Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan – Transit Commitments
2012 Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
January 23, 2013
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 23, 2013
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 22, 2012). 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 18, 2012.
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, TDD: 617-973-7306
www.mass.gov/massdot
State Implementation Plan – Transit Commitments
2012 Annual Status Report
Agency Responses to Public Comments
I.
MassDOT Certification
II.
List of Public Comments Received
III.
Agency Responses to Public Comments
IV.
2012 Annual Status Report
V.
Public Comments
a. Oral Testimony
b. Emails & Letters
Leading the Nation in Transportation Excellence
Ten Park Plaza, Suite 4160, Boston, MA 02116
Tel: 857-368-4636, TDD: 617-973-7306
www.mass.gov/massdot
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
OFFICE OF TRANSPORTATION PLANNING
MEMORANDUM
TO:
Kenneth L. Kimmell
Commissioner
Department of Environmental Protection
FROM:
David J. Mohler
Executive Director
MassDOT Office of Transportation Planning
DATE:
January 23, 2013
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 2012 Annual SIP Status Report (by format and date)
Oral Testimony
Date
Title
9/18/2012
9/18/2012
9/18/2012
9/18/2012 Staff Attorney
9/18/2012
9/18/2012 Representative
9/18/2012
9/18/2012
9/18/2012
9/18/2012
First Name
Bill
Stephen
Ken
Rafael
Alan
Denise
Ellin
Carolyn
William
Wig
Last Name
Deignan
Kaiser
Krause
Mares
Moore
Provost
Reisner
Rosen
Wood
Zamore
Affiliation
City of Cambridge
Association of Cambridge Neighborhoods
Written Testimony
Date
Title
First Name
Last Name
Affiliation
Ellin
Neil
Rafael
Reisner
Osborne
Mares
Richard
Ken
Paul
Denise
Ellin
Fred
Dimino
Krause
Morrissey
Provost
Reisner
Salvucci
9/18/2012
9/18/2012
9/23/2012
9/24/2012
9/25/2012
9/25/2012
9/25/2012
9/25/2012
9/25/2012
9/25/2012
9/25/2012
President
Staff Attorney
President
Representative
Additional Authors
Conservation Law Foundation
Friends of the Community Path
Massachusetts House of Representatives
Somerville Transportation Equity Partnership
Green Line Advisory Committee for Medford
Green Line Advisory Committee for Medford
Green Line Advisory Committee for Medford
Somerville Transportation Equity Partnership
Mystic Valley Area Branch NAACP
Conservation Law Foundation
Friends of the Community Path
A Better City
Additional Authors
Carolyn Rosen, William Wood, Neil Osborne, Gwen Blackburn, Paul Morrissey, Mary
Anne Adduci, Henry Milorin, Bernie Green, Felix Blackburn
Alan Moore, Lynn Weissman
Aero Cycle
Massachusetts House of Representatives
Vig Kishnamurthy, Jim McGinnis, Karen Molloy
Massachusetts Department of Transportation
Massachusetts Bay Transportation Authority
State Implementation Plan - Transit Commitments
2012 Annual Status Report
Agency Responses to Public Comments
Submitted to the
Massachusetts Department of Environmental Protection
January 23, 2013
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 2012 Annual Status Report (the Status Report) submitted to the Massachusetts
Department of Environmental Protection (DEP) on July 2, 2012 in order to fulfill the
requirements of 310 CMR 7.36, Transit System Improvements. The Status Report detailed the
status of four public transit projects – listed below – required of MassDOT under 310 CMR 7.36.
The projects are:




Fairmount Line Improvement Project
Construction of 1,000 New Commuter Parking Spaces
Red Line/Blue Line Connector - Final Design
Green Line Extension to Somerville and Medford
MassDOT accepted public comments on the Status Report through September 24, 2012,
following a public meeting (September 18, 2012) at which staff from MassDOT 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 other
non-SIP issues. MassDOT has 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 has 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 commentator back to an earlier response or, if the issue has changed in
some meaningful way, will clarify and update earlier responses as appropriate.
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.
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
Massachusetts Department of Transportation
January 23, 2013
Page 1
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. Furthermore, MassDOT and the MBTA must always be
sensitive to the overall constrained fiscal climate of both the MBTA and the Commonwealth.
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 and the Fairmount Line Improvement Project. MassDOT
appreciates that there is substantial public interest in the selection of appropriate interim
mitigation measures. The proposed measures for the Green Line Extension project are being
considered by MassDOT and will be discussed as part of a separate public process. More
information about the ongoing process of determining appropriate mitigation for the Green
Line Extension project can be found at: http://www.greenlineextension.org/documents.html.
Project Completion
As discussed in the annual report and 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 will cease reporting on the parking
space commitment going forward.
Massachusetts Department of Transportation
January 23, 2013
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.

