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
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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.
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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.
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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.
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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.
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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.
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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.
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