would save themselves two transfers, for a one-seat ride to their destination. The connection would also further the aims of environmental justice, connecting jobs-rich Kendall Square with more affordable housing north of Boston. This list
could go on.
Benefits for other subway riders are equally evident: I live in Roxbury and work in Government Center, relying on the Orange Line every day. Frequently on my way home when I board the Forest Hills train at State station,
I encounter people arriving from the Airport and carrying heavy baggage who must also squeeze their way onto the
already crowded train—often to go just one stop to change again at Downtown Crossing. (The overcrowding is so
bad that I often avoid State and go out of my way to board at Haymarket.) Both they and we would be better
served by construction of the Connector, which would allow them a direct transfer to the Red Line while reducing
congestion at the existing downtown transfer stations.
The MBTA has claimed that the new “Silver Line” bus from South Station to the Airport obviates the need for
the link underneath Cambridge Street. This ride, however, is slow, bumpy and unreliable, frequently getting delayed
by traffic in the Ted Williams Tunnel and causing many Red Line Airport travelers to vote with their feet and continue to use the Blue Line. Too, the bus is of no use to people who live or work in East Boston or Revere and want
to reach the Red Line or destinations like Mass. General. Future development along the Blue Line corridor, like the
casino planned at Suffolk Downs, is almost certain to increase its ridership. While casino promoters anticipate that
the majority of its patrons will be arriving by car, it is only fair to assume that a sizable minority will arrive by T, as
will many of its workers.
10 Milk Street Suite 632 Boston MA 02108 tel: 617.423.5775 fax: 617.423.5858 www.sierraclubmass.org
Massachusetts Chapter
The Connector is not a frill but a badly needed addition to the T system. We also need to consider the future
of the Blue Line, the shortest of the MBTA’s four transit lines and the only one terminating in downtown. Extending it to Charles cannot fail to increase its ridership—especially if the Line is ever extended on the other end to Lynn
—fueling the need for more interconnectivity with the rest of the system. Over the years there have been various
proposals to extend the Blue Line to the west, most notably to Kenmore Square and beyond, to relieve pressure on
the overburdened Green Line through the Back Bay. These possibilities need to remain on the table and not be
precluded by short-range financial considerations that are now being used to dictate the short-sighted “solution” of
abandoning the Connector. Boston has long styled itself as a “world class city.” Such a failure to invest in our own
future would mock these aspirations. It would be tantamount to a declaration of economic defeat, a pathetic admission that we’re not as competitive as we had once liked to believe.
After lavishing ever more money on the Central Artery project ($24 billion and counting!), it is interesting to
hear the state now plead poverty in an attempt to wiggle out of another one of its 1990 Commitments. Far from
being an extraneous add-on burdening its bottom line, these Commitments speak to the need to enhance transportation options for those of us who live or work in the Boston area. It is instructive to note that while the Commonwealth expands transit and commuter rail lines in all directions away from the center, it has systematically neglected any expansion to its downtown core—and the MassDOT application does not even bother to list any proposed remediation for failing to meet its deadline for designing the project. This imbalance of priorities must stop!
It urgently behooves MassDOT to continue the planning for this link against the day that the money becomes available for its construction; if the final design of the Connector is never completed, we will not have any data on its
costs should the occasion for funding it arise. Such lack of foresight has already prevented the MBTA from taking
much advantage of the American Recovery and Reinvestment Act of 2009 (the “Stimulus package”) because it had
precious few projects on the table that were “shovel ready.”
In recent months the local press has carried numerous articles, letters and Opinion pieces addressing the nexus
between the mushrooming cost of the Big Dig and the desperate state of our chronically underfunded and crumbling transit infrastructure. Most notable of these was “Surging ridership could overwhelm T” (June 14 Globe,
http://www.bostonglobe.com/metro/2012/06/14/surging-mbta-ridership-could-overwhelm-system-reportwarns/gIaIU4WgfyKpTWC1AodmoK/story.html).
In contrast with comprehensive metro networks in cities like London or Paris or New York that cover far
more of their metropolitan areas, Boston’s rapid transit system can be best described as skeletal, with too many riders funneling into too few lines. At the very least, capacity in the downtown core needs to be significantly expanded,
with service extended into many underserved areas, like central Roxbury and northern Dorchester. Sadly, we could
have greatly improved the scope and coverage of our public transit system for a mere fraction of the cost of the
overruns of the Big Dig. Given the expansion of commuter rail service and park and ride lots over the past two
decades, primarily to serve suburban riders, the state’s protestations of inadequate funding are actually a judgment
that it views those of us living in the inner city who depend on its services every day—its “captive audience,” so to
speak—as second-class citizens.
DEP, do your duty as public servants: This Central Artery Mitigation Transit Commitment must stand.
Respectfully submitted,
John Kyper, Transportation Chair
Sierra Club, Massachusetts Chapter
10 Milk Street Suite 632 Boston MA 02108 tel: 617.423.5775 fax: 617.423.5858 www.sierraclubmass.org
From:
To:
Subject:
Date:
Attachments:
Ken Krause
Fichter, Katherine (DOT); "Grafe, Jerome (DEP)"
SIP Annual Status Report comment letter
Thursday, September 19, 2013 1:06:11 AM
13SIP_AnnRpt-Krause.pdf
Please find attached a comment letter on the State Implementation Plan – Transit Commitments
2013 Status Report.
Thank you.
- Ken Krause
+++++++++++++++++++++
Ken Krause
50 Mystic St.
Medford, MA 02155
781-396-0920
Kenneth J. Krause
50 Mystic Street Medford, MA 02155
781-396-0920 kenneth.krause@comcast.net
September 19, 2013
Kate Fichter
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 Ms. Fichter and Mr. Grafe,
Thank you for the opportunity to comment on the annual update and status report for
transit projects required by 310 CMR 7.36(7) that was submitted by the Massachusetts
Department of Transportation (MassDOT) to MassDEP on July 1, 2013.
Green Line Extension to Somerville and Medford
The past year marked an important and much welcomed turning point in the Green Line
Extension (GLX) project as construction began on Phase I. Other positive developments
as stated in the report were the completion of Advanced Conceptual Design; the start of
Advanced Preliminary Engineering and Final Design (APE/FD); completion of a value
engineering workshop by the Owner’s Representative procured by the MBTA; and
completion of the GLX Relocation Plan.
In less than one year, the APE team, working with HDR/Gilbane, has made notable
progress in improving the project, with several changes likely to reduce its
environmental impact:
•
Redesign through value engineering and other methods to reduce the size of the
stations by up to 10%.
•
An increase in station bicycle parking of 50% over the commitment in the
Environmental Assessment
•
A new route for the Community Path extension near Washington Street Station
that led to an MBTA commitment to a complete design of the path to the North
Point/Charles River paths, an important connection that previously was missing
•
Major infrastructure repairs associated with the Harvard Street rail bridge
reconstruction in Medford that will address serious flooding problems in the area
Kenneth J. Krause - 2013 SIP Annual Report
The work of the APE/FD team bodes well for a smooth handoff of the Final Design for
the CM/GC team that will execute the construction of Phases 2 through 4 of the GLX.
One notable absence in the annual report was any reference to the MassDOT Preferred
Full Build Alternative terminus station on the Medford Branch 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, with this year $29.9 million being programmed for
Federal Fiscal Year 2017 in the 2014-17 Transportation Improvement Program:
In its response to public comments on last year’s SIP annual report, dated January 23,
2013, MassDOT acknowledged the MPO’s action, adding: “This funding becomes
available in 2016, and MassDOT and the MBTA will begin working on this effort as that
timeframe draws closer.”
With the start of FFY2016 only 24 months away, MassDOT should be referencing the
Route 16 phase of project in both its annual and monthly status reports, and also
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. Rather, the report states
that “Completion of Phase 4 [College Avenue Station] also represents completion of the
Green Line Extension project.” This statement should be clarified to state that it pertains
only to the portion of the GLX in the SIP.
Finally, I encourage MassDEP to ensure a robust public review process for the interim
mitigation measures required to be implemented by MassDOT by December 31, 2014,
the legal deadline for GLX implementation. There were many very worthwhile projects
Kenneth J. Krause - 2013 SIP Annual Report
submitted for analysis that could have far-reaching environmental impacts, including
completion of the Mystic River Reservation multi-use path in Medford, and accelerating
design and construction of the Somerville Community Path and other paths in the
regional network.
While the completion delay for the GLX is disappointing, interim offset measures that
ultimately will complement and feed the Green Line Extension will make the project that
much more successful in improving regional mobility, air quality, and achieving other
environmental benefits.
Red Line/Blue Line Connector Design
I again urge MassDEP to deny MassDOT’s request to be relieved of its legal obligation
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 that has been created or is under development in Cambridge, South
Boston, and East Boston. And since last year’s annual report, a second proposed
casino development, on the Mystic River in Everett, has joined Suffolk Downs in
competition for a gaming license. A casino development in either of these locations
would have major environmental impacts that could in part be mitigated by improved
public transportation service, including the Red/Blue Connector, an immensely valuable
project that is integral to the efficiency of the MBTA system and its ability to meet
increasing ridership demands.
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 which, 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 Mohler, Chair, Boston Region MPO
Richard Davey, Secretary of Transportation
Kenneth J. Krause - 2013 SIP Annual Report
From:
To:
Cc:
Subject:
Date:
Attachments:
Friends of the Community Path
Fichter, Katherine (DOT); jerome.grafe@state.ma.us
Patricia.Jehlen@state.ma.us; denise.provost@MAHouse.gov; Timothy.Toomey@mahouse.gov;
carl.sciortino@state.ma.us; Tim.Snyder@masenate.gov; mark.kennedy@mahouse.gov;
William.Sutton@mahouse.gov; Raffi.Freedman -Gurspan@mahouse.gov; daniel.weber@mahouse.gov;
alan@pathfriends.org; reisnere51@gmail.com; Hayes Morrison ; Sarah Spicer City of Somerville
Re: FCP DEP/SIP Comments (due by today)
Thursday, September 19, 2013 9:26:18 AM
FCP SIP Comments to DEP Sep 2013.pdf
To the Kate Fichter and Jerome Grafe:
Please accept these comments, on behalf of the Friends of the Community Path, to the DEP on annual
State Implementation Plan (SIP) Transit Commitments report:
http://www.massdot.state.ma.us/Portals/17/docs/sip/2013%20SIP%20Annual%20Report%20%20final.pdf
These comments regard our support of the GLX, CPX, Fairmount Line, Red-Blude Connector and GLX
Mitigation projects.
As I understand it, the DEP SIP comment deadline is today, 9/19, at 5:00 pm.
Thank you,
Lynn Weissman and Alan Moore
Friends of the Community Path
facebook.com/FriendsoftheCommunityPath
http://www.pathfriends.org/scp/join.html
twitter.com/pathfriends
617.776.7769
------------------------------------------------------------------------The mission of the Friends of the Community Path is
to link the Minuteman Bikeway and Charles River Path networks,
by extending the Community Path along the future Green Line extension.
"To Lechmere... and Beyond!!"
Friends of the Community Path
112 Belmont Street, Somerville, MA 02143
617.776.7769
friendspath@yahoo.com
facebook.com/FriendsoftheCommunityPath
twitter.com/pathfriends
Kate Fichter
MassDOT Office of Transportation Planning, Room 4150
Ten Park Plaza, Boston, MA 02116
Katherine.fichter@dot.state.ma.us
Jerome Grafe
Mass DEP Bureau of Waste Prevention
One Winter Street, Boston, MA 02018
jerome.grafe@state.ma.us
Date: September 19, 2013
Re: DEP SIP Comments in Support of GLX, CPX, Fairmount Line, Red-Blue Connector, and
GLX Mitigation
To Kate Fichter and Jerome Grafe:
We take this opportunity on behalf of the Friends of the Community Path, a regional group with
~1300 members, to comment on the annual State Implementation Plan (SIP) Transit
Commitments report:
http://www.massdot.state.ma.us/Portals/17/docs/sip/2013%20SIP%20Annual%20Report%20-%20final.pdf
Our mission is to extend the Community Path, along the future Green Line Extension (GLX)
route, thus linking the Minuteman Bikeway and Charles River path networks. This 2-mile
Community Path Extension (CPX) will result in ~48 miles of continuous path network through
11 Boston MPO cities and towns, with multi-modal connections to the GLX.
Support for SIP Commitments and Mode Shift to Transit, Walking and Biking
With new state transportation funding legislation largely in place, we’d like to emphasize the
importance of sustainable urban transportation, including transit, walking and biking.
We enthusiastically support the completion of GLX and the Fairmount Line projects, the
major remaining transit commitments 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. However, we do not agree with MassDOT’s recommendation
to stop the design of the Red/Blue connector and eliminate it from the SIP. We hope that the
DEP does not allow this requested change in the SIP.
page 1 of 3 -
Somerville's Orange Line Station at Assembly Square and the Green Line Extension are,
respectively, the first new subway and light rail expansions in a generation. Along with the
Community Path Extension (CPX), these are the most important environmentally clean
mode shift projects underway in the Commonwealth. The CPX will connect multi-use paths
in 11 Boston MPO cities and towns, making for 48 miles of continuous path network, with
multimodal connections.
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.
There are hugely positive local and regions impacts associated with the completion of these longdiscussed projects, including the new Green Line branches to Union Square and Route 16 as well
as completion of the CPX and its full integration with the new GLX transit facilities.
Mitigation Projects for GLX Delay
As the GLX opening will be delayed beyond its current legal deadline, we suggest the following
interim projects that MassDOT should do in the corridor that will fully make up for the delayed
environmental benefits. With regard to selection of GLX offset/mitigation projects, the
Friends of the Community Path urge MassDOT to:
1. - Complete design and construction of the CPX, from Lowell Street all the way to the
paths at Lechmere/North Point. The Community Path is a great regional project that
meets SIP requirements, and MassDOT’s GreenDOT, Healthy Transportation Compact,
and Mode Shift goals. Technically, the interim offset projects can be eliminated once
the GLX is fully operational, but it will be most cost-effective to spend mitigation funds
on projects with permanent benefits, like the CPX!
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. - Provide free transit and Hubway programs during the delay. This will also provide a
financial incentive for timely project completion
page 2 of 3 -
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. Sincerely,
Alan Moore
Lynn Weissman
Co-Presidents, Friends of the Community Path -
page 3 of 3 -
From:
To:
Subject:
Date:
Nina Garfinkle
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT); friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 10:19:57 AM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated area.
Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
We need to put our communities first and figure out multiple says to move people around if we
are to remain economically and environmentally viable. These delays are have been unjust and
amends are required, but really the best solution is required for all of us and this is an end to
that.
Thank you.
Nina Garfinkle
___________________________________________________
Nina Garfinkle | Garfinkle Design | www.ninagarfinkle.com
7 Holyoke Street, Boston MA 02116
T: 617.424.9115 | M: 617.733.4321 | nina@ninagarfinkle.com
From:
To:
Subject:
Date:
resablatman@gmail.com on behalf of resa blatman
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT); friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 10:24:20 AM
Dear Ms. Fichter and Mr. 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you,
Resa Blatman
42 Bartlett Street
Somerville, MA 02145
From:
To:
Subject:
Date:
Kevin Donovan
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT); friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 11:19:33 AM
To Kate Fichter and Jerome Grafe:
I appreciate this opportunity to comment on the annual State Implementation Plan (SIP) Transit
Commitments Report. The projects in this report will prove a critical step to making Massachusetts a
real world economic player, and a better place to live.