DEP is unable to effectively police MassDOT on the implementation of the SIP projects.
MassDOT previously addressed this issue in 2011:
MassDOT feels that the partnership currently in place between the two agencies is an
effective one for advancing the SIP projects during a challenging fiscal time.

SIP projects should be funded by the Commonwealth, not by the MBTA.
As the SIP projects are commitments of the Commonwealth, they are funded using
Commonwealth funds (not MBTA funds). The Massachusetts Legislature has authorized
MassDOT to create and use an account funded with Commonwealth bond monies to
support the costs of the SIP projects. Funds dedicated to the MBTA, whether state or
federal, are not used to support the capital costs of the SIP projects.

Investment in the SIP projects comes at the expense of the service quality and systemwide condition of existing MBTA infrastructure.
MassDOT previously addressed this issue in 2011:
The use of non-MBTA Commonwealth monies to fund the development and
implementation of the SIP projects means that no existing MBTA funds are diverted
from routine investment in the core MBTA system to support the expansions called for
in the SIP.

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
elements of the SIP commitment, and to minimize delays. At this point, many elements
are fully complete, including the entire 1,000 parking space commitment, and several
new elements of the Fairmount corridor. Many of the project delays have been caused
by circumstances outside of MassDOT’s control, such as the ongoing neighborhood
discussion about station locations at Blue Hill Avenue.
While the Green Line Extension is significantly delayed, MassDOT and the MBTA have
been upfront and open about the sources and effects of the delay, and are working as
expeditiously as possible to begin service. In Summer 2011, responding to a programwide risk assessment that extended the project’s completion date to the 2018-2020
Massachusetts Department of Transportation
January 23, 2013
Page 3
timeframe from the previously anticipated late 2015 completion date, the GLX team
proposed and then implemented a project phasing plan that:
(1)
(2)
(3)
(4)
Commenced construction in 2012,
Established an interim completion target of Green Line service operation
from the relocated Lechmere Station to new stations at Union Square and
Washington Street in Somerville,
Targeted final completion of the project in 2018 – 2020, depending on the
project’s ability to mitigate the identified risks to cost and schedule, and
Proposed the use of a Construction Manager/General Contractor (CM/GC)
approach on latter phases of the project to provide flexibility in meeting and
overcoming the identified risks in a timely manner. This approach required
legislative, MBTA Board and Office of Inspector General approval.
Since then, the project awarded (in December 2012) its first construction contract,
received key FTA environmental (Finding of No Significant Impact) and process
(Permission to Enter Preliminary Engineering) approvals, commenced the procurement
of a CM/GC (after an extended series of approval steps), and issued a Notice to Proceed
for GLX Advanced Preliminary Engineer/Final Designer. The interim completion date for
item 2 (above) remains on track for early 2017, even as the final FTA funding approval
(Full Funding Grant Approval) is, according to the current FTA roadmap, not expected
until February 2015 (It is possible that some limited work activities can be permitted to
proceed prior to the Grant Approval, with FTA concurrence). Finally, overall completion
remains on-schedule to complete in the 2018-2020 timeframe.
MassDOT and the MBTA are working towards program milestones while maintaining
required compliance with the FTA’s approval dates to maintain the possibility of federal
funding participation.

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.
MassDOT previously addressed this issue in 2011:
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. In addition, the
impacts of the station can be effectively mitigated at that location, a location which has
the support of the City of Medford (unlike other proposed locations in the area).
Furthermore, the need to acquire property at this location is minimal.
Massachusetts Department of Transportation
January 23, 2013
Page 4
The current design for the College Avenue Station acknowledges its role as a gateway to
both the adjacent Medford residential neighborhoods and to Tufts University. The
station will create an active use at the intersection of Boston and College Avenues,
incorporating a South-facing plaza that will provide a gathering place for neighbors,
students and transit riders. The scale of the station headhouse will respect the
character of the residential buildings in nearby neighborhoods with its modest size and
simple detail.
A pedestrian walkway will link the Station’s entry plaza to the nearby Burget Avenue
neighborhood, and an accessible drop-off/pick-up area will be located along the Boston
Avenue edge. The selection of materials for fencing, walls, paving and limited seating
and planted areas will be sensitive to the area’s context and will be utilized to 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
Organization (November 30, 2011).
For all of these reasons, we believe that a College Avenue terminus meets the goals and
intentions 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.

Vehicle Miles Traveled (VMT) is not the best measure of air quality conformity. Consider
using Vehicle Hours Traveled (VHT) instead.
MassDOT previously addressed this issue in 2011:
The current state of the practice for calculating on-road emissions, and the only method
currently approved by the relevant state and federal environmental agencies (DEP and
the U.S. Environmental Protection Agency), is to use the US EPA Mobile 6.2 emissions
modeling software. Mobile 6.2 makes use of inputs developed locally by DEP. The
Mobile 6.2 method involves using estimates of vehicle miles of travel (VMT) and the
corresponding MOBILE 6 emission factor, as mapped according to speed, roadway type,
vehicle type, and time period. Mobile 6.2 is used to generate a ‘look up’ table mapped
to the congested speed and other pertinent characteristics of roadway segments and
incorporate that information into its emissions calculations. Emissions are then
Massachusetts Department of Transportation
January 23, 2013
Page 5
calculated by multiplying the VMT data by an emissions factor as shown in the following
equation:
Emissions = VMT * EF * K
Where: Emissions = emissions in tons by roadway type and vehicle type
VMT = vehicle miles traveled by roadway type and vehicle type
EF = emission factor in grams/mile by roadway type and vehicle type
K = conversion factor
Vehicle Hours of Travel (VHT) is a function of both the VMT and the congested speed on
a particular roadway segment. The congested speed is used to determine a vehicles
path through the roadway system and the resulting VMT generated along that path is
measured on a segment by segment basis. Thus, a calculation of VMT indirectly includes
a calculation of VHT in the analysis of emissions. However, based on the current
regulatory guidance and the available emissions modeling software, we are obligated to
use VMT and congested speeds as independent factors as the means to develop
emissions estimates. The method of estimating VMT by the factors listed above has
been used since 1978 and will continue to be used by US EPA in their new emissions
model called ‘MOVES.’ Barring any new guidance from US EPA and/or DEP, the Boston
Region Metropolitan Planning Organization will continue to use this method, which is
widely applied and has been thoroughly tested.
Massachusetts Department of Transportation
January 23, 2013
Page 6
II. FAIRMOUNT LINE IMPROVEMENT PROJECT

[We] respectfully request that DEP require the inclusion of a reduction of fares as one of
the interim emission offset measures to counter the negative impacts of the delays in the
implementation of the Fairmount Line Improvement project.
As part of the process of identifying appropriate interim offset measures for the
Fairmount Line Improvement project, MassDOT analyzed the impacts on regional air
quality of reducing existing fares for the Fairmount and Readville stations on the
Fairmount Line. While the air quality impacts were indeed positive and beneficial and
the reduction would have made sense in certain ways, the associated reduction in fare
revenue for the MBTA system made it untenable as an interim emission offset measure
for MassDOT to propose. Furthermore, another concern for the MBTA is that such a
localized modification of fare policy could result in an inconsistent fare structure on the
Commuter Rail system, something the MBTA has worked hard to avoid.
MassDOT prepared a Petition to Delay and an Interim Emission Offset Plan for the
Fairmount Line Improvement Project, to be implemented for the duration of the delay.
Both the Petition and Offset Plan were submitted to DEP, and posted to MassDOT’s SIP
website. MassDOT estimated the reduced emissions expected to be generated by the
implementation of the new Fairmont Line stations. MassDOT and the MBTA, in
consultation with Fairmount Line stakeholders, identified a set of potential interim
emission reduction offset measures that would meet the emissions reduction targets.
On January 2, 2012, the offset measures were implemented: additional trips via a
dedicated shuttle on the CT3 bus route between Andrew Station and Boston Medical
Center; and increased weekday frequency on the Route 31 bus. These measures are still
ongoing, and will continue during the length of the delay.
Massachusetts Department of Transportation
January 23, 2013
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:
MassDOT recognizes that the text of the SIP regulation (310 CMR 7.36) uses the term
‘construction’ to refer to the creation of 1,000 new park and ride parking spaces.
However, the intention of the SIP regulation is to provide transportation alternatives
that make it possible for individuals to travel in such a way that will reduce the overall
production of air pollutants. The point of providing 1,000 new park and ride parking
spaces is to encourage greater use of the public transit network by encouraging
motorists to park their cars at remote locations and then board public transit to
complete their trips. Whether the spaces are ‘constructed’ or ‘provided’ matters much
less than whether they exist and serve their purpose, which is the focus of MassDOT’s
efforts. There are many benefits to providing surface-level parking lots rather than
major parking structures that require substantial construction: parking lots are less
expensive, more flexible, avoid many of the negative environmental impacts associated
with the construction of a parking garage, and can provide the opportunity for future
higher-use development on the same sites, development that could be adjacent to
public transit nodes and could provide underground or other types of parking.