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you.
-Kevin Donovan
Mobile: 603 703 3057
Work: 603 669 3100
From:
To:
Cc:
Subject:
Date:
Hayward Zwerling
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 11:25:07 AM
To Kate Fichter and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan
(SIP) Transit Commitments Report.
I support completing the Green Line Extension (GLX) and the Fairmount Line. I
appreciate that MassDOT is moving ahead with the GLX.
I urge that the full Community Path Extension (CPX) be built as soon as possible and
that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines
connector and eliminate it from the SIP. I urge the DEP to reject this requested SIP
revision.
I support the following with respect to GLX environmental offset/mitigation projects
for the GLX delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at
Lechmere/North Point, as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or
more of the GLX air quality and environmental benefits.
Thank you.
Hayward Zwerling, M.D., FACP, FACE
15 Elston St, Somerville, MA
HZMD@me.com
mobile: 978-407-0101
President, ComChart Medical Software, www.ComChart.com
The Lowell Diabetes & Endocrine Center, www.DiabetesEndocrine.com
MeaningfulHealthIT, www.MeaningfulHealthIT.com
From:
To:
Subject:
Date:
Ted Bach
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT) ; friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 11:26:44 AM
Dear Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
As a long time resident of Somerville, I support completing the Green Line Extension (GLX) and
the Fairmount Line, the major remaining transit/air quality mitigation commitments from the Big
Dig. I appreciate that MassDOT is moving ahead with the GLX. I urge that the full Community
Path Extension (CPX) be built as soon as possible and that the GLX be built to Route 16.
The community path extension will contribute significantly to transportation equity in our densely
populated environment and yield significant alternative transportation synergies when combined
with the Hubway project and the GLX itself.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector
and eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX
delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated area.
Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
From:
To:
Subject:
Date:
Christopher Ferry
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 11:27:26 AM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as
possible and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector
and eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX
delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point,
as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX
air quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide
a financial incentive for timely project completion
Thank you.
Christopher P. Ferry, CRM
263 Highland Ave., Apt. 3
Somerville, MA 02143
From:
To:
Cc:
Subject:
Date:
Susan Hamilton
Fichter, Katherine (DOT)
friendspath@yahoo.com
GLX and Community Path
Thursday, September 19, 2013 11:37:45 AM
> To Kate Fichter and Jerome Grafe:
>
> I and my children live in Somerville which has some of the worst air quality in Massachusetts due to
excessive car traffic. Please help reduce traffic and improve air quality in our neighborhood by
completing the GLX on time! And include the community path in this extension to encourage more
cycling and walking. There's no time to waste.
>
> I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving ahead
with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible and that
the GLX be built to Route 16.
>
> I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
>
> I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
> 1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as soon
as possible.
> 2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
> 3. Reject any new diesel rail stops on commuter rail lines through this densely populated area.
Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and asbestos.
> 4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
>
> Thank you.
> Susan Hamilton
> 223 Morrison Ave
> Somerville, MA 02144
From:
To:
Subject:
Date:
Attachments:
John Wilde
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT); friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 11:51:45 AM
ATT00022.txt
_Certification_.htm
To Kate Fichter and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan
(SIP) Transit Commitments Report:
I am a supporter of the Somerville 'Friends of the Community Path' whose goal is to see the
minuteman bikeway and Somerville Community Path extended from its current terminus at Cedar Street
in Somerville to the paths at Lechmere/North Point. This extension of the path must realistically be
built in tandom with the green line extension planned through Somerville.
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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you.
John Wilde
Somerville Resident
224 Highland Avenue, Somerville, MA
From:
To:
Subject:
Date:
Ellin Reisner
Grafe, Jerome (DEP); Fichter, Katherine (DOT)
Comments of the 2013 SIP Transit Report and Status
Thursday, September 19, 2013 12:05:35 PM
Thank you for the opportunity to comment on the 2013 SIP Transit Report and Status. This
is the sixth year that I have submitted comments on the Transit SIP. It is good to see that
some progress has been made on the Fairmount Line and Green Line Extension (GLX), but I
remain very concerned about the delays to opening the GLX. As a result the date for
implementing interim offset measures is fast approaching.
The 2013 report states that if the Green Line Extension (GLX) were on time we would be
expecting that the extensions to Union Square and College Avenue would be opening for
revenue service by the end of December, 2014. We do know that this deadline will not be
met on time, but that progress is being made.
In 2012 the Commonwealth rolled out the GreenDOT Implementation Plan with the lofty
goal of “…leading the nation in sustainable transportation.” Clearly, the opening of the GLX
extensions and the completion of the Community Path from Lowell Street to Boston (along
the Lowell line extension of the GLX) will be real GreenDOT accomplishments that MassDOT
and MassDEP should be championing.
The GLX and the new Orange Line Station at Assembly Square are the most important
environmentally clean mode shift projects in the Commonwealth that meet GreenDOT
goals. These projects and completion of the Community Path are critical regional projects
as well. They will provide clean transportation options for Somerville residents and
businesses and regional multi-modal transportation users. As has been noted before the
percentage of city residents with convenient access to transit will expand from 15% to
85%. This huge mode shift opportunity should be the Commonwealth’s model for urban
transportation in this century.
The 2013 SIP Report specifically notes that the extension of the Community Path is not part
of the SIP agreement, but does not make the same clarification about the Vehicle
Maintenance and Storage Facility which is also not part of the SIP agreement. While I am
not arguing against the Maintenance Facility, it should be noted that it is not part of the SIP
or the Path should also be included in the same manner.
Since completion of the GLX project will not meet its SIP deadline, I strongly urge MassDOT
to complete the Community Path from Lowell Street to the Lechmere/North Point Paths as
part of the SIP agreement.
As interim offset measures to be implemented I January, 2015, I would recommend
expanding bike share programs in Somerville, Cambridge and Medford and providing
reduced fares for residents until the GLX opens. To reduce traffic congestion around the
busy Highland Avenue corridor free T passes should be provided for high school students to
encourage use of buses that would reduce traffic congestion and pollution around
Somerville High School.
Lastly, I urge DEP to reject MassDOT’s recommendation to stop the design of the Red/Blue
Lines connector and eliminate it from the SIP. The Red/Blue Connector is a very good transit
improvement that will particularly benefit low income, environmental justice residents of
East Boston and Revere to improve access to jobs in Boston and Cambridge.
Submitted by
Ellin Reisner
Somerville Transportation Equity Partnership
51 Mt. Vernon St.
Somerville , MA 02145
Reisnere51@gmail.com
-Ellin Reisner, Ph.D.
reisnere51@gmail.com
From:
To:
Subject:
Date:
Kate Sackton
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT) ; friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 12:23:39 PM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as
possible and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector
and eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I am grateful not to have to own a car, to be able to live in a dense, vibrant urban place where I
can commute to work and do almost all my errands by public transit. Investing in improving our
environmentally friendly public transit infrastructure should be a priority of our state government,
thus greatly improving the quality of life of MA citizens.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX
delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point,
as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX
air quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide
a financial incentive for timely project completion
Thank you.
Kate Sackton
20 Wallace St #2, Somerville, MA 02144
From:
To:
Cc:
Subject:
Date:
Steele, Matthew
"jerome.grafe@state.ma.us"; Fichter, Katherine (DOT)
"friendspath@yahoo.com"
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 12:32:03 PM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as soon as
possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air quality
and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated area.
Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
I hope that your agencies continue to recognize the drastic growth in bicycle transportation in the
Boston area.
Thank you.
Matt Steele
318 Rindge Ave., 209
Cambridge, MA 02140
This e-mail and any attachment or file transmitted with it may contain privileged and confidential information for the use of the intended
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From:
To:
Subject:
Date:
Jennifer D
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 1:25:01 PM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you.
From:
To:
Subject:
Date:
Importance:
Macdougall, John
Fichter, Katherine (DOT)
transit improvements
Thursday, September 19, 2013 2:13:41 PM
High
From: Macdougall, John
Sent: Thursday, September 19, 2013 2:05 PM
To: jerome.grafe@state.ma.us; katherine.fichhter@dot.state.ma.us
Subject: transit improvements
Subject:
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
To Kate Fichter and Jerome Grafe:
My wife and I have no car. We use the T or MBTA buses nearly every day, and do a lot of biking
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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you.
John_macdougall@uml.edu
175 Richdale ave. #209, Cambridge MA 02140 (member, 350MA)
From:
To:
Subject:
Date:
Attachments:
John Roland Elliott
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
Comments on 2013 SIP Transit Commitments Status Report
Thursday, September 19, 2013 2:54:34 PM
2013 SIP Comments.pdf
Attached and posted at https://app.box.com/s/svs5i4eypblgdta063yg, please find my comments on
the 2013 SIP Transit Commitments Status Report.
19-Sep-2013
To:
Kate Fichter, MassDOT, Office of Transportation Planning
Jerome Grafe, MassDEP, Bureau of Waste Prevention
From:
John Roland Elliott, 34 Emery Street, Medford Hillside
Subject:
Comments on State Implementation Plan – Transit Commitments, 2013 Status Report, III. Green Line
Extension to Somerville and Medford
It is reassuring finally to have palpable, tangible, non-trivial progress on the GLX. Unfortunately, any celebratory
mood that might well up inside is diluted by recognition of the distance left to go, the obstacles still to surmount
and the challenges that will be encountered. And celebration is tempered with justifiable doubts that the
Commonwealth is genuinely invested in meeting its obligations.
Given the SIP Requirement and the Project Description and the chasm that separates them from the currentlyconstituted GLX project, it is clear that, until the GLX project has been redefined to more nearly satisfy the needs
of its constituents, the Commonwealth will have failed. It is evidence of the triumph of fantasy over reality that
the Status Report contains the words
Phase 4 will provide service … to College Avenue Station. It is currently targeted to
be completed by the end of July 2019. … Completion of Phase 4 also represents
completion of the Green Line Extension project.
Completion of Phase 4 decidedly does not complete the Green Line Extension as it is defined by the SIP in five
critical ways:
1. Completion of Phase 4 does not extend the Green Line to its mandated destination, Medford Hillside,
much less by the end of 2014, as required.
Then, because the Extension is prematurely truncated at College Avenue rather than continuing to its
required destination,
2.
3.
4.
5.
1
The boost to transit ridership is inadequate.
Mobility and air quality remains worse than it could be.
Distribution of transit services continues to be unfair and imbalanced.
Opportunities for sustainable development are foreclosed.
19-Sep-2013
SIP Requirement to extend the Green Line from Lechmere Station to Medford Hillside
The SIP Requirement as included in the Status Report unambiguously identifies Medford Hillside as the
destination of the Green Line Extension, mentioning it by name twice in the first sentence of the Requirement. I,
and others, have provided you repeatedly with overwhelming and incontrovertible evidence that the planned
location of College Avenue Station is outside the boundaries of Medford Hillside. A compendium of such
evidence can be found at https://app.box.com/shared/t499nbnoa8 including historical, commercial and
governmental references. The Commonwealth’s own MassGIS Online Mapping Tool at
http://maps.massgis.state.ma.us/map_ol/oliver.php also demonstrates that the planned site of the College
Avenue Station is a full 0.60 miles short of Medford Hillside. For comparison, Mystic Valley Parkway / Route 16
Station location is 0.30 miles into Medford Hillside.
College Avenue Station is 0.60 miles short of
Medford Hillside
Mystic Valley Parkway / Route 16 Station is 0.30
miles into Medford Hillside
So long as the northernmost stop on the Green Line is at College Avenue, the Commonwealth has failed to meet
its obligation to extend the Green Line to Medford Hillside.
2
19-Sep-2013
Transit Ridership Boost as a purpose of the Green Line Extension Project
The purpose of the GLX project, as stated in the Project Description in the Status Report, includes five points. The
second of these is “boost transit ridership”. It seems axiomatic that this purpose is best served by locating
stations in and nearby to densely-populated residential neighborhoods. MassGIS’s Online Mapping Tool
demonstrates the inadequacy of a College Avenue Station in this regard with the preferred MVP/R16 station
shown for comparison.
mile radius surrounding College Avenue Station
with markers added (by author) for apartment
buildings and dormitories
1. station’s surrounding property is
predominantly non-residential (Tufts
University)
2. the few high-density residential locations
are farthest from the station
mile radius surrounding Mystic Valley Parkway /
Route 16 Station with markers added (by author)
for apartment buildings, senior living, etc.
1. station has smaller non-residential
surrounding (predominantly green space)
2. considerable high-density residential
locations near the station
With a final stop for the Green Line Extension at College Avenue, the ridership boost is inadequate. The densely
populated residential neighborhoods that were to be served by bringing the Green Line to Medford Hillside are
isolated from the College Avenue Station by the Tufts University campus and a station that would capture
ridership from Medford Hillside, West Medford, North Somerville and parts of Arlington remains nearly a mile
farther north on the right-of-way. The boosts that would be had from serving affordable and senior housing near
a Mystic Valley Parkway / Route 16 Station are probably entirely lost when the nearest GLX Station is more than
a mile away at College Avenue.
3
19-Sep-2013
Purposes of Improvement of Mobility and Air Quality
The SIP explicitly lists two further purposes of the project – to “improve corridor mobility” and to “improve
regional air quality”. Presumably pedestrian, cycle and other non-motorized modes of mobility, in addition to
contributing to mobility and air quality purposes, have the added advantage of promoting health and fitness in
the citizens of the Commonwealth. MassGIS’s Mapping Tool, in particular its display of existing, planned and
considered cycle and pedestrian paths shows how ill-suited College Avenue Station is for multi-modal trips that
take advantage of the Commonwealth’s paths and trails.
(Key: Existing, Existing Unimproved, Underway, Considered.)
mile radius surrounding College Avenue Station
1. poor connection to / utility from current
and future pedestrian / cycle / nonmotorized mobility paths
2. requires use of busy motorways (Boston
Avenue, College Avenue) to approach GLX
station from the nearest paths and trails
mile radius surrounding Mystic Valley Parkway /
Route 16 Station
1. close to intersection of existing and
considered pedestrian / cycle / nonmotorized mobility paths
2. provides access to GLX from east, west
and south without exposure to and
interference with motor vehicle traffic
The Commonwealth continues to devote resources to providing its citizens with attractive healthy alternatives
to the privately-owned internal combustion engine. One such amenity, serving both recreational and mobility
pursuits, is the DCR’s network of trails and paths. Locating the final stop of the GLX at College Avenue, a mile
away from any path or trail (that exists, is under construction, is planned or is being considered), compromises
the utility of the trail and path network and undermines return on investment from it. The Mystic Valley
Parkway / Route 16 Station is at the intersection of two pedestrian / cycle arteries.