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.
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. As the plans for the private development around Wonderland Station are
not yet finalized, nor is the private development project in construction, this agreement
will not be an issue for the short-term. Over the long-term and 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. Similar situations have been handled at
numerous other MBTA parking facilities, including Lynn Station, Route 128 Station and
Mystic Center (Wellington).
Massachusetts Department of Transportation
January 23, 2013
Page 8
IV. RED LINE/BLUE LINE CONNECTOR

MassDOT and the MBTA should build the Red Line/Blue Line Connector project.
MassDOT previously addressed this issue in 2011:
The Red Line/Blue Line Connector project is an idea that has been studied repeatedly
over the past several decades. The project has merit, and would provide meaningful
benefits both for residents and employees on the north side of Boston and for users of
the central subway system, who would experience a reduction in system-wide
congestion due to the newly-created connection. MassDOT supported the inclusion of
final design of the Red Line/Blue Line Connector as a SIP commitment both as a way to
further the understanding of the details of the project – last rigorously studied in the
1980s – and in the hope that funding to construct the project might become available
during the period of design development. MassDOT has completed conceptual design
and a Draft Environmental Impact Report for the project. However, construction
funding has not become available and, in fact, the financial situation facing MassDOT
and the MBTA has worsened in the intervening years. As a result, construction funding
for the Red Line/Blue Line Connector has not been included in any of the required
planning/funding documents prepared by MassDOT/MBTA and the Boston Region
Metropolitan Planning Organization, as it would need to be in order for the project to
advance.
Couple this with the fact that fully engineering a project as complex as the Red Line/Blue
Line Connector is an expensive undertaking in and of itself, and that to do so in a way
that is divorced from a construction procurement strategy is problematic at best and
impossible at worst, and MassDOT feels that it can no longer pursue the project. For
these reasons, MassDOT is requesting that DEP relieve it from the obligation to fully
design the Red Line/Blue Line Connector.

MassDOT and the MBTA should prepare the Red Line/Blue Line Connector to be ‘shovelready.’
MassDOT previously addressed this issue in 2011:
The term ‘shovel-readiness’ entered standard parlance during the implementation of
the American Recovery & Reinvestment Act in 2009. Conceptually, shovel-ready means
that an infrastructure project is fully ready for construction – all designs done, all rightof-way purchased, all environmental clearances obtained, all public support in place –
and is simply waiting for the availability of funding. In reality, this is a quite difficult (and
not necessarily prudent) strategy for the public sector to pursue for a project like the
Red Line/Blue Line Connector. The investment of time and resources required to make
a project of the scope and complexity of the Red Line/Blue Line Connector shovel-ready
is substantial, with monetary costs in the tens of millions of dollars or more. There are
also opportunity costs, as those funds can’t then be used to advance other projects.
There are also regulatory consequences, as permits can expire and regulations and
Massachusetts Department of Transportation
January 23, 2013
Page 9
design requirements can change, making designs stale before a project is built. Lastly,
there are public consequences, as the premature purchase of private property –
particularly property that may wind up not being used, if a project is never built – can
have real and negative impacts on businesses and residents and the urban environment.
For all of these reasons, MassDOT is cautious about preparing a project like the Red
Line/Blue Line Connector to a ‘shovel-ready’ level.
A project like the Red Line/Blue Line Connector simply requires too many years of
nurturing and dedicated project development to be brought to the ‘shovel-ready’ stage
without the commitment of sustained funding over the course of years. Furthermore,
the costs of a project like the Red Line/Blue Line Connector will always be too large for
the capacity of a discretionary program of the type for which ‘shovel-readiness’ is a
meaningful evaluation criterion.

Given that MassDOT agreed to include final design of the Red Line/Blue Line Connector
as a commitment in the State Implementation Plan, MassDOT should not now be
allowed to argue that the commitment lacks measurable benefits.
MassDOT has responded to this concern on multiple occasions, and the agency’s
position on this issue has not changed. As noted in an earlier response, MassDOT agreed
to the inclusion of final design of the Red Line/Blue Line Connector as a SIP commitment
as a way to further the understanding of the details of the project and to better position
the project should construction funding become available. Inclusion of the final design
commitment in the SIP clearly has had planning benefits, as MassDOT now has a much
clearer understanding of the challenges and opportunities presented by this very
complex urban tunneling project. Given what MassDOT knows now, however, it would
arguably have been prudent to not agree to include the Red Line/Blue Line design
commitment among the other SIP projects. The financial situation faced by the
Commonwealth, MassDOT, and the MBTA has only worsened since the SIP regulation
was last amended, and it is now clear that further engineering and construction funding
will not be available in the foreseeable future to make the Red Line/Blue Line Connector
a reality.
The lack of demonstrable air quality benefits associated with the final design of the Red
Line/Blue Line Connector—a fact that requires little in the way of argument for
support—is not MassDOT’s rationale for requesting that DEP relieve it of the
commitment. The rationale is that MassDOT believes that it is irresponsible to devote
scarce public resources at a time of such great need to the design of a project for which
MassDOT and the MBTA clearly do not have the financial capacity to implement over
the next two decades.