4
19-Sep-2013
Transit Services distributed equitably by the Green Line Extension
Also in the stated purpose of the GLX project is “ensure equitable distribution of transit services”. Public
transportation projects frequently have been criticized for neglecting the communities and populations that
need services the most – e.g., the poor, the elderly and the linguistically-marginalized – and disproportionately
burdening those populations with inconvenience and environmental impact as the transit accommodations are
constructed and eventually operated. MassGIS’s Mapping Tool depicts Environmental Justice populations as
identified by the 2010 census and demonstrates the failure of a terminus at College Avenue to deliver services
equitably. (Key to EJ areas:
Minority,
Income,
Minority and Income)
mile radius surrounding College Avenue Station
1. overlapping with designated
Environmental Justice populations in less
than 1% of its area
2. overlapping with approximately 90% of
the Tufts University Medford / Somerville
campus
mile radius surrounding Mystic Valley Parkway /
Route 16 Station
1. overlapping with designated
Environmental Justice populations in
approximately 55% of its area
2. providing access to recreational green
space for populations to the south
Located at the campus’ center of gravity, the College Avenue Station location does a spectacular job of serving
Tufts University. To reach College Avenue, the rail right-of-way runs through South Medford and requires the
reconstruction of the bridge at Harvard Avenue, disrupting traffic and introducing (albeit temporarily) noise
pollution and construction dust to the neighborhood, which happens to house an identified Environmental
Justice population. Having subjected an EJ population to inconvenience and harm to quality of life in order to
deliver service to Tufts University, it is downright unjust not to extend the service beyond College Avenue
Station to a site where it would serve another cluster of EJ citizens.
5
19-Sep-2013
Support for Sustainable (Transit-oriented) Development
The final stated purpose of the GLX project is “support opportunities for sustainable development”. The planned
College Avenue Station is entirely surrounded by the Tufts University campus making TOD adjacent to the
station impossible. In stark contrast, at or adjacent to the site of a Mystic Valley Parkway / Route 16 Station,
there is property that is either already commercial or is residential but conceivably suited to redevelopment.
(Key: existing commercial property, existing residential use conceivably practical for development,
identified by author rather than by MassGIS)
College Avenue Station showing mile radius
surrounding with nearby commercial property and
property conceivably suitable for development
1. developable properties are more than a
quarter mile from station
2. closest nearby properties that even
remotely make sense for development
about 50,000 square feet (1.15 acres in a
shape ill-suited for any use)
Mystic Valley Parkway / Route 16 Station showing
mile radius surrounding with adjacent and
nearby commercial property and property
conceivably suitable for development
1. approximately 900,000 square feet (20.7
acres) of existing commercial property or
property suitable for development at,
adjacent to or abutting proposed station
site and right-of-way
2. additional 300,000± square feet nearby
Properties practical for sustainable development around College Avenue Station are few, minuscule, poorlysituated and inappropriately-shaped. In stark contrast, a Mystic Valley Parkway / Route 16 Station would achieve
the development goals of the SIP, as demonstrated by Metropolitan Area Planning Council’s Mystic Valley
Parkway Green Line Extension Community Visioning Process, which MAPC conducted fall 2012.
6
19-Sep-2013
To my surprise and relief, in January 2009 MassDOT (EOT at the time) identified Mystic Valley Parkway / Route
16 as the preferred terminus for the Green Line Extension. Subsequently, to my surprise and horror, MassDOT
has backpedaled and variously adopted assorted dishonest and disingenuous postures contending that the
Green Line Extension concluding at College Avenue Station
1. In fact, extends the Green Line to Medford Hillside (because in one map we found, the second “d” in
“Medford” is to the southeast of Winthrop Street.)
2. If not in fact, at least in spirit extends to Medford Hillside as there are things nearby that have “hillside”
in their names.
3. Serves Medford Hillside by virtue of being within a mile of it.
4. Achieves the same air-quality benefits as extending the Green Line to Medford Hillside, so … close
enough.
No amount of cartographical legerdemain is going to relocate Medford Hillside to contain College Avenue
Station. History, including more than a century of use of the term Medford Hillside, defends against revisionist
attempts to define College Avenue Station as part of Medford Hillside. Geographic authorities including the US
Geological Survey, Board on Geographic Names and the Commonwealth’s Information Technology DivisionMassGIS confirm that Medford Hillside is well north of the College Avenue Station.
The SIP’s long-standing and well-established requirements and unambiguously-stated purposes for the Green
Line Extension, coupled with reliable demographic information, demonstrate the wisdom of identifying Medford
Hillside as the destination rather than some location short of Medford Hillside. A Medford Hillside terminus, e.g.,
one at Mystic Valley Parkway / Route 16, brings the Green Line to a large prospective ridership, includes EJ
communities in its catchment, connects with non-motorized mobility infrastructure and accesses areas that can
support sustainable development.
The Green Line Extension as currently constituted, with a final stop at College Avenue, fails to meet the SIP’s
definition and it fails to achieve any of its five purposes adequately. So long as the Commonwealth uses College
Avenue Station as the conclusion of the Green Line Extension, it has failed to satisfy the SIP and failed its
citizens.
7
From:
To:
Cc:
Subject:
Date:
Attachments:
Importance:
Robert Reardon
jerome.grafe@state.ma.us; Fichter, Katherine (DOT)
friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 2:56:15 PM
ATT00002.txt
High
To Kate Fichter and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan (SIP) Transit
Commitments Report:
I am Somerville resident of 34 years and homeowner for 31 of those. My wife and I have raised
three children in Somerville who all attended the public schools here, and graduated college with
honors. My wife has been a teacher in Somerville for 22 years. We are proud of and committed to
our community and it’s positive growth. As the most densely populated city in the commonwealth,
the most important component to support the current density and enable responsible growth is
providing transportation options at are “growth compatible” with the city, and can address the
existing overcrowding of cars, parking and the attendant air quality degradation. The GLX combined
with the CPX is best solution. I have worked in Europe for part of my career and used the
outstanding trans system there and also witnessed (and used a bit) the bike friendly infrastructure
many cities provide for bicycle commuters, The Netherlands and Denmark being impressive
examples. I have commuted by bicycle both to Boston (not so good- as there is no connecting bike
path)regularly and for a couple of years seasonally to Bedford (great – the minuteman bikeway)
using the bike path.
The central reason that the CPX should be constructed in its entirety (including sensible connection
to Boston from the proposed Washington Square station) is that this is far bigger than Somerville. A
completed CPX will be a resource connecting many communities together and to Boston. An
examination of the actual public and environmental ROI from CPX yielding tangible benefits for
many communities in addition to Somerville and Cambridge, demonstrate the soundness of the plan
and the public need.
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are classified by WHO as a Class 1 carcinogen just like smoking and
asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
BTW: We have a two family home and out tenant has no car and is a bike commuter to MIT. This is
something we looked for in selecting a tenant, as parking our street is already overcrowded because
many two family homes have two (or more!)cars per unit, and there just is not the room (including
driveways).
Somerville needs the CPX and of course the GLX can’t come soon enough.
Thank you.
Robert J Reardon - on behalf of your household.
27 Gilman Terrace
Somerville, MA 02145
From:
To:
Cc:
Subject:
Date:
Todd Van Hoosear
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
Friends of the Community Path
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 2:56:39 PM
Dear Jerome and Katherine:
As a resident of Somerville and an avid bicyclist, I'd like to thank you for this opportunity to comment
on the annual State Implementation Plan (SIP) Transit Commitments Report.
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving ahead
with the GLX, but I urge that the full Community Path Extension (CPX) be built as soon as possible and
that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay
past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as soon as
possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air quality
and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated area. Diesel
emissions are classified by WHO as a Class 1 carcinogen just like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a financial
incentive for timely project completion
Thank you for your time.
Sincerely,
Todd Van Hoosear
Somerville Resident
50 Pinckney St.
Somerville, MA 02145
+1-617-326-3211
From:
To:
Cc:
Subject:
Date:
Alex Epstein
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
Joel Bennett
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 3:00:04 PM
To Kate Fichter and Jerome Grafe:
I'd like to take this opportunity to submit a couple of comments on the annual State Implementation
Plan (SIP) Report:
http://www.massdot.state.ma.us/Portals/17/docs/sip/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig.
I urge that the full Community Path Extension (CPX) be built as soon as possible and that the
GLX be completely built to Route 16 in Medford Hillside.
I believe MassDOT’s recommendation to halt the design of the Red/Blue Lines connector and
eliminate it from the SIP is shortsighted. We should not preclude future construction when funds
become available. The lack of shovel-ready projects stung Massachusetts when ARRA funds became
available--surely we should avoid this mistake in the future. I urge the DEP to reject this requested
SIP revision.
I support the following measures for GLX environmental offset/mitigation projects due to missing the
legal start -of-service deadline of Dec 31, 2014:
1. Build the full CPX, from Lowell Street to the existing paths at Lechmere/North Point, as
soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air
quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated
area. Diesel emissions are Class 1 carcinogens.
4. Retrofit all MBCR locomotives to Tier 4 emissions standards.
4. Retrofit MBCR locomotives to be dual-powered, with 3rd rail shoes, like the locomotives
operated by NJ Transit, Metro -North, and Long Island Railroad. Build substations and 3rd rail
within the urban core and run all commuter rail trains on electric power within this zero -emission
zone.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a
financial incentive for timely project completion
Thank you.
Alex Epstein
278 Beacon Street
Somerville, MA 02143
From:
To:
Subject:
Date:
Spencer Sherman
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT); Friends of the Community Path
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 3:11:18 PM
To Kate Fichter and Jerome Grafe:
Thank you for this opportunity to comment on the annual State Implementation Plan
(SIP) Transit Commitments Report.
My wife and I are new homeowners and plan on starting our family in
Massachusetts. We are both car-free and use the Community Path on a daily basis
to get around town, meet our neighbors and get exercise. However, living in the
Winter Hill area, we don't have easy access to the Community Path and are limited
as to where it can take us. To get into Boston, we rely on a bus to get to Sullivan
Station, which comes infrequently at night and on weekends.
According to census data, the number of cars in Somerville has dropped 18% from
2010 - 2012 (it's dropped 24% in Boston!). We need to invest in infrastructure that
supports this trend in order to have transportation equity in this state and allow
people to live healthy lives (with specific focus on air quality).
I support completing the Green Line Extension (GLX) and the Fairmount Line, the
major remaining transit/air quality mitigation commitments from the Big Dig. I
appreciate that MassDOT is moving ahead with the GLX. I urge that the full
Community Path Extension (CPX) be built as soon as possible and that the GLX be
built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines
connector and eliminate it from the SIP. I urge the DEP to reject this requested SIP
revision.
I support the following with respect to GLX environmental offset/mitigation projects
for the GLX delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North
Point, as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of
the GLX air quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely
populated area. Diesel emissions are classified by WHO as a Class 1 carcinogen just
like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also
provide a financial incentive for timely project completion
Thank you.
Spencer Sherman
Webmaster
Health Resources in Action
453 Broadway
Somerville, MA 02145
From:
To:
Subject:
Date:
Attachments:
aide.rep.sciortino@gmail.com on behalf of Freedman -Gurspan, Raffi (HOU)
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
Somerville-Medford Delegation Letter for SIP 19 September 2013
Thursday, September 19, 2013 4:56:09 PM
Somerville_Medford_DelegationLetter_SIP_19Sep2013.pdf
Dear Ms. Fichter and Mr. Grafe,
On behalf of the legislators from Medford and Somerville, please find enclosed our
delegation letter on MassDOT's July 1st 2013 SIP to MassDEP.
Thank you,
Raffi Freedman-Gurspan
-Raffi Freedman-Gurspan
Legislative Director
Office of Representative Carl M. Sciortino, Jr.
(617) 722-2013
Raffi.Freedman-Gurspan@mahouse.gov
COMMO NWEALTH OF MASSACHUSET TS
THE GENERAL COURT
STATE HOUSE, BOSTON 021 33-1053
Scptember 19t\ 2013
Kate Fichter
MassDOT Office of Transportation Planning
Room 4150, Ten Park Plaza
Boston, MA 02116
Jerome Grafe
MassDEP, Bureau ofWastc Prevention
One Winter Street
Boston, MA 02108
Dear Ms. Fichter and Mr. Grafe,
We are writing to subrnit public comment on the annual update and report for transit projects required by
law that was subrnitted by the Massachusetts Department of Transportation (MassDOT) to MassDEP on
July 1"\ 2013. As legislators representing districts that will benefit from the extension of the Green Line
through Cambridge, Somerville and Medford, wc are writing in strong support of the Green Line
Extension project (GLX).
This past year an important rnilestone passed with the beginning of construction on Phase I of the GLX
project along with completion of the Advanced Conceptual Design; the start of Advanced Preliminary
Engineering and Final Design (APE/FD); and other important developments. This work made substantial
improvements to the GLX project and reduced its environmental impact:
•
•
•
•
Redesign of the GLX project has reduced the size of stations by 10%;
Change in the allotment of bicycle parking at stations has been increased to 50%, a figure over
the commitment in the Environmental Assessment;
Continued design of the Community Path Extension (CPX) near the new GLX Washington Street
Station that will fulfill an MBTA comrnitment to connect our communities to the North
Point/Charles River paths; and
Beginning of repairs and infrastructure improvements on the Harvard Street bridge in Medford
and the Medford Street bridge in Somerville that will not only prepare thcse bridges for usage for
the Green Linc, but also address concerns over flooding problems.
The work by the APE/FD team has allowed for a smooth transition of the Final Design for the CM/GC
team that will start the construction of Phases II through IV of the project.
We would like to draw your attention to the absence of the MassDOT Preferred Full Build Alternative
tenninus station on the Medford Branch of the GLX project at Mystic Valley Parkway/Route 16. While
not an official part of the SIP, this final extension passed College Avenue continues to receive
programmed fonds from the Boston Region MPO, including $29.9 million bcing approved this year for
programming in the FFY Year 2017 in the 2014-2017 Transportation Improvement Program (TIP). As we
commented on last year, and as MassDOT acknowledge this past January, the MPO has addcd this
funding with the understanding of its availability in 2016, which MassDOT and the MBTA will begin
working on once the timeframe draws closer. We ask that MassDOT begin to reference this preferred
alternative of Route 16 in bath its annual and monthly status reports, and also ensure that Final Design of
the College A venue station is completed in a way as to accommodate for the eventual continuation of the
Green Line to Route 16.
Finally, we encourage MassDEP to ensure a public review process for the interim mitigation measures
required to be implemented by MassDOT by December 31 5\ 2014, the legal deadline for GLX
implementation that will not be met. We firmly believe that any mitigation project should be executed
within the proposed corridor of the GLX project to mitigate for the environmental impact on our
communities. Such proposais include completion of the Mystic River Reservation multi-use path in
Medford, and fast tracking design and construction of the CPX path in Somerville.
We look forward to the progression on the Green Line Extension project, and expect that interim offset
measures will complement the project to ensure that improvements are made in our districts' regional
mobility, air quality, and other environmental benefits.
Thank you for your bard work to meet Massachusetts' environmental goals and needs and for your
consideration of this letter.
Sincerely,
s~~
2nd
Middlesex District
Representative Carl Sciortino
34th Middlesex District
Representative Denise Provost
27th Middlesex District
From:
To:
Subject:
Date:
Karen Molloy
Grafe, Jerome (DEP); Fichter, Katherine (DOT)
My Comments of the 2013 SIP Transit Report and Status
Thursday, September 19, 2013 5:00:30 PM
Dear Kate Fichter and Jerome Grafe:
Below are my comments on the annual State Implementation Plan (SIP)
Transit Commitments Report.
I support completion of the Green Line Extension (GLX) a major
remaining transit/air quality mitigation commitments from the Big Dig.
I appreciate the progress that MassDOT has made with GLX, but am
still concerned by the chronic delay of this project which should have
been completed in 2011.
I do not agree with MassDOT’s recommendation to halt the design of the
Red/Blue connector and eliminate it from the SIP. This is one of two
major gaps in the current T system (the other being no North -South
Station connection) and I would urge the Mass DEP to reject this
requested SIP revision. This connection will benefit low income,
environmental justice residents of East Boston and Revere and greatly
improve access to jobs in Boston and Cambridge. It seems ot me, that
this falls in line with the GreenDOT goal of “…leading the nation in
sustainable transportation.”
For a GLX environmental offset/mitigation project due to the GLX delay
past its legal deadline, I urge MassDOT to build the Community Path
Extension from Lowell St. to the Lechmere/North Point Paths.
Best regards,
-Karen Molloy
197 Highland Ave.
Somerville, MA 02143
===================
karenmolloy@gmail.com
From:
To:
Subject:
Date:
Attachments:
Sutton, William (HOU)
Fichter, Katherine (DOT); Grafe, Jerome (DEP)
SIP Status Report Comments
Thursday, September 19, 2013 5:03:02 PM
Toomey_SIP_919.pdf
Please find Rep. Toomey’s comments attached.
Thanks,
Will
Will Sutton
Senior Aide
Office of Rep. Timothy J. Toomey, Jr.
State House Room 238
Boston, MA 02133
P - 617-722-2380
F - 617-722-2847
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TIMOTHY J. TOOMEY, JR.
COMMITTEES:
STATE REPRESENTATIVE
VICE CHAIR, REVENUE
26TH MIDDLESEX DISTRICT
CONSUMER PROTECTION A ND
PRO FESSIONAL LICENSURE
SOMERVILLE - CAMBRIDGE
ROOM 238, STATE HOUSE
TEL: (617) 7 22-2380
STATE ADM INISTRATION AND
REGULATORY OVERSIGHT
FAX: (617) 722- 2847
T imothy.Toomey@MAhouse .gov
September 191\ 2013
Kate Fichter
MassDOT Office of Transportation Planning
Room 4150, Ten Park Plaza
Boston, MA 02116
Jerome Grafe
MassDEP, Bureau ofWaste Prevention
One Winter Street
Boston, MA 02108
Dear Ms. Fichter and Mr. Grafe,
I am writing to submit comment on the annual update and report for transit projects required by
law that was submitted by the Massachusetts Department of Transportation (MassDOT) to
MassDEP on July 15\ 2013. As a Representative for communities that will benefit from the
extension of the Green Line, I am writing in strong support of the Green Line Extension project
(GLX).
This past year an important milestone passed with the beginning of constrnction on Phase I of the
GLX project along w ith cornpletion of the Advanced Conceptual Design, the start of Advanced
Preliminary Engineering and Final Design (APE!FD), and other important developments. This
work made substantial improvements to the GLX project and reduced its environmental impact:
•
•
•
•
Redesign of the GLX project has reduced the size of stations by 10%;
Change in the allotment of bicycle parking at stations bas been increased to 50%, a figure
over the commitment in the Environmental Assessment;
Continued design of the Community Path Extension (CPX) near the new GLX
Washington Street Station that will fulfill an MBTA commitment to connect our
communities to the North Point/Charles River paths; and
Beginning of repairs and infrastrncture improvements on the Harvard Street Bridge in
Medford and the Medford Street Bridge in Somerville that will not only prepare these
bridges for usage for the Green Line, but also address concems about flooding problems.
The work by the APE/FD team has allowed for a smooth transition of the Final Design for the
CM/GC team that will start the construction of Phases II through IV of the project.
While thcse are important milestones and I am very pleased about the progress that bas been
made on the GLX in recent months, I feel very strongly that there should be proper mitigation for
the extended delays that the GLX has experienced. Although completion of the GLX will bring
public transit access to thousands of people and take many cars off of the road, whole
neighborhoods have suffered in the face of multi-year delays.
I strongly encourage MassDEP to ensure a public review process for the interim mitigation
measures required to be implemented byMassDOT by December 31 5\ 2014, the legal deadline
for GLX implementation that will not be met. l firmly believe that any mitigation project should
be executed within the municipalities that the GLX project will ultimately serve in order to
properly mitigate the environmental impact that GLX delays have had on our communities. Such
proposais include fast tracking design and construction of the CPX path in Somerville, and
completion of the Mystic River Reservation multi-use path in Mcdford.
I look forward to seeing the Green Line Extension project make further progress, and expect that
interim offset measures will complement the project to ensure that improvements have lasting
regional mobility, air quality, and environmental benefits.
Thank you for your bard work to meet Massachusetts' environmental goals and needs and for
your consideration of this letter.
•
From:
To:
Cc:
Subject:
Date:
Attachments:
Lee Auspitz
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
mary.mello@dot.gov
Comment letter on SIP 2013 Status Report
Thursday, September 19, 2013 5:53:01 PM
melloltr.aug2013.doc
OMB Circular A-16 Memo Durbin July2013.doc
Subject: Comment letter on 2013 SIP transit commitments annual report
Dear Ms. Fichter and Mr. Grafe:
While I remain cognizant and respectful of the many years of dedicated professional work
and volunteer commitment that have gone into the Green Line Extension (GLX) I note the
following topics in the current status update that require attention:
1. Non-conformity to OMB geospatial requirements.
This issue is summarized in the attached letter to the FTA Regional Administrator
(“MelloLtr.Aug2013”). In a nutshell there is a discrepancy between the Medford Hillside
requirement of the SIP and the current plan to end the GLX at a station surrounded by Tufts
University. This geospatial discrepancy threatens both the future eligibility for New Starts
funding in a highly competitive environment and, in the event an award is made, the
eligibility of GLX for retroactive reimbursement of funds scheduled for expenditure during
the current 2014 state fiscal year.
I have also attached a draft memo, included in the submission to FTA Region I, briefly
summarizing the history of OMB geospatial requirements as embodied in Circular A -16 and
detailing their internal codification in Section 35 of the FTA Master Agreement. (This memo
will be put into final form after comments are received from FTA and Congressional
transportation specialists, and stakeholders in the GLX. Thus far, no critical comments have
been received on the substantive content.) The self-corrective mechanisms available to FTA
at the regional level are adequate to resolve the issue before an FFGA is issued. Of course,
by law the final non-judicial arbiter of compliance with OMB Circular A -16 is the OMB itself.
There are also two tracks of litigation—environmental and “qui tam”—for which standing
requirements are broad. It seems likely that the merits of this issue will receive attention at
some level through the checks and balances of our democratic system. The arguments for
doing this sooner rather than later now have a price tag: $180,000 per day during 2014 (the
prorated 2014 expenditures for phase I) in forfeited reimbursements for every day of nonconformity.
It compounds the problem that there has been no serious attempt to research federal
geospatial standards either in general or for Medford Hillside by EOT/MassDOT, MassEPA, or
the Central Transportation Planning Staff during the several years in which this issue has
been called to their attention by scores of individuals, including the overwhelming
preponderance of stakeholders, elected officials and citizen advisory group members. To
the contrary, all three of the agencies mentioned, have issued non-conforming maps,
memoranda and mutually supportive letters of determination that promote a false sense
that the Medford Hillside requirement of the SIP is geospatially fulfilled by the current plan
to limit the GLX New Starts project to a Tufts University terminus at College and Boston
Avenues.
At the same time, it is encouraging that outside the formal structure of the GLX, the Boston
Area MPO has included the full extension to Route 16 in its long-term plan (TIP) and set
target funds for its initial planning and MAPC has completed an economic development
study for this terminus . Those behind these developments understand very well that the
Route 16 terminus satisfies both the legal Medford Hillside requirement and the intent
more generally that the GLX serve a broader ridership and spark economic development not
available around a station almost entirely surrounded by university-owned land. However,
as with the Urban Ring, TIP inclusion may be evanescent. The nexus between Route 16 and
the GLX is at best informal. There are various ways of tightening this nexus: memoranda of
understanding, letters of intent, formal amendment, legislative resolution, reconfiguration of
GLX itself. A prompt consideration of this issue is long overdue.
2. Using Boston Engine Terminal land for VMSF office and parking space
While it is good to hear that land taking for the Vehicle Maintenance and Storage Facility will
be closely scrutinized, the parameters given to the independent evaluators would appear to
exclude vacant land already owned by the MBTA in the adjacent Boston Engine Terminal.
The series of consulting studies ruling out any use of BET land has been remarkable for
overstating the problem, as if to defend a Chinese wall between the MBTA commuter rail
subcontractor at BET and the MBTA itself at VMSF: arguments that any sharing would
require joint use of the same track by heavy and light rail in violation of federal regulations,
an entire study of the infeasibility of superimposing a VMSF building over the existing heavy
rail repair building, and (though I am not aware of their publication) technical data citing
elevation and engineering issues against any use of vacant BET land. The simple issue to be
addressed, however, is whether some new takings can be obviated by the use of vacant BET
land for office and parking space. As the FTA -commissioned risk study cited VMSF takings as
one of the two highest risk/cost factors, it behooves both MassDOT and FTA to reexamine
the savings from using BET land for ancillary VMSF functions.
3.
Mitigating a new pollution/congestion hotspot in the actual Medford Hillside
NEPA requires that environmental “hotspots” not be submerged in the large numbers of
what may appear to be regionally benign pollution ratings. For any period in which the Tufts
University station at College and Boston Avenues functions as a terminus without the further
terminus at Route 16, there will be a predictable hotspot in the actual Medford Hillside
neighborhood and its approaches. The two vehicular approaches to the Tufts station are a)
up the steep Winthrop Street hill from Route 16, and b) across a mile of slow stop -and -go
traffic along Boston Avenue from Route 16. Current studies indicate that the
Winthrop/Route 16 intersection is the second most polluted in the GLX area, while the
Route 16/Boston Avenue intersection is the second most heavily trafficked. The spillover
from these two sites by kiss-and -ride drop-offs will create predictable air quality and traffic
problems that do not appear to be given weight in current MassDOT mitigation plans.
*
*
*
As in the past, I appreciate the opportunity to contribute to the discussion through one of
the many venues our system of government provides. If there are any flaws or
misconceptions in the attached memo on OMB Circular A -16, I would welcome criticisms.
Sincerely,
Lee Auspitz
617-628 -6228
--DRAFT--NOT FOR QUOTATION--DRAFT-MEMO TO: Mr. Josiah Lee Auspitz, jlauspitz@comcast.net
MEMO FROM: Wilford Durbin, wilford.durbin@gmail.com
SUBJECT: OMB Circular A-16 and Related Regulations for Geospatial Information
Mr. Josiah Lee Auspitz,
Pursuant to your request, I have researched and presented here a review of relevant laws
and directives corresponding to the effective management of geospatial information. With
regard to the Green Line Extension project, I believe that these documents apply to any federal
funds supporting the operations of the MBTA and MassDOT, specifically concerning your
question on the use of geospatial information to fulfill the State Implementation Plan, generation
of maps, use of said maps, and overall conduct. That the MBTA and MassDot as well as Region
I of the FTA may have already transgressed some of these federal directives places GLX funding
in jeopardy.
OMB Circular A-16
Since January 16, 1953, the closing days of the Truman Presidency, OMB Circular A-16
has sought to conduct procedures for the agreement and coordination of federal geospatial data. 1
Prior to this, Public Law 80-242 (July 25, 1947) called for the same level of coordination
between federal and local agencies by appointing the Secretary of the Interior and Board on
Geographic names to “provide for uniformity in geographic nomenclature and orthography
throughout the Federal Government.” Responding to new challenges arising in the age of the
Internet, President Bill Clinton issued Executive Order 12906 on April 14, 1994, to “strengthen
and enhance the general policies described in OMB Circular A-16.” The order stipulated that
“Federal agencies collecting or producing geospatial data, either directly or indirectly, shall
ensure, prior to obligation of funds for such activities, that data will be collected in a manner that
meets all relevant standards adopted through the FGDC process.” (§4.d.) Further, EO12906
“called for the establishment of a National Geospatial Data Clearinghouse to address data
standardization, make geospatial data publically available, and address redundancy and
incompatibility of geospatial information.” 2
In its present revision issued August 19, 2002, OMB Circular A-16 provides “direction
for federal agencies that produce, maintain or use spatial data either directly or indirectly in the
fulfillment of their mission.” In application, it appears that the functions of OMB Circular A-16
are twofold: first, to provide for “improvements in coordination and use of spatial data,” which
1
In fact, origins of OMB Circular A-16 reach as far back as 1906. For a history of the Circular, please reference
Appendix A.
2
Peter Folger, “Issues and Challenges for Federal Geospatial Information,” Congressional Research Service, April
27, 2012, 2.
refers to “information about places or geography, and has traditionally been shown on maps;”
and secondly, the Circular describes “the effective and economical use and management of
spatial data assets in the digital environment for the benefit of the government and the nation.”
(§1, ¶1).
To enforce consistent representation of geospatial information, the Circular establishes
the Federal Geographic Data Committee as the “interagency coordinating body for National
Spatial Data Infrastructure-related activities.” Included in the component of the NSDI is the
National Spatial Data Clearinghouse (the Clearinghouse) which is an “electronic service
providing access to documented spatial data and metadata from disturbed data sources,” and
serves as the source of record. Any collection, production, use, or distribution of geospatial
information that does not correspond to FGDC data points maintained in the Clearinghouse is
non-compliant to OMB Circular A-16.
As the document states, “implementation of this Circular is essential to help federal
agencies...reduce resources spent on unfunded mandates...and improve the efficiency and
effectiveness of public management.” (§3 ¶2) To be sure, “Many applications are dependent
upon accurate spatial data...[including] the analysis of management of utility infrastructures,
transportation...and other civilian” strategic issues. (§3 ¶3) In accordance with the importance of
coordinated geospatial data, the Circular applied to any agency that “collects, produces, acquires,
maintains, distributes, uses, or preserves analog or digital spatial data to fulfill [its] mission,
either directly or through a relationship with other organizations” such as State and local
governments (§5 ¶1). The scope of this statement casts a wide net.
The Circular recognizes only three exempted activities that fall beyond the scope of the
directive. These include the activities of tribal governments, classified national security-related
spatial data, and intelligence spatial data activities deemed by the Director of the Central
Intelligence Agency to be valuable to national security.
To enforce its directives, the Circular outlines to the executive departments a number of
responsibilities that, if appropriately satisfied, allow for the release of federally appropriated
funds. It states that all “agencies that collect, use, or disseminate geographic information and/or
carry out related spatial data activities will, both internally and through their activities involving
partners, grants, and contracts”:
• §8.a.(3) “Allocate agency resources to fulfill the responsibilities of effective spatial data
collection, production, and stewardship.”
• §8.a.(4) “Use FGDC data standards, FGDC Content Standards for Digital Geospatial
Metadata, and other appropriate standards, documenting spatial data with the relevant
metadata, and making metadata available online through a registered NSDI-compatible
Clearinghouse node.”
• §8.a.(5) “Coordinate and work in partnership with federal, state, tribal and local
government agencies, academia and the private sector to efficiently and cost-effectively
collect, integrate, maintain, disseminate, and preserve spatial data, building upon local
data wherever possible.”
• §8.a.(6) “Use spatial information to enhance electronic government initiatives, to make
federal spatial information and services more useful to citizens, to enhance operations, to
support decisionmaking, and to enhance reporting to the public and to the Congress.”