MassDOT is overestimating or purposefully inflating the costs of completing design for
the Red Line/Blue Line Connector intentionally in order to justify the proposed removal
from the SIP.
Massachusetts Department of Transportation
January 23, 2013
Page 10
MassDOT previously addressed this issue in 2011:
This is not correct. The cost projections for final design and construction of the Red
Line/Blue Line Connector were prepared by a capable team of technical professionals as
part of the development of the Draft Environmental Impact Report. This work
represented the first time in more than two decades that the costs for the project had
been estimated in a detailed and comprehensive way; previous estimates had simply
been inflations of earlier estimates, crudely projected into the future. The current cost
estimate for the Red Line/Blue Line Connector may seem high to those who are
accustomed to earlier estimates, but they reflect contemporary professional standards.
Furthermore, the experience of MassDOT and the MBTA indicates that many projects
can come in over their original cost estimates, not under. MassDOT did not manipulate
the process of estimating the costs.

In particular, MassDOT should link the design or construction of the Red Line/Blue Line
Connector to the proposed casino developments at Suffolk Downs, encouraging or
forcing any casino developer to undertake the project.
Under Massachusetts’ gaming facilities law, proponents must negotiate a Memorandum
of Understanding (MOU) with host municipalities which would include a mitigation
package. The mitigation proposals are intended to reduce negative impacts—in the
case of the transportation network, the increased demand on the system. The resulting
host community MOU is then voted on by residents of the host municipality. In the case
of proposals in the City of Boston, only the host ward votes on the agreement.
MassDOT does have a role under MEPA in guiding transportation mitigation for
development project impacts. The scale of the Red Line/Blue Line Connector –
projected to cost $748 million – makes it unsuitable as a mitigation project for a private
development. MassDOT therefore will not recommend that any casino developer fund
the construction cost of the Red Line/Blue Line Connector.
MassDOT’s role is also limited to discussing potential mitigation projects with a
proponent—the MOU and the mitigation projects included are ultimately the product of
a negotiation between the developer and the host community (City of Boston) and
those voting on the MOU (residents of affected wards).

Like the Red Line/Blue Line Connector, few planning projects have funding “at any point
in the next 20 years”. Yet planning continues on other, unfunded, projects. Why is the
Red Line/Blue Line Connector being treated differently by MassDOT?
Significant planning work has already been conducted on the Red Line/Blue Line
Connector. From this point forward, the work would focus much more on actual design
and engineering work, which would have a limited shelf life should funding for its
construction not materialize soon. While work continues on a few other major transit
Massachusetts Department of Transportation
January 23, 2013
Page 11
projects (such as South Coast Rail and South Station Expansion) which do not have full
funding commitments for construction, the work on both of those projects is still
focused primarily on planning rather than design. Both of those projects have also been
recipients of significant grant funds from the federal government which has allowed
MassDOT to advance specific project elements.

MassDEP should require MassDOT to identify substitution projects to compensate for the
Red Line/Blue Line Connector if it is not being built. Alternatively, MassDEP should
require MassDOT to appropriate $26 million (the difference between the original $29
million estimate to complete design for the Red Line/Blue Line Connector and the $3
million already spent on the project) toward interim offset projects for other SIP
commitments.
In July 2011 MassDOT submitted a request to MassDEP to relieve MassDOT of the
commitment to complete final design on the Red/Blue Connector given that 1) there
was no funding available to implement the project in the foreseeable future, which
would call into question the value of advancing designs that would have to be revisited
within a few years anyway, and 2) the design of Red/Blue itself has no measurable air
quality benefit. MassDEP is considering this request, and held public hearings to solicit
comments during summer 2012. Based on MassDOT’s position, as described in the
request, MassDOT believes that no additional resources should be required to be
invested on the Red Line/Blue Line Connector project. MassDEP has not yet issued a
decision on MassDOT’s request.

Construction of the Red Line/Blue Line Connector should be included in the construction
contract of the Green Line Extension project, as a way to gain efficiencies, and
potentially as an interim offset measure to the Green Line Extension project delays.
MassDOT previously addressed this issue in 2011:
Leaving aside the contractual complexities of the mechanics of trying to accomplish this,
the Red Line/Blue Line Connector will not be on the same construction schedule as the
Green Line Extension project, for which ground has just been broken. Furthermore, the
fundamental problem of financing the construction of the Red Line/Blue Line Connector
remains, which prohibits it from serving as an interim offset measure for the Green Line
Extension project.
Massachusetts Department of Transportation
January 23, 2013
Page 12
V. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD

MassDOT is violating the SIP regulations by not providing details related to the
continued delays of the Green Line Extension Project.
MassDOT always strives to provide the most accurate and up-to-date information
possible on its programs and projects. For the SIP projects, MassDOT submits monthly
reports to the Boston Region Metropolitan Planning Organization, as well as to the
Federal Highway Administration and the Federal Transit Administration, on the status of
the four outstanding SIP projects. In those documents, MassDOT reports the most
timely available status information for each of the projects. MassDOT endeavors to
report as accurately as possible, and we generally do not report on changes in a project
status until we are completely confident that the change is certain and meaningful.
The monthly status reports are available at: http://www.massdot.state.ma.us/SIP.