• §8 a.(10) “Search all sources, including the National Spatial Data Clearinghouse, to
determine if existing federal, state, local or private data meets agency needs before
expending funds for data collection.”
Collectively, these directives establish a strict protocol for agencies, which must in turn be
applied to any recipients of federal funds. The Circular makes this explicit, mandating that
“Before the obligation of funds, [the agency must] ensure that all expenditures for spatial data
and related systems activities financed directly or indirectly, in whole or in part, by federal funds
are compliant with the standards and provisions of the FGDC.” (§8.b.)
The Circular also charges certain agencies with “lead responsibilities for coordinating the
national coverage and stewardship of specific spatial data themes,” (8.c.) and stipulates that
“major differences” or questions concerning the “coordination or conduct of activities covered
by” the Circular must be referred to the Director of the OMB. (§9 ¶1) The Circular clearly
designates both the Department of the Interior and the US Geological Survey as possessing lead
responsibilities for the accurate use and coordination of “geographic place names deemed official
for federal use by the U.S. Board on Geographic Names as pursuant to Public Law 80-242.”
Continuing, the Circular defines “Geographic Names information” as “both the official place
name (current, historical, and aliases) and locative direct (i.e., geographic coordinates) and
indirect (i.e., State and County where place is located) geospatial identifiers and categorized as
populated places, schools, reservoirs, parks, streams, valleys, and ridges.” (Appendix E) Other
data themes, such as those involving the transportation system or the environment, have their
own clearly defined parameters and lead agencies. The US Department of Transportation is
charged with the responsibility of assuring FGDC compliance in the transportation realm. 3
On November 10, 2010, the OMB issued a Supplemental to OMB Circular A-16, and
while it “expands upon and clarifies some of the language and responsibilities contained in [the
Circular],” the Supplemental “is a supportive document that does not alter the current language
of the OMB Circular A-16.” (§1.2.) The purpose of the Supplemental is to introduce a portfolio
style management system in the possessing and use of geospatial data. The benefits of this
approach are explained:
Issues affecting both citizens and mission-critical government functions are often
place-based or location-specific. The Supplemental Guidance is needed to link
interagency portfolios, portfolio enhancement, reuse, and programmatic benefit to
Department/Agency missions and the larger stakeholder community. To support
mission-critical functions, the Federal Government makes large investments in
acquiring and developing geospatial data. Historically these investments were
largely uncoordinated and often lacked transparency, and sometimes resulted in
data deficiencies, lack of standardization, inefficient use of resources, lack of
interoperability, or inability to share data. The enterprise-wide adoption and
execution of these practices not only foster improved operating efficiencies in
3
For a list of relevant data themes and their lead agencies, see Appendix B.
Federal and partner programs but also include reporting that supports government
transparency. (§1.3.)
To ensure the “quality and usability of NGDA Datasets,” all data admitted and used must be
“discoverable” (i.e., published and available), “reliable” (i.e., coordinated by a recognized
national steward), “consistent” (i.e., supported by defined schema, standards and understood
content definitions to ensure their integrity), and “current and applicable” (i.e., maintained
regularly and adaptable to current needs).
Recent Congressional activity indicates a continuing interest in the coordination and
maintenance of geospatial information on the part of our legislative bodies. H.R. 1620, the
Federal Land Asset Inventory Reform Act (March 15, 2011) and its companion S. 1153 would
establish a national cadastre, or map of ownership and boundaries of land parcels. H.R. 4233,
the Map it Once, Use it Many Times Act (March 21, 2012) would establish a National
Geospatial Technology Administration in the DOI to create a National Geospatial Database to
catalogue all federal and non-federal lands. The bill would also create a National Geospatial
Policy Commission to coordinate federal agencies, state and local governments, and private
entities to “eliminate redundancy in the performance of geospatial activities” (Title II, §201(2) of
H.R. 4233).
Department of Transportation, Federal Transit Administration Master Agreement
Beginning with the Federal Transit Administration Master Agreement (FTA MA) (13),
dated October 1, 2006, the FTA included a provision in its Master Agreement to comply with
OMB Circular A-16 requiring recipients to agree to “implement its Project so that any activities
involving spatial data and geographic information systems activities directly or indirectly, in
whole or in part, by Federal assistance, consistent with the National Spatial Data Infrastructure
promulgated by the Federal Geographic Data Committee.” (Changes to FTA Agreements -- FY
2007).
The most recently adopted FTA MA (19), of October 1, 2012, maintains these provisions.
In “Section 35. Geographic Information and Related Spatial Data,” FTA MA (19) stipulates that
“Except as the Federal Government determines otherwise in writing, the Recipient agrees to all
of the following: a. Standards. Its Project activities will conform to the Federal Geographic Data
Committee’s National Spatial Data Infrastructure if those activities directly or indirectly involve:
(1) Spatial data, or (2) Geographic information systems, and b. Federal Guidance. It will follow:
(1) U.S. OMB Circular A-16, “Coordination of Geographic Information and Related Spatial Data
Activities,” August 19, 2002, and (2) U.S. OMB Circular A-16 Supplemental Guidance,
“Geospatial Line of Business,” November 10, 2010.
According to “Section 12. Right of the Federal Government to Terminate,” the Federal
Government may suspend or terminate “all or any part of the Federal funding awarded for the
Project if: (1) the Recipient has violated the Underlying Agreement or this Master Agreement,
especially if that violation would endanger substantial performance of the Project.” (§12 a. (1))
Conclusion
The documents and laws mentioned reveal how the United States Government, its federal
agencies and partners have managed and used geospatial information for well over a century.
There can be little doubt that the federal funding of the Green Line Extension project falls within
the authority and intent of OMB Circular A-16 and FTA Master Agreement, especially because
the GLX project is tied to specific geographic points in order to satisfy the State Implementation
Plan. The inclusion of any federal agencies and partners that “produce, maintain, or use spatial
data either directly or indirectly in the fulfillment of their mission” is a low bar, indeed. That the
operation of the GLX project directly maintains and uses spatial data is not only implicit, but
required by the court mandated SIP.
Compliance to OMB Circular A-16 requires deference to federal standards by both
federal agencies “internally, and through their activities involving partners, grants, and
contracts,” in this case, the MBTA and MassDOT. In evaluating the MBTA’s application for
federal funds, both the FTA and OMB must ensure that all activities conducted on the part of the
applicant allocate resources to “fulfill the responsibilities of effective spatial data collection” and
stewardship; “use FGDC data standards; and “search all sources, including the National Spatial
Data Clearinghouse, to determine if existing federal, state, local or private data meets agency
needs before expending fund for data collection. Further, “before the obligation of funds, [the
agency must] ensure that all expenditures for spatial data and related systems activities financed
directly or indirectly, in whole or in part, by federal funds are compliant with the standards and
provisions of the FGDC.”
The FTA’s commitment to, and agreement with, the federal standards described by OMB
Circular A-16 is evidenced by the internalization of that document into the agency’s Master
Agreement. Any recipient of federal funding through the FTA must agree that all “project
activities will conform to the Federal Geographic Data Committee’s National Spatial Data
Infrastructure if those activities directly or indirectly involve” spatial data. The Master
Agreement also explicitly binds funding recipients to follow OMB Circular A-16 and its
Supplemental Guidance.
Of course, recipients of federal funding must pass this muster as well. Public information
requests reveal that the MBTA, EOT, and MassDOT conducted their planning on the GLX
without reference to OMB Circular A-16 standards, EO12906, or the FTA Master Agreement.
The FTA regional office itself could find no record of due diligence to comply with the FTA
Master Agreement on geospatial requirements. Discussions of geospatial issues by the
Massachusetts Central Transportation Planning Staff also fail to reference the federal standards.
Repeated citizen requests from scores of correspondents have not led state authorities to
reference the federal standard. Continued neglect of federal standards provides prima facie
evidence of disregard for OMB Circular A-16 and its longstanding efforts to establish geospatial
conformity through the federal government.
For these reasons, it is questionable whether the OMB can approve the release of federal
funds toward the implementation of the GLX project until the initiative resolves the geospatial
discrepancies between requirements of the SIP, the directives of the Circular, and its own
mapping references.
As the GLX project is currently operating outside the federal standards defined in the
OMB Circular A-16, the MBTA, MassDOT and Region I of the FTA may have already incurred
irreparable consequences. As MassDOT states in their “State Implementation Plan--Transit
Commitments: 2013 Status Report,” of July 1, 2013, upon enrollment in the New Start pipeline
on June 11, 2012, “the MBTA may be able, in the future, to seek reimbursement from FTA for
expenditures.” Eligibility to “seek such reimbursements depends upon the Green Line Extension
project being able to successfully compete against other public transit projects within the New
Starts program.” 4 Even if the GLX project fulfills the geospatial requirements of the SIP at a
future date, requests for reimbursement for expenditures between June 11, 2012, and the date
compliance is achieved would be placed in competition with projects without such conflicts to
federal standards. Any such expenditures during this period of non-compliance to the SIP, and
hence the Circular, may be deemed disqualified for reimbursement.
Respectfully,
Wilford Durbin,
4
Massachusetts Department of Transportation, “State Implementation Plan--Transit Commitments: 2013 Status
Report,” July 1, 2013, p. 13 ¶2.
Appendix A. History and Background of Circular A-16 5
This Circular was originally issued in 1953, revised in 1967, and revised again in 1990. The Bureau of the
Budget (now the OMB) issued Circular No. A-16 on January 16, 1953. Appended to this Circular were
Exhibits, occasionally revised, that dealt with procedures for programming and coordinating of federal
Topographic Mapping Activities, National Atlas, Geodetic Control Surveys and International Boundaries.
The purpose of the 1953 Circular was "to insure (sic) that surveying and mapping activities may be
directed toward meeting the needs of federal and state agencies and the general public, and will be
performed expeditiously, without duplication of effort." The original Circular references Executive Order
No. 9094, dated March 10, 1942. This Executive Order directs the Director of the Bureau of the Budget to
coordinate and promote the improvement of surveying and mapping activities of the Government.
Furthermore, it passes on functions carried out by the Federal Board of Surveys and Maps, established by
Executive Order No. 3206, dated December 30, 1919. Thus, the OMB is directed to make
recommendations to agencies and to the President regarding the coordination of all governmental map
making and surveying. Executive Order No. 3206 superseded an Executive Order, dated August 10, 1906,
that granted advisory power to the United States Geographic Board to review mapping projects to avoid
duplication and to facilitate standardized mapping.
A revised Circular A-16 was issued on May 6, 1967. The most significant change in this revision is the
addition of a new section on Responsibility for Coordination. This section outlines the responsibilities of
three federal departments (Department of the Interior (DOI), Department of Commerce (DOC) and
Department of State (DOS)). Both the original and the 1967 revision of the Circular focus on providing a
guide for the development of annual programs of the individual agencies and, through the Exhibits,
established extensive reporting requirements.
A second revised Circular A-16 was issued on October 19, 1990. This revision expanded the Circular to
include not only surveying and mapping, but also the related spatial data activities. Specifically, it
included geographically referenced computer-readable (digital) data. In addition, the Exhibits are no
longer referenced and a short reporting requirements section is added.
The 2002 updated Circular calls for continued improvements in spatial data coordination and the use of
geographical data. Objectives for this revision are to reflect the changes that have taken place in
geographic information management and technology, and to clearly define agency and FGDC
responsibilities. The proposed revision displays an integrated infrastructure system approach to support
multiple government services and electronic government.
5
Circular A-16 Revised, White House Office of Management and Budget, Appendix C. Reproduced here in its
entirety.
Appendix B. NSDI Data Themes, Definitions, and Lead Agencies 6
Cadastral: DOI, Bureau of Land Management (BLM)
Cadastral data describe the geographic extent of past, current, and future right, title, and interest in real
property, and the framework to support the description of that geographic extent. The geographic extent
includes survey and description frameworks such as the Public Land Survey System, as well as parcel-byparcel surveys and descriptions.
Cultural and Demographic Statistics: DOC, U.S. Census Bureau (USCB)
These geospatially referenced data describe the characteristics of people, the nature of the structures in
which they live and work, the economic and other activities they pursue, the facilities they use to support
their health, recreational and other needs, the environmental consequences of their presence, and the
boundaries, names and numeric codes of geographic entities used to report the information collected.
Cultural Resources: DOI, National Park Service
The cultural resources theme includes historic places such as districts, sites, buildings, and structures of
significance in history, architecture, engineering, or culture. Cultural resources also encompass prehistoric
features as well as historic landscapes.
Geodetic Control: DOC, NOAA
Geodetic control provides a common reference system for establishing coordinates for all geographic
data. All NSDI framework data and users' applications data require geodetic control to accurately register
spatial data. The National Spatial Reference System is the fundamental geodetic control for the United
States.
Geographic Names: DOI, USGS
This dataset contains data or information on geographic place names deemed official for federal use by
the U.S. Board on Geographic Names as pursuant to Public Law 80-242. Geographic Names information
includes both the official place name (current, historical, and aliases) and locative direct (i.e., geographic
coordinates) and indirect (i.e., State and County where place is located) geospatial identifiers and
categorized as populated places, schools, reservoirs, parks, streams, valleys, and ridges.
Governmental Units: DOC, USCB
6
Selected NSDI Data Themes are sampled from “Circular A-16 Revised,” White House Office of Management and
Budget, Appendix E. The entire list can be view on the White House’s website at
http://www.whitehouse.gov/omb/circulars_a016_rev .
These data describe, by a consistent set of rules and semantic definitions, the official boundary of federal,
state, local, and tribal governments as reported/certified to the U.S. Census Bureau by responsible
officials of each government for purposes of reporting the Nation's official statistics.
Transportation: Department of Transportation, Bureau of Transportation Statistics
Transportation data are used to model the geographic locations, interconnectedness, and characteristics of
the transportation system within the United States. The transportation system includes both physical and
non-physical components representing all modes of travel that allow the movement of goods and people
between locations.
Josiah Lee Auspitz
17 Chapel Street
Somerville, MA 02144
Phone: 617-628-6228, Fax: -9441
E-mail: jlauspitz@comcast.net
August 29, 2013
Ms. Mary Beth Mello, Regional Administrator
Federal Transit Administration Region I
Department of Transportation
Volpe Building
55 Broadway, Suite 920
Cambridge Massachusetts 02142
Dear Ms. Mello:
I write with a friendly but persistent update to my long-standing correspondence with Region I, dating from
December 2009, on the geospatial standards that must be satisfied before federal funds are released for the Green
Line Extension (GLX). I trust that in framing a written response you will review and reconsider the entire file up to
and including the belated verbal response I received late last month at the staff level to the emails to you and your
deputy of May and June 2012. I should especially like to call to your attention the new materials attached to this
letter reviewing the provisions of OMB Circular A-16 and reporting on changes in map labeling at the state level.
These fully confirm the factual basis of my concern.
The specific concern, as you will recall, involves a geospatial discrepancy between the “Medford Hillside”
requirement in the court-mandated State Implementation Plan (SIP) and the Tufts University terminus at College
and Boston Avenues actually chosen for the New Starts application. During the period 2004-2010 in which I served
on citizen advisory panels, the SIP was amended to go beyond Tufts to Medford Hillside, but subsequent to the
amended SIP, map labeIs were altered in ways that either eliminated or underrepresented the difference between
these two places. Whereas the maps used in the “Beyond Lechmere” study properly followed the federal practice
showing Tufts and Medford Hillside as distinct locations, non-standard maps were introduced sometime after the
appearance of an amended SIP in the Federal Register. In the non-standard maps Tufts and Medford Hillside
appeared either as identical or as within the same light-rail catchment radius.