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.
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 has been
selected by the FTA for approval into Preliminary Engineering.
As part of the application to FTA for Preliminary Engineering, MassDOT was required to
present a plan to resolve the MBTA’s structural deficit and provide the capital funds for
the Project. In turn, this would allow FTA to participate in funding a portion of the
Green Line Extension project. The latest Green Line Extension project financial plan,
submitted to the FTA, can be found at the following project website:
http://www.greenlineextension.org/docs_FTA_NewStarts.html. In addition, MassDOT
recently released a statewide transportation finance plan, which would, in part, support
the Green Line Extension project. The plan can be found at:
http://www.massdot.state.ma.us/Portals/0/docs/infoCenter/docs_materials/TheWayFo
rward_Jan13.pdf.
In addition to federal funding, MassDOT and the MBTA will use Commonwealth funds to
support the design and construction of the Green Line Extension project. These funds
will be raised with the backing of authorizations made to support the State
Implementation Plan (SIP) projects in Transportation Bond Bills of the past several years.
At present, MassDOT has $624 million available in active Transportation Bond Bill
authorizations for the SIP projects. This value does not account for the monies
Massachusetts Department of Transportation
January 23, 2013
Page 13
encumbered to support current projects to date. MassDOT will seek additional
Transportation Bond Bill authorization to cover the costs of the Green Line Extension
project, as well as other SIP projects as necessary.

MassDOT should consider phasing the implementation of the Green Line Extension
project, with clear goals and milestones.
As discussed previously, MassDOT and the MBTA are implementing a phased approach
to deliver the Green Line Extension project to the communities of Cambridge, Somerville
and Medford. The first Phase has been awarded for construction and the rehabilitation
and widening of two bridges and the demolition of a tire warehouse which has
commenced in late 2012. The second Phase, extending service from North
Station/Science Park to the relocated Lechmere station and on to Union Square and
Washington Street in Somerville, will start full construction in early 2015 (after the FTA
has issued its determination of funding for the project) and complete construction in
early 2017, followed by a period of operational testing before passenger service
commences.
Phase 4, extending from Washington Street Station to the College Ave Station in
Medford will also commence in early 2015, but the narrow corridor, the work adjacent
to the active commuter rail and the sequencing of bridge construction to minimize
community impacts will likely extend this phase until 2018, followed by a period of
testing prior to providing service. Finally, a vehicle storage and maintenance facility will
be constructed in East Somerville to support this portion of the Green Line system. This
phasing approach is intended to minimize risks to cost and schedule and deliver portions
of the project as soon as possible to these communities while not jeopardizing
opportunities for federal financial participation.

Many local residents and important underserved populations have been unable to
participate in the Green Line Extension decision process.
Since the inception of the project in 2006, the Green Line Extension project team has
made public participation a top priority. As much as possible, information has been
provided about the project to the public; the team has sought public input and used it to
modify project plans, designs, and overall direction of the project. MassDOT and the
MBTA take seriously public expectations for the quality of our work and hold ourselves
to the high standards set for us by the public; and we are genuinely interested in and
enjoy interaction with the public.
That being said, it is always challenging to reach certain populations: new immigrants,
those with limited English proficiency, those without access to the internet, and those
who are unable or unwilling to participate in public meetings. MassDOT staff members
are aware of these challenges, and always strive to broaden the circle of outreach in
Massachusetts Department of Transportation
January 23, 2013
Page 14
order to include more voices in our planning processes. We will continue with our
efforts, and welcome ideas and suggestions from local community members.

The current phasing plan of the Green Line Extension project leaves out Gilman Square
Station from Phase 2/2A. Gilman Square should be accelerated as it is the highest
projected ridership station.
The current travel forecast model estimates the daily ridership at Gilman Square Station
in 2030 to be 3,930 boardings. The estimated ridership at Union Square Station in 2030
is 3,570 boardings, which is similar to Gilman Square Station. These two stations have
the next highest ridership projection, following the relocated Lechmere Station with
8,820 daily boardings.
While ridership is an important measure of service needs, and the whole GLX corridor
serves highly dense communities, the current phasing plan for the GLX implementation
was developed by MassDOT and the MBTA based on a number of factors and risks
related to the agency’s technical and operating characteristics, the actual work required
to provide service to each location and the financial resources available. The complexity
of corridor development to provide Green Line service between Washington Street and
Gilman Square Stations is substantially different than the area from Lechmere to
Washington. This is primarily due to the fact that the corridor has to be widened to
accommodate the additional tracks and the station, which involves the reconstruction
of at least the Medford Street and the School Street Bridges, extensive utility work and
drainage work both on the bridges and in the corridor, retaining wall and noise wall
work and the relocation of the Commuter Rail tracks to clear the area to build the new
GLX platform and tracks. Also considered was the need to relocate an existing NSTAR
substation at Gilman and the required additional traction power substation in the area.
It was also determined that additional vehicles would be required to maintain headways
and support the extended Green Line service to Gilman Square Station, where they are
not required to support the extension of service to Washington and Union. When
considering each of these elements and the time required to implement them, there
was therefore no ability to commit to delivering the extension service to Gilman Station
as part of Phase 2/2A and in the same time frame as service to Washington and Union.