I took this problem to FTA Region I after being informed by responsible officials in both the executive and
legislative branches that any geospatial discrepancy between the SIP and the GLX must be resolved before FTA can
approve final engineering drawings. I was also reliably informed in 2009 that while Congressional and OMB staff
provide a fallback level of oversight on geospatial issues of this kind, the primary responsibility for resolving them
early in the process rests with the regional offices of FTA.
FTA Region I did indeed make a first attempt to resolve the issue by addressing a formal query to state
environmental officials. The result was an official-sounding letter dated July 9, 2010, from the Massachusetts
Department of Environmental Protection (MassDEP) to the Massachusetts Department of Transportation
(MassDOT). It was artfully worded to imply that MassDEP was qualified to “determine” eligibility for federal
funding and that the GLX met the geospatial requirements, without referencing any maps or coordinates. Instead,
the response relied on region-wide air quality standards with no mention of federal geospatial standards or
jurisdictional regulations. It portrayed the conflation of Tufts and Medford Hillside as a trivial matter of
discretionary placement of the GLX terminus (a matter of “exact location”). The response concluded, however,
with a disclaimer acknowledging that the writer lacked geographical expertise and encouraging others to
demonstrate the existence of a “greater Medford Hillside neighborhood .“ The letter had other disqualifying flaws
1
which I noted for you in correspondence. Nevertheless, this letter was thenceforth cited by FTA, the MBTA and
MassDOT as an authoritative resolution of the geospatial issue.
Last month’s telephone response from FTA Region I did not invoke this obviously flawed letter. Instead, the
telephone response I received was that my concern had been jurisdictionally misdirected for these past 43
months. Instead of addressing it to FTA Region I, I am now told, I should have gone exclusively to state agencies,
as indeed scores of other people have done with the same concern. The jurisdictional error on my part, I was told,
was that the issue involved a neighborhood designation (a “populated place” in the technical language of the
United States Geographical Survey) with no legally defined boundaries. Therefore, it was a local matter of
“vernacular usage” to determine just how far this populated place might extend. An example from New York City
was cited: the neighborhood Morningside Heights and Columbia University are interpenetrating, so who is FTA
Region I to say that this might not also be the case for Medford Hillside and Tufts University?
I was further informed that since this was thought to be a purely local issue, there had been no need for any due
diligence on geospatial matters by FTA Region I. As a result, there was, as indeed I had earlier confirmed by means
of a public information request, no internal memorandum or documentation at the federal level that referenced
federal geospatial standards.
* * *
I have attached materials which seem to me to warrant a thoroughgoing reconsideration of the hands-off
approach taken by Region I: a) a draft memorandum reviewing the FTA’s responsibilities under OMB Circular A-16
and the codification of this circular in its own Master Agreement, and b) evidence that the “vernacular usage” cited
as a reason for inaction by Region I has its basis in a non-conforming (and now officially corrected) mislabeling of
maps at the state level by MassDEP.
In the light of these materials, as well as materials in my previous correspondence and in the public archive I have
maintained at www.glxgeography.com, let me summarize and then detail for you the reasons why the response I
have received thus far is inadequate: 1) It appears clearly mistaken on the jurisdictional question; 2) it falls short
of fulfilling the duties of FTA Region I; 3) in a time of fiscal pressure it puts at needless risk the hoped for matching
grant of New Starts funding for GLX; 4) it fails to consider the actual geospatial facts at issue; and 5) it has not yet
made provision for self-corrective or remedial action.
1.
The jurisdictional question
As you may recall, my correspondence was undertaken in December of 2009 at the suggestion of Joyce Rose,
then the Congressional staff expert on the New Starts program, on referral from Thomas E. Petri, the long-time
Chairman of the responsible House authorizing subcommittee for surface transportation. [Ms. Rose has since
retired while Rep. Petri has resumed chairmanship of the subcommittee.] I also touched base with relevant
executive branch personnel in DOT and OMB in Washington.
Those I consulted in both the legislative and executive branches advised me that FTA Region I was the appropriate
jurisdictional locus. Until the telephone communication from your offices last month, no one has suggested that
federal transportation funds can be committed without review of transportation-specific geospatial requirements
at the federal level.
The binding character of federal geospatial requirements has it foundations in OMB Circular A-16, which like other
OMB circulars lays out good government guidelines applying to all federal agencies. Circular A-16 has been in
force since 1953, with periodic updates. Its statutory roots are in Public Law 80-242 of 1947. In a digital age it
remains an area of ongoing legislative and executive branch interest, as evidenced by periodic refinements,
updates, executive orders and congressional studies and proposals. Appendix B of the Circular specifies the lead
agencies for its implementation. For geographic names the Department of the Interior and US Geological Survey
are the lead agencies. The US Department of Transportation is the lead agency for the transportation system,
2
which “includes both physical and non-physical components representing all modes of travel that allow the
movement of goods and people between locations.” Since geospatial requirements are especially salient in its
work within US DOT, FTA has since October 2006 codified the provisions of Circular A-16 internally in its Master
Agreement.
Section 35 of the FTA Master Agreement (“Geographic Information and Related Spatial Data”) internalizes all
provisions and supplemental guidance of Circular A-16. It requires, at pain of possible loss of funding, conformity
to the Federal Geographic Data Committee’s (FDGC) National Spatial Data Infrastructure for those activities which
“directly or indirectly” involve spatial data or geographic information systems. Thus, FTA not only has the
jurisdiction but also the affirmative responsibility to assure geospatial conformity with federal standards in all
transportation projects. As you are aware, the fact that the GLX is a court-mandated response to an
environmental lawsuit does not warrant substituting fulfillment of region-wide environmental standards for
location-specific geospatial conformity: “FTA serves as the lead agency under NEPA for this project.” [Mary Beth
Mello, Finding of No Significant Impact, letter to Richard Davey, July 9, 2012, p.3.]
I have attached a draft memorandum on “OMB Circular A-16 and Related Regulations for Geospatial Information.”
It details the federal requirements and possible funding consequences to projects found in violation of them. It
also addresses the specific case of the GLX. The memorandum was prepared by a Boston College graduate student
in American History with Capitol Hill experience on the staff of the then ranking Democratic member of the House
Appropriations subcommittee responsible for the DOT budget. As the memo is still in draft form, both he and I
would appreciate any comments and corrections from you and your staff.
2.
The responsibilities of FTA Region I
The declared mission of the FTA regional offices is to “work with local transit officials in developing and processing
grant applications.” [from www.fta.dot.gov/documents/RegOffcs.doc] Maintaining friendly relations between
federal regional officers and their counterparts in the state agencies is of course useful in the fulfillment of the
regional mission, but an excess of permissiveness serves no one well. In this case, as noted above, Region I has
thus far neglected to address or document the matter of compliance with OMB-mandated geospatial standards,
and indeed has taken no steps to inform MassDOT that such standards exist. In response to a public information
inquiry, MassDOT itself could find no reference to the relevant federal geospatial standards in the GLX records.
And as we shall see below, the state environmental agency upon which FTA Region I has relied for its certifications
has itself been a source of non-conforming geospatial data.
With respect to Section 35 of the FTA Master Framework, the mission of Region I in “developing and processing
grant applications” remains incomplete for the level of advanced preliminary engineering that has been certified.
Region I did not take the opportunity of the mandatory risk assessment workshop to address the geospatial issues,
though the workshop did identify New Starts funding as one of the top two major risk factors on its multi-pronged
rating system. A further risk assessment workshop is scheduled in the coming fiscal year prior to the next
milestone (the FFGA, or Full Funding Grant Agreement). But as we shall see in the next section, there are
significant financial risks to the Commonwealth and to the GLX in anything less than an expedited approach to the
geospatial issue.
3.
The financial risks of inaction and delay
Your own letter of “Preliminary Engineering Approval” to the DOT Secretary dated June 11, 2012, puts the matter
well: “As with all pre-award authority, all Federal requirements must be met prior to incurring costs in order to
retain eligibility of the costs for future FTA grant assistance.” It would seem to follow, as the attached draft memo
suggests, that until OMB geospatial requirements are fulfilled, costs incurred may prove ineligible for
reimbursement. Since state monies are already being advanced to the GLX in expectation of partial
3
reimbursement —and the commencement of the 2014 fiscal year will soon accelerate the rate of expenditure—
the case is overwhelming for a prompt and expedited resolution of all outstanding issues.
The gross sums potentially involved are reported in your own letter of June 11, 2012: it put the federal grant
request at $557.06 million out of a total budget of $1,334.62 million, including contingencies. The expenditures
will be phased, with $131 million to be released by MassDOT in fiscal year 2014 in the expectation of up to 50% in
reimbursements if the New Starts grant comes through. On a prorated basis at a hoped for 50% reimbursement
rate, the financial exposure is just under $180,000 for every day in fiscal 2014 that GLX operates outside the
geospatial requirements of OMB Circular A-16 as further embodied in FTA Master Agreement Section 35.
It is worth noting that Congressman Capuano, who sits on the above-mentioned surface transportation
subcommittee, reports [August 2013 Newsletter] that the current House funding proposal contains, as he had long
forewarned, a substantial cutback in New Starts funding. Whether or not this level of cutback is finally voted
through, the proposed bill indicates that New Starts, which has had broad bipartisan support in the past, will face
future challenges in taking on new projects. Until the geospatial issue is addressed decisively, GLX may have to
compete for a shrinking budget against projects unencumbered with OMB irregularities.
4.
The geospatial facts and “vernacular usage”
On the matter of “vernacular usage” there is new documentation that should put a definitive end to all speculation
about whether Medford Hillside and Tufts University are interpenetrating places, on the supposed model of
Morningside Heights and Columbia University. With the permission of John Roland Elliott, the most thorough
researcher into the local geography, I attach the full text and map illustrations of his recent correspondence with
MassGIS, dated July 31 through August 21 of this year.
Since 2006 MassGIS has continuously developed and improved the interactive map called OLIVER. Mr. Elliott
noticed that though the Medford Hillside center point in OLIVER conformed, when queried, to the geographical
coordinates that had been established in the federal standard since 1974, the “Medford Hillside” label on
continuous view in its basemap was inexplicably placed at a far remove from this center point, in a position
adjacent to Tufts University. OLIVER’s MassGIS Statewide Basemap labeling, the feature most visible to the casual
observer, was, in other words, out of alignment with the federal standard. By contrast, the planning maps used by
the City of Medford as well as most of the other local usages Elliott had surveyed in a 2008 publication conformed
to the federal standard. The USGS and City of Medford usages, which seemed most relevant, were, as he put it, in
“an area entirely non-overlapping with MassGIS Statewide Basemap’s label for it.” He proposed that the Medford
Hillside label be moved from a position adjacent to Tufts University to a placement close to the geographical
coordinates established in 1974 in the federal registry of geographical names. This was not merely the federal
practice but the overwhelming vernacular usage: Elliott provided a summary table of his 2008 survey of maps and
archival materials on Medford Hillside, which he had submitted through the GLX public outreach process.
MassGIS agreed that the non-conforming labeling was a “mistake, which will be corrected.” [email of August 1].
It made the map change on August 21, 2013. It described the previous label as a “bogus placement” [email of
August 12] by interns in the employ of the Massachusetts Department of Environmental Protection (MassDEP)
using antiquated USGS materials. [email of August 21.]
With the corrected label placement and the addition of a cadastral layer displaying tax-paying versus tax-exempt
properties, OLIVER now is transparent to the casual observer. It displays Tufts as a largely contiguous, all-white
(tax-exempt) area surrounding the junction of Boston and College Avenues, where the GLX station will be situated.
Medford Hillside is displayed as a distinct area to the northwest, which would fall mostly within a catchment area
4
to be served, along with adjacent environmental justice communities, by the proposed GLX add-on to Route 16.
This is the same picture to be found on all other digital maps, since the federal standard has been incorporated by
Google, Microsoft, and others. Tufts is usually shaded to distinguish it from privately-owned property. The
cadastral and catchment pattern here is quite different from that of Columbia University and Morningside Heights,
as any inspection of the actual maps will confirm.
For FTA’s limited purposes the salient facts would appear to be: 1) there is now no discrepancy either in
geographical coordinates or in map legends between Massachusetts GIS and USGS geospatial representations of
Medford Hillside—these maps all reflect the overwhelming vernacular usage both currently and historically; 2)
there remains a significant geospatial discrepancy between the SIP designation of Medford Hillside and the
proposed GLX terminus at the junction of Boston and College Avenues, a point surrounded by Tufts University land
and having a catchment area that excludes most of what is locally understood as Medford Hillside; 3) until the
action by MassGIS on August 21, 2013, no official at either the state or federal level had done due diligence to
conform the Medford Hillside location to the federal geospatial standards required by OMB Circular A-16; 4) there
is now a documented record of non-conforming geospatial practice by MassDEP during the period in which both
FTA and MassDOT have deferred to this agency for an authoritative SIP geospatial determination.
5.
Remedial Action
Given the facts and circumstances, FTA would seem minimally obliged to require conformity with federal
geospatial standards prior to the next milestone. Given the reimbursement risk, an expedited resolution is in
order. I am aware that FTA can only be party to a resolution that will require back-and-forth discussions with state
agencies and other stakeholders-- but also that FTA plays in this case an inescapable catalytic role.
There are two aspects to the problem: de facto and de jure conformity.
A de facto remediation has long been underway in the form a lagged commitment to restore Route 16 as the
northern Green Line terminus. Route 16 was designated by MassDOT as its preferred alternative, but was
chopped at the time GLX was charged with the very substantial costs of the Lechmere station relocation that were
to have been borne by private developers.
The Route 16 terminus, as is well known, more than fulfills the Medford Hillside requirement. It would have a light
rail catchment area that includes-- as the Tufts University catchment area does not-- not only the Hillside
neighborhood but also six tracts in Medford and Somerville designated on income and/or racial grounds as
“environmental justice” communities, as well as a subsidized elderly housing project in the each of the two cities.
It would also have strong economic development potential not possible for a terminus surrounded by university
land. It would sit astride a main artery that will attract ridership from surrounding communities without sending
kiss-and-ride vehicular traffic down an already congested, stop-and-go Boston Avenue to Tufts University. Every
transportation planner who looks at GLX understands quickly all these advantages. In New Start metrics it adds a
mile of distance at a relatively low cost.
As a result there has been, on the merits more than the legalities, a concerted movement within the
knowledgeable transportation community to restore Route 16 at a later phase. By an overwhelming vote MPO has
included it in its long-term plans and pledged outlays to it. MAPC has conducted a study of its economic
development potential. Key environmental studies are in readiness from the period that Route 16 was part of the
GLX. But MassDOT has exhibited more reluctance: it has neglected to revise cost estimates for Route 16 which
include high-priced land takings that have proven unnecessary; it has configured its mitigation measures to underrate enhanced bus service to the communities that would be served by Route 16; it has in the past moved to delay
MPO research that would accelerate the readiness of Route 16.
5
The easiest course might be to tighten the nexus between the de jure and de facto aspects with some quasibinding device such as a memo of understanding or letter of intent that would include specific actions to
accelerate the readiness of Route 16. It may require some creative lawyering to do this in a way that is OMBacceptable, but the stakes warrant resourcefulness. The mere presence of Route 16 in the TIP does not suffice to
pass geospatial muster for the current New Starts application because there is no documentation tying it to that
application.