Not enough is being done to mitigate the construction impacts of the Green Line
Extension and the rehabilitation of roadway bridges in the area. This will severely
hamper east-west travel in the project corridor.
MassDOT is fully aware of various roadway/bridge projects whose construction work is
scheduled to be undertaken between 2012 and 2016 (or later) in the project area. Due
to close geographical proximities and overlapping schedules, MassDOT has initiated, in
collaboration with the City of Somerville, an effort to coordinate these projects so that
the overall construction impacts to the communities can be minimized. The Green Line
Massachusetts Department of Transportation
January 23, 2013
Page 15
Extension project also has construction activities scheduled during this period, including
the Phase 1 construction package, (the widening of the two early rail bridges and a
building demolition), which received a Notice to Proceed in December 2012. The Green
Line Extension project team has been a participant in the coordination that has occurred
on these roadway and bridge projects. Key projects in the vicinity of the GLX project
include, but are not limited to: rehabilitation of Cross Street Bridge; replacement of
Route 28 over Gilman Street; repairs to the McCarty Overpass; construction of a portion
of the Somerville Community Path; reconstruction of Beacon Street; and streetscape
improvements on Broadway.
Coordination will continue as the Green Line Extension project design advances and
construction work will be planned in a manner that minimizes community disruption
and recognizes the team’s principles of maintaining the project area’s major traffic
access and avoiding the closures of two adjacent bridges at the same time. An example
of this effort is the Phase 1 package for the GLX that includes a contract provision
requiring the contractor’s active participation in project coordination efforts.

The Green Line Extension project will affect the Medford community negatively through
real estate speculation.
Public transit investments like the Green Line Extension project can, over time, influence
local economies in ways both positive and negative. For all of the benefits brought by
increased access to public transit – greater mobility for residents and workers of all
incomes, greater access to employment and other services, and cleaner transportation
than that offered by automobiles – some negative effects can also be felt. These can
include an increase in the cost of rental properties in neighborhoods with immediate
access to new public transit services. These negative effects can be offset by proactive
municipal policies, however, including: policies to stabilize rents, increase the supply of
affordable housing, and implement progressive taxation policies that encourage
targeted growth and density. Concerns among some Medford residents about
displacement are reasonable, and can be addressed through effective, thoughtful
collaboration among residents, community groups, and municipal officials.
MassDOT supported work by the Metropolitan Area Planning Council to research and
review issues of potential future gentrification in Medford, particularly around the
future site of a Green Line station at Route 16. The results of the work can be found at:
http://mapc.org/green-line-extension.

Cleaning up the diesel locomotives through Somerville and Medford will do more for
local health and quality of life in Medford than will the Green Line Extension.
At present, the MBTA uses ultra-low sulfur diesel fuel on all commuter rail vehicles. In
addition, the MBTA is in the process of adding head-end power to one-third of its
locomotive fleet. These units will allow these locomotives to run more cleanly, with
Massachusetts Department of Transportation
January 23, 2013
Page 16
fewer emissions and less fuel, while also bringing them into compliance with US EPA Tier
II standards, some of the strictest air quality standards in existence for locomotives.
Additionally, existing locomotives have been rebuilt, as part of the MBTA’s mid-life
overhaul program, with existing engines rebuilt to new standards and new emission
levels, resulting in fewer emissions, as well as more efficient operations of the engines.
As part of the fleet upgrade, the MBTA has added Auto Assisted Shutoff Systems which
prohibit a locomotive from idling for more than 30 minutes after its use. This is
particularly critical in Somerville as locomotives are stored and maintained at the
Commuter Rail Maintenance Facility (CRMF). Lastly, the MBTA has purchased and is
awaiting delivery of 25 new locomotives which will replace older locomotives. These
new engines meet, and in some cases exceed, EPA standards for emissions and will be
some of the cleanest engines available. Although these improvements (i.e., new
locomotives, head end power upgrades, shutoff systems) will provide air quality
benefits in the entire commuter rail service area, and particularly in Somerville. The air
quality benefit of the Green Line Extension project will continue to outweigh any
improvements in commuter rail emissions, however, through the auto diversions
induced by the project.