An acceleration of Route 16 readiness may also be useful in the event that future competitiveness for New Start
funds should require a higher cost-effectiveness rating or some reconfiguration of the project. The GLX’s slipping
to a medium-low grade on the heavily weighted cost-effectiveness metric could prove its undoing.
Should one simply amend the SIP? Amending the SIP to replace “Medford Hillside” with “Tufts University” or
“College Avenue” is a theoretical possibility that would not be well received. Amending it to include Route 16 by
name, which I had earlier suggested, seems superfluous, since Route 16 already meets the Medford Hillside
requirement. In both cases, the amendment process could set back the clock and further delay the project.
* * *
When I began this correspondence in 2009 I stated that my desire was to flag early an issue that would prove
increasingly troublesome as the GLX project progressed. I am, as you know, a strong supporter of this project and
would like to see it successfully funded. I understand that FTA Region I, by acting on the materials I have enclosed,
will place itself in the uncomfortable position in which they have also placed me.
I am therefore all the more appreciative of your kind attention.
Sincerely,
Josiah Lee Auspitz
END NOTE: For the sake of completeness, I should mention another non-conforming practice by an agency usually relied upon
for professional advice: the use of a one-mile catchment area for the “Walk Market” memoranda prepared in 2010 by the
Central Transportation and Planning Staff (CTPS). At the time the CTPS memos were composed, the catchment area they
proposed did not conform to the half- mile norm for light rail New Starts projects [see July 2008 update of Reporting
Instructions for Section 5309 New Starts Criteria, pp 50-51, items #2,4 and 6.] CTPS reverted to a one-half mile catchment area
two years later in designing mitigation measures for the GLX delay. Though defining a neighborhood by its unified socioeconomic character, the memos proceed to portray Tufts and Medford Hillside on topographical grounds as forming a “greater
Medford Hillside neighborhood” by virtue of falling within a one-mile radius of the proposed College Avenue station. This work
was criticized in withering detail by several respondents to the FEIR, including myself, for self-contradictions and scholarly
errors, for methodological irregularities, for neglecting the federal standard, for giving priority to non-conforming over
conforming maps, for confusing the use of the word “Hillside” as an intramural Tufts College term referring to “College Hill”
with the usage for a neighborhood beyond the university precincts, as well as for using a non-conforming one-mile catchment
radius. JLA
Enclosed: 1) DRAFT MEMO: OMB Circular A-16 and Related Regulations for Geospatial Information
2) MassGIS Correspondence of John Roland Elliott, July 31 to August 21, 2013
Cc: Tom Bent, John Roland Elliott, John Lenicheck, Raphael Mares, Denise Provost, Carl Sciortino
6
From:
To:
Cc:
Subject:
Date:
Mark Nahabedian
Fichter, Katherine (DOT); jerome.grafe@state.ma.us
friendspath@yahoo.com
Supporting GLX, CPX, Fairmount Line, Red-Blue Connector, and GLX Mitigation
Thursday, September 19, 2013 6:00:31 PM
To Kate Fichter and Jerome Grafe:
I'm writing is support of the transportation agenda espoused by the Friends of the
Community Path, whose statement is included below.
Particularly important to me are personally are:
Connecting the Red and Blue lines,
A complete connection of the Minute Man Trail all the way through to Lechemere Square,
and the Green Line extension.
I deplore the fact that wealthy special interests were able to block the Red to Blue line
connection each time it's been proposed in the past.
Points 3 and 4 of the Friends agenda are less important to me since I don't live along the
right of way.
Thank you for your consideration and your devotion to public service.
Sincerely,
Mark Nahabedian
66 Prospect Street
Cambridge MA 02139-2503
Message from Friends of the Community Path:
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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major
remaining transit/air quality mitigation commitments from the Big Dig. I appreciate that
MassDOT is moving ahead with the GLX. I urge that the full Community Path Extension
(CPX) be built as soon as possible and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines
connector and eliminate it from the SIP. I urge the DEP to reject this requested SIP
revision.
I support the following with respect to GLX environmental offset/mitigation projects for the
GLX delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North
Point, as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of
the GLX air quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely
populated area. Diesel emissions are classified by WHO as a Class 1 carcinogen
just like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also
provide a financial incentive for timely project completion
Thank you,
Mark Nahabedian
66 Prospect Street
Cambridge MA 02139-2503
From:
To:
Subject:
Date:
Max Morrow
jerome.grafe@massmail.state.ma.us; Fichter, Katherine (DOT)
Supporting GLX, CPX, FAIRMONT Line, Red-Blue Connector and GLX Mitigation
Friday, September 20, 2013 7:39:47 AM
To Kate Fichter 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/2013%20SIP%20Annual%20Report%20%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining
transit/air quality mitigation commitments from the Big Dig. I appreciate that MassDOT is moving
ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as possible
and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and
eliminate it from the SIP. I urge the DEP to reject this requested SIP revision.
My wife and I moved to Somerville a year ago and the biking amenities, with the
prospect of more, have become perhaps the most significant factor in the love we
have for the area. It is also obvious that this sentiment is widespread from the
observation of utilization. The benefit to the community is enormous in many ways
and the expansion of the system would be a high priority.
Jeffrey S Morrow, M.D
Sandra B Morrow
From:
To:
Subject:
Date:
Lee Auspitz
Fichter, Katherine (DOT)
RE: Comment letter on SIP 2013 Status Report
Friday, September 20, 2013 11:30:53 AM
Kate,
To be more exact I have made a correction in the second paragraph under #1 below to read 50% of
the prorated 2014 expenditures, since the 180K/day figure is calculated on the hoped for 50%
reimbursement not on the total $131M cost. I hope you can insert this.
Lee
From: Fichter, Katherine (DOT) [mailto:katherine.fichter@state.ma.us]
Sent: Friday, September 20, 2013 10:47 AM
To: Lee Auspitz
Subject: RE: Comment letter on SIP 2013 Status Report
Lee –
I definitely will.
Thank you,
Kate
Kate Fichter
Manager of Long-Range Planning
Office of Transportation Planning - Massachusetts Department of Transportation
Ten Park Plaza, Room 4150, Boston, MA 02116
857.368.8852 - Please Note New Telephone Number!
From: Lee Auspitz [mailto:jlauspitz@comcast.net]
Sent: Friday, September 20, 2013 10:45 AM
To: Fichter, Katherine (DOT)
Subject: RE: Comment letter on SIP 2013 Status Report
Thanks, Kate. Please also add the attachments. Lee
From: Fichter, Katherine (DOT) [mailto:katherine.fichter@state.ma.us]
Sent: Friday, September 20, 2013 10:04 AM
To: Lee Auspitz
Subject: RE: Comment letter on SIP 2013 Status Report
Lee –
Many thanks for this. I’ll add your letter to the official 2013 SIP record.
Best,
Kate
Kate Fichter
Manager of Long-Range Planning
Office of Transportation Planning - Massachusetts Department of Transportation
Ten Park Plaza, Room 4150, Boston, MA 02116
857.368.8852 - Please Note New Telephone Number!
From: Lee Auspitz [mailto:jlauspitz@comcast.net]
Sent: Thursday, September 19, 2013 5:53 PM
To: Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.us
Cc: mary.mello@dot.gov
Subject: Comment letter on SIP 2013 Status Report
Subject: Comment letter on 2013 SIP transit commitments annual report
Dear Ms. Fichter and Mr. Grafe:
While I remain cognizant and respectful of the many years of dedicated professional work
and volunteer commitment that have gone into the Green Line Extension (GLX) I note the
following topics in the current status update that require attention:
1. Non-conformity to OMB geospatial requirements.
This issue is summarized in the attached letter to the FTA Regional Administrator
(“MelloLtr.Aug2013”). In a nutshell there is a discrepancy between the Medford Hillside
requirement of the SIP and the current plan to end the GLX at a station surrounded by Tufts
University. This geospatial discrepancy threatens both the future eligibility for New Starts
funding in a highly competitive environment and, in the event an award is made, the
eligibility of GLX for retroactive reimbursement of funds scheduled for expenditure during
the current 2014 state fiscal year.
I have also attached a draft memo, included in the submission to FTA Region I, briefly
summarizing the history of OMB geospatial requirements as embodied in Circular A-16 and
detailing their internal codification in Section 35 of the FTA Master Agreement. (This memo
will be put into final form after comments are received from FTA and Congressional
transportation specialists, and stakeholders in the GLX. Thus far, no critical comments have
been received on the substantive content.) The self-corrective mechanisms available to FTA
at the regional level are adequate to resolve the issue before an FFGA is issued. Of course,
by law the final non-judicial arbiter of compliance with OMB Circular A-16 is the OMB itself.
There are also two tracks of litigation—environmental and “qui tam”—for which standing
requirements are broad. It seems likely that the merits of this issue will receive attention at
some level through the checks and balances of our democratic system. The arguments for
doing this sooner rather than later now have a price tag: $180,000 per day during 2014
(50% of the prorated 2014 expenditures for phase I) in forfeited reimbursements for every
day of non-conformity.
It compounds the problem that there has been no serious attempt to research federal
geospatial standards either in general or for Medford Hillside by EOT/MassDOT, MassEPA, or
the Central Transportation Planning Staff during the several years in which this issue has
been called to their attention by scores of individuals, including the overwhelming
preponderance of stakeholders, elected officials and citizen advisory group members. To
the contrary, all three of the agencies mentioned, have issued non-conforming maps,
memoranda and mutually supportive letters of determination that promote a false sense
that the Medford Hillside requirement of the SIP is geospatially fulfilled by the current plan
to limit the GLX New Starts project to a Tufts University terminus at College and Boston
Avenues.
At the same time, it is encouraging that outside the formal structure of the GLX, the Boston
Area MPO has included the full extension to Route 16 in its long-term plan (TIP) and set
target funds for its initial planning and MAPC has completed an economic development
study for this terminus . Those behind these developments understand very well that the
Route 16 terminus satisfies both the legal Medford Hillside requirement and the intent
more generally that the GLX serve a broader ridership and spark economic development not
available around a station almost entirely surrounded by university-owned land. However,
as with the Urban Ring, TIP inclusion may be evanescent. The nexus between Route 16 and
the GLX is at best informal. There are various ways of tightening this nexus: memoranda of
understanding, letters of intent, formal amendment, legislative resolution, reconfiguration of
GLX itself. A prompt consideration of this issue is long overdue.
2. Using Boston Engine Terminal land for VMSF office and parking space
While it is good to hear that land taking for the Vehicle Maintenance and Storage Facility will
be closely scrutinized, the parameters given to the independent evaluators would appear to
exclude vacant land already owned by the MBTA in the adjacent Boston Engine Terminal.
The series of consulting studies ruling out any use of BET land has been remarkable for
overstating the problem, as if to defend a Chinese wall between the MBTA commuter rail
subcontractor at BET and the MBTA itself at VMSF: arguments that any sharing would
require joint use of the same track by heavy and light rail in violation of federal regulations,
an entire study of the infeasibility of superimposing a VMSF building over the existing heavy
rail repair building, and (though I am not aware of their publication) technical data citing
elevation and engineering issues against any use of vacant BET land. The simple issue to be
addressed, however, is whether some new takings can be obviated by the use of vacant BET
land for office and parking space. As the FTA-commissioned risk study cited VMSF takings as
one of the two highest risk/cost factors, it behooves both MassDOT and FTA to reexamine
the savings from using BET land for ancillary VMSF functions.
3.
Mitigating a new pollution/congestion hotspot in the actual Medford Hillside
NEPA requires that environmental “hotspots” not be submerged in the large numbers of
what may appear to be regionally benign pollution ratings. For any period in which the Tufts
University station at College and Boston Avenues functions as a terminus without the further
terminus at Route 16, there will be a predictable hotspot in the actual Medford Hillside
neighborhood and its approaches. The two vehicular approaches to the Tufts station are a)
up the steep Winthrop Street hill from Route 16, and b) across a mile of slow stop-and-go
traffic along Boston Avenue from Route 16. Current studies indicate that the
Winthrop/Route 16 intersection is the second most polluted in the GLX area, while the
Route 16/Boston Avenue intersection is the second most heavily trafficked. The spillover
from these two sites by kiss-and-ride drop-offs will create predictable air quality and traffic
problems that do not appear to be given weight in current MassDOT mitigation plans.
*
*
*
As in the past, I appreciate the opportunity to contribute to the discussion through one of
the many venues our system of government provides. If there are any flaws or
misconceptions in the attached memo on OMB Circular A-16, I would welcome criticisms.
Sincerely,
Lee Auspitz
617-628-6228
From:
To:
Cc:
Subject:
Date:
Attachments:
Grafe, Jerome (DEP)
Fichter, Katherine (DOT)
Kirby, Christine (DEP); Blanchet, Richard (DEP); Ciborowski, Matthew (DOT) ; Maureen Kelly
Pub Mtg - written comments
Friday, September 20, 2013 3:46:43 PM
Pub Mtg scan comments Kyper, Sierra Club.pdf
Pub Mtg scan comments Wood, GLAM.pdf
Hi Kate,
MassDEP received a total of 33 separate written comments. Several of which were formulated from a template, but were sent from individuals. The
2 attached comments were the only hard copy mailed versions, the 2 copied below were emailed, but without your address and the remaining 29
were emailed to both of us so I assume you received those too.
Thanks!
Jerome
First forwarded comment:
To Kate Fichter and Jerome Grafe:
I and my children live in Somerville which has some of the worst air quality in Massachusetts due to excessive car
traffic. Please help reduce traffic and improve air quality in our neighborhood by completing the GLX on time! And
include the community path in this extension to encourage more cycling and walking. There's no time to waste.
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining transit/air quality
mitigation commitments from the Big Dig. I appreciate that MassDOT is moving ahead with the GLX. I urge that the
full Community Path Extension (CPX) be built as soon as possible and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and eliminate it from the
SIP. I urge the DEP to reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay past its legal
deadline:
1.
Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as soon as possible.
2.
Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air quality and
environmental benefits.
3.
Reject any new diesel rail stops on commuter rail lines through this densely populated area. Diesel emissions
are classified by WHO as a Class 1 carcinogen just like smoking and asbestos.
4.
Provide free transit and Hubway programs during the GLX delay, which will also provide a financial incentive for
timely project completion
Thank you.
Susan Hamilton
223 Morrison Ave
Somerville, MA 02144
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Second Forwarded comment:
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/2013%20SIP%20Annual%20Report%20-%20final.pdf
I support completing the Green Line Extension (GLX) and the Fairmount Line, the major remaining transit/air quality mitigation commitments from
the Big Dig. I appreciate that MassDOT is moving ahead with the GLX. I urge that the full Community Path Extension (CPX) be built as soon as
possible and that the GLX be built to Route 16.
I disagree with MassDOT’s recommendation to stop the design of the Red/Blue Lines connector and eliminate it from the SIP. I urge the DEP to
reject this requested SIP revision.
I support the following with respect to GLX environmental offset/mitigation projects for the GLX delay past its legal deadline:
1. Build the full CPX, from Lowell Street all the way to the paths at Lechmere/North Point, as soon as possible.
2. Accelerate other regional bike/ped paths and facilities equal to 50% or more of the GLX air quality and environmental benefits.
3. Reject any new diesel rail stops on commuter rail lines through this densely populated area. Diesel emissions are classified by WHO as a
Class 1 carcinogen just like smoking and asbestos.
4. Provide free transit and Hubway programs during the GLX delay, which will also provide a financial incentive for timely project completion
Regards,
Courtney O'Keefe | Ward 5 Alderman
WWW.CourtneyOKeefe.Com
WWW.Ward5Online.Com
2013 SIP Public Meeting Summary
State Implementation Plan Public Meeting
Massachusetts Department of Environmental Protection and the Massachusetts
Department of Transportation
September 12, 2013 – 1:30 PM to 2:15 PM and 5 PM to 6 PM
Massachusetts Department of Environmental Protection
One Winter Street
Washington Street Conference Center
Boston, MA
Attendees at Afternoon Session:
Nancy Farrell, Regina Villa Associates
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection (DEP)
Christine Kirby, Director of Transportation Program, DEP
David Mohler, Executive Director, Office of Transportation Planning, Massachusetts
Department of Transportation (MassDOT)
Neema Chaiban, Conservation Law Foundation
Kate Fichter, MassDOT
Jerome Grafe, DEP
Maureen Kelly, Central Transportation Planning Staff (CTPS)
Rafael Mares, Conservation Law Foundation (CLF)
Anne McGahan, CTPS
Carolyn Rosen, Green Line Advisory Group of Medford (GLAM)
Leonard M. Singer
William Wood, GLAM
Wig Zamore, Somerville Transportation Equity Partnership
Attendees at Evening Session:
Nancy Farrell, Regina Villa Associates
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection (DEP)
Christine Kirby, Director of Transportation Program, DEP
David Mohler, Executive Director, Office of Transportation Planning, Massachusetts
Department of Transportation (MassDOT)
Paul Christner, Massachusetts Port Authority
Matthew Ciborowski, MassDOT
Jerome Grafe, DEP
Maureen Kelly, CTPS
Anne McGahan, CTPS
Alan Moore, Friends of the Community Path
Elin Reisner, Somerville Transportation Equity Partnership
1
2013 SIP Public Meeting Summary
Introduction
Nancy Farrell, moderator, opened the annual meeting on the 2013 annual report on the
State Implementation Plan (SIP) by reviewing the purpose of the meeting and the
guidelines for personal conduct at the meeting. Then Nancy Seidman, Assistant
Commissioner, Bureau of Waste Prevention, DEP, provided background information
regarding the meeting in the overall regulatory context of the SIP, public process
requirements, which are articulated in subsection (7) 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 SIP in July 2008.
Under this regulation MassDOT is required to submit an annual status report on all
uncompleted SIP requirements and submit that report to DEP. DEP is then required to
hold 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.
Written testimony on the SIP will be accepted until 5 PM on September 19, 2013.
Written comments may be sent to Kate Fichter, MassDOT Office of Transportation
Planning, Room 4150, Ten Park Plaza, Boston, MA 02116 or
Katherine.Fichter@dot.state.ma.us; and Jerome Grafe, DEP, Bureau of Waste Prevention,
One Winter Street, Boston, MA 02018 or Jerome.Grafe@state.ma.us.
Ms. Seidman noted that DEP’s certification letter regarding MassDOT’s 2012 SIP report
was issued on May 6, 2013. DEP determined that MassDOT met public process and
annual reporting requirements. The certification letter is posted on MassDOTs website
at: http://www.massdot.state.ma.us/Portals/17/docs/sip/DEPApprovalAfMassDOT
12313TransitSubmittal.pdf.
Status Report
David Mohler, Executive Director of MassDOT’s Office of Transportation Planning,
provided a summary of the status of the remaining three SIP commitments. A written
status report is available on MassDOT’s website at http://www.massdot.state.ma.us/
Portals/17/docs/sip/2013%20SIP%20Annual%20Report%20-%20final.pdf.
MassDOT is no longer reporting on the ‘1,000 New Parking Spaces’ requirement because
that commitment has been satisfied.
There has been no change in the status of the Red Line - Blue Line Connector (design)
project since last year’s report. MassDOT has petitioned DEP to amend the SIP to
remove this requirement and is not recommending a substitution project since design of
the project would not produce any air quality benefits.
2
2013 SIP Public Meeting Summary
Three new rail stations have opened on the Fairmount commuter rail line as part of the
Fairmount Line Improvement Project. Four Corners, Talbot Avenue, and Newmarket
Stations opened in July 2013. Blue Hill Avenue Station is still in design and MassDOT is
in discussion with abutters to the proposed station. A construction date and anticipated
completion date have not yet been set. As mitigation for the delay in the construction of
the complete Fairmount Line Improvement Project, MassDOT is running a shuttle service
on MBTA bus route #CT3 between Andrew Station and Boston Medical Center and
increasing the frequency of weekday service on the route #31 bus. These mitigation
measures will be in effect at least until the last station is opened on the Fairmount Line.
Phase 1 of the Green Line Extension project is now under construction. Phase 1 includes
the widening of the Harvard Street Bridge in Medford and Medford Street Bridge in
Somerville, as well as the demolition of the MBTA-owned building at 21 Water Street in
Cambridge. MassDOT has awarded a Construction Manager/General Contractor
(CM/GC) contract to White/Skanska. The first tranche of $7.1 million in funding has
been awarded.
MassDOT will be awarding the second tranche of funding soon for the design and
construction of Phase 2. This Phase includes the extension of the mainline to a new
station at Washington Street, the relocation of Lechmere Station, and the construction of
a spur track to serve a new station at Union Square. Phase 3 of the project will be the
construction of a Green Line vehicle maintenance facility. Phase 4 will extend the
mainline from Washington Street to the line’s terminus at College Avenue.
MassDOT is seeking funding for the project through the federal New Starts program and
hopes to have 50% federal participation for the $1.3 billion project. Regardless of the
ultimate availability of federal funding, the Commonwealth remains fully committed to
the project. MassDOT will be submitting an update to the Federal Transit Administration
(FTA) this fall and hopes to have federal funding available for the project at the
beginning of the next calendar year.
MassDOT expects to award a contract for vehicle design and manufacture early in
calendar year and to have vehicles delivered in the autumn of 2017. MassDOT has
executed a memorandum of understanding with City of Somerville for acquisition of land
around the Union Square station site.
Because MassDOT will not meet its deadlines on the project, it has an internal working
group preparing a mitigation plan that will be submitted to DEP no later than December
31, 2013 and implemented by December 31, 2014.
3
2013 SIP Public Meeting Summary
Oral Testimony – Afternoon Session
Carolyn Rosen, GLAM
Ms. Rosen spoke in regards to the Green Line Extension project. First, she alleged that
Tufts University has received ‘mitigation money’ from MassDOT and that this
information should be made public. Then she spoke regarding a lawsuit brought by
GLAM, William Wood, and herself that accuses MassDOT of violating the NEPA
process. She stated that MassDOT has taken a conservative, anti-environmental position
in response to the lawsuit, while GLAM has taken the more liberal position of ‘ecosystem
protection’ and the protection of people with disabilities and civil rights.
She raised concerns about MassDOT’s failure to study the potential negative health
impacts from carcinogenic diesel particulate matter pollution (from Commuter Rail
trains) on vulnerable populations. She also alleged that MassDOT failed to analyze and
disclose the effects of diesel particulate matter/hot spots (from Commute Rail trains) on
local residents. Further, Ms. Rosen alleged that in failing to evaluate the local air quality
impacts (of the Green Line Extension project) when preparing the Environmental
Assessment for the project, MassDOT has gone against FTA guidelines that require that
the aggregation of emissions data at a regional level should not obscure local details.
Ms. Rosen accused MassDOT of violating the NEPA process and the civil rights of
environmental justice populations in the project area in an attempt to keep the
planning/design process running on time. She pointed to FTA deficiency reports (Title VI
and ADA) that document violations in MassDOT’s approach to public engagement, and
said that in the process that accompanied the development of the Environmental
Assessment, MassDOT deprived civil rights groups of their Constitutional rights causing
irreparable harm (under NEPA) to those populations.
Ms. Rosen reported that a federal court has dismissed the lawsuit brought by GLAM and
that the organization could not afford a ‘retainer’ to continue the lawsuit. The lawsuit
being brought by Ms. Rosen and Dr. Wood, however, is still under review.
Ms. Rosen submitted written comments.
Rafael Mares, Conservation Law Foundation
Mr. Mares noted that, over the past year, there has been cause for celebration due to the
groundbreaking of the Green Line Extension project and the ribbon cutting for the new
Fairmount Line stations, but that the Conservation Law Foundation continues to have
several concerns about MassDOT’s compliance with the SIP.
He expressed concern that a 19-month delay in completion of the Green Line Extension
project has not been explained in the SIP report. While a risk assessment document
notes that the project would be complete by 2017, the new completion date is July 2019.
4
2013 SIP Public Meeting Summary
He stated that all interim offset projects proposed by the public to mitigate for the project
delays should be modeled and that the public should be involved in their selection.
Further, he said that the interim offset projects should be implemented within the Green
Line Extension corridors. He also called for MassDOT to provide a funding plan and to
include the extension of the Green Line to Route 16 in the SIP report.
Regarding the Fairmount Line Improvement project, Mr. Mares asked that MassDOT
provide a more concrete timeline for the construction and completion of the Blue Hill
Avenue Station to the public.
He stated that the Red Line/Blue Line Connector (design) project should not be removed
as a requirement of the SIP. If it is removed, he alleged, a substitution project would be
required under the SIP regulations.
He also called for MassDOT to continue reporting on the 1,000 New Parking Spaces
requirement until all the new spaces are in place. He noted that spaces at Wonderland
Station have not yet been reserved for transit riders. He also noted that it is important to
understand the distinction that, under the SIP, MassDOT is required to construct new
spaces, not just open new spaces.
Lastly, he asked that MassDOT continue to report on the Blue Line Modernization
project considering that modernization work is still occurring at Orient Heights Station
and will be occurring at Government Center Station next year.
The Conservation Law Foundation will be submitting written comments.
Wig Zamore, Somerville Transportation Equity Partnership
Mr. Zamore began by discussing diesel particulate matter pollution. He said that studies
show that it is the pollutant most responsible for environmental justice disparities in the
United States because environmental justice populations often live near rail and trucking
corridors and because environmental safety does not always get the consideration it needs
in the inner cities. He expressed opposition to the use of Diesel Multiple Units on the
Fairmount Line corridor for that reason.
He then discussed concerns about ozone pollution, noting that a scientific advisory
committee making recommendations to the U.S. EPA has advised that stricter ozone
standards are needed. He said that the link between ozone and negative public health
outcomes and mortality has been strengthened by recent studies, including an American
Cancer Society study.
He went on to say that there is no longer thought to be a safe threshold for the pollutant
PM 2.5 and that this pollutant is now considered to be driving mortality outcomes for
about ten percent of the U.S. population. PM 2.5 from diesel emissions is associated with
lung cancer, he said.
5
2013 SIP Public Meeting Summary
Further, he discussed research being conducted by the Somerville Transportation Equity
Partnership and Tufts University that is finding a relationship between cardiovascular
health and subjects’ proximity to roadways. He pointed to other studies that show that
people who live near roadways suffer higher rates heart disease, asthma, and autism.
Mr. Zamore expressed support of the expeditious completion of the Green Line
Extension project to Route 16 with the Community Path integrated. He said that the
project represents MassDOT’s best opportunity for achieving its mode shift goals. He
made suggestions for interim offset projects to mitigate for delays in the project: offering
free transit rides in areas that do not receive Green Line service on time; and putting air
pollution filtration devices in schools near highways and diesel corridors.
In closing, he discussed the merits of Europe’s electric rail systems.
William Wood
Dr. Wood opened his remarks by thanking the Somerville Transportation Equity
Partnership for conducting their air quality research. He then noted that the president of
the Medford chapter of the NAACP is opposed to the Green Line Extension to Route 16.
Dr. Wood then suggested that MassDOT is perjuring itself in court, as there is no funding
to extend the Green Line to Route 16 until FFYs 2020-25.
He cited information from a business newsletter, which, he said, reports that state
governments could be facing $4.4 billion in cuts later this year due to the federal
sequester. Dr. Wood alleged that the people who will likely lose their jobs will be
‘people of color, gays and lesbians, people who are disabled, and women.’ He noted that
GLAM represents those groups and that MassDOT does not have their participation in
the Green Line Extension project.
He faulted the SIP report for not reporting which experts it used to determine that
alternative transportation is needed to take cars off the road. He referenced a study that
determined that there would not be enough ridership to make the Green Line Extension to
Route 16 economically viable, and he said that more studies are needed. Dr. Wood also
asked why ‘mitigation money’ given to Tufts University has not been made public.
He expressed GLAM’s opposition to extending the Green Line to Route 16, though noted
that the group does not oppose the extension to College Avenue. He noted that there are
fears in his community because the Route 16 option remains on the table. People, he
said, are fearful of having their homes taken, and they are fearful that the extension will
benefit Somerville at the expense of Medford. He also expressed that MassDOT and the
Conservation Law Foundation have taken a conservative, anti-environmental position in
regards to this project.
He stated that GLAM will continue to fight the extension to Route 16 and to put political
pressure on state to lower funding for that portion of the project.
6
2013 SIP Public Meeting Summary
Oral Testimony – Evening Session
Alan Moore, Friends of the Community Path
Mr. Moore spoke on behalf of the Friends of the Community Path, a citizen organization
of over 1000 members that is advocating for the extension of the Community Path from
Somerville to Cambridge and to the Charles River paths. He asked DEP to influence
MassDOT to include the construction of the Community Path as part of the Green Line
Extension project. The path is integral to the Green Line Extension as both facilities are
within the same transit corridor and because the path will provide access to the new
Green Line stations. He asked that construction funding for the Community Path be
considered as an interim offset project to mitigate for the delays in the Green Line
Extension project. He also suggested accelerating the construction timeline for the
Community Path as mitigation.
Speaking for himself, Mr. Moore asked that the Red Line – Blue Line Connector
(Design) project remain a requirement of the SIP. He also advocated for building the
Green Line Extension to a terminus at Route 16, noting that he believes that Medford
Hillside (which is the legal requirement for the terminus) is beyond College Avenue.
Elin Reisner, Somerville Transportation Equity Partnership
Ms. Reisner expressed that she is discouraged by the delays on the Green Line Extension
project, which was supposed to be open by December 2014. Citing the Commonwealth’s
goals for leading the nation in sustainable transportation, she said that the Green Line
Extension and the Community Path will be real, concrete accomplishments for the
implementation of MassDOT’s GreenDOT policy. She noted that the new stations on the
Green Line and the new Orange Line station at Assembly Square will provide easy access
to transit for 85% of Somerville’s population (up from 15% currently), and that these
projects should be a model for the Commonwealth’s sustainability goals.
She noted that the 2013 SIP report states that the Community Path project is not part of
the SIP requirement, but that it does not make same statement about vehicle maintenance
facility project. If one project is going to be mentioned in the report, so too should the
other, she said.
Ms. Reisner suggested two interim offset measures for mitigating delays in the Green
Line Extension project: increasing the bike share program in Somerville to serve lowincome neighborhoods and adding bike stations at locations such as Sullivan Station,
Mystic Housing, Winter Hill, and East Somerville; and giving free bus passes to
Somerville High School students.
She also expressed support for the Red Line/Blue Line Connector project.
7