The Green Line Extension project has not completed a robust air quality impact analysis.
Analysis of local impacts is required by the Massachusetts Air Pollution Control
Regulations. Diesel trains from the commuter rail will emit air contaminants into
environmental justice communities and the project adds to that burden by not
remedying that current situation. MassDOT has failed to determine local air quality data.
Diesel exhaust emissions from engines used during construction must be added to the
environmental analysis, as was mandated in the EENF, but not completed in the EA.
The environmental analysis prepared for the project pursuant to the National
Environmental Policy Act (NEPA) and the Massachusetts Environmental Policy Act
(MEPA) was prepared in accordance with all state and federal air quality regulations and
all appropriate standards. The analysis methodology was reviewed and commented on
by MassDEP as well as the US EPA. MassDOT is confident that the air quality analysis
performed for the project meets or exceeds state and federal air quality standards.
As for diesel exhaust emissions during construction, the requirement in the
environmental document was to meet DEP standards for retrofitting construction
equipment and to DEP anti-idling regulations. These construction retrofit and anti-idling
provisions have also been reinforced in MassDOT’s recently released GreenDOT
Implementation Plan.

Over the last year, the Green Line Extension project team has fallen short in engaging
the Design Working Group in a meaningful way. How can we expect that to change over
the next year?
Massachusetts Department of Transportation
January 23, 2013
Page 17
The Green Line Extension (GLX) Project team last met with the Design Working Group
(DWG) on November 15, 2012. At that meeting, an update on the design progress was
made and the DWG was introduced to key staff from AECOM/HNTB, who will be
completing design work for the GLX. The next meeting of the DWG will be scheduled for
early 2013, at which time a more detailed program of public involvement and DWG
meetings to support the development of designs for the project over the coming year
will be discussed.
Beginning in December 2011, the GLX Project team hosted a series of four station area
workshops to present progress on designs made since the previous station workshop
meetings were held in June 2011. Community input was gathered at these workshops
to inform design development. An additional meeting to introduce design progress for
retaining walls and noise barriers was held in May of 2011. An update on designs for the
Community Path was held on December of 2012, following up on a presentation made
in September 2011. All of these well-attended public meetings provided input from
community members and local residents, including many members of the Design
Working Group.

MassDOT is pushing the Green Line Extension simply to promote the expansion of a wellconnected entity in Tufts University.
MassDOT previously addressed this issue in 2011:
MassDOT and the MBTA do not show favoritism or provide special access or advantages
to any group involved with the Green Line Extension project, as evidenced by the
number of MassDOT and MBTA decisions about the Green Line Extension project that
have angered or disappointed so-called special interest groups. That being said, the
challenge of equitably and consistently involving all interested stakeholders –
particularly those who aren’t sophisticated in the ways of public participation and
advocacy – is a real one, and one that MassDOT and the MBTA struggle with on many of
our projects. We rely not only on our own resources and knowledge but also on those
of established local groups to make and sustain important contacts with abutters and
other relevant stakeholders. Only with their involvement can we endeavor to make
sure that the Green Line Extension project is founded on the needs and aspirations of a
diverse group of individuals and local communities.
MassDOT and the MBTA make good faith efforts to involve a broad range of
stakeholders and individuals in its planning processes. MassDOT and the MBTA have no
bias toward or against any individuals or groups, based on income, education, or other
characteristics. Furthermore, the relationship between MassDOT and the MBTA and
Tufts University is limited to appropriate discussions about the design and location of
the future College Avenue station.

Interim Offset Measures for the Green Line Extension project’s delay must be
implemented in the project corridor of Cambridge, Somerville, and Medford.
Massachusetts Department of Transportation
January 23, 2013
Page 18
MassDOT previously addressed this issue in 2010:
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 enacting interim offset measures in the most prudent way possible to meet
regional air quality goals. However, in making decisions on interim offset measures,
MassDOT will attempt, whenever reasonable, to identify measures that would also
improve air quality directly in the project corridors associated with the delayed
implementation of any projects.

In presenting the summary of potential interim offset measures, MassDOT dismissed
virtually all of them for one reason or another, before any modeling was completed. Why
were so many worthwhile projects ignored? Too many appropriate mitigation measures
are prematurely scoped out due to the lack of support from the MBTA and MassDOT.
The position of limiting peak-period service expansion handicaps the potential to provide
meaningful mitigation, and could potentially be overcome with contracted services.
Specifically, the following offset measure was not fully evaluated by MassDOT, and
requires further consideration in the interim offset mitigation process:
o Signal prioritization for buses in the GLX corridor
o Green Line services to Lechmere at 3-minute peak headways
o Improved pedestrian connections in the GLX corridor
o Removing the elevated portions of the McGrath Highway
o Instituting free Hubway memberships for corridor residents
o Construction of part of the Mystic Valley Reservation Master Plan, specifically the
mutli-use path from Harvard Avenue to the Malden Bridge
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 Grand Junction corridor rail service to improve connectivity in Cambridge
o Construction of the Red Line/Blue Line Connector
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 spoke to issues of practicality, operational
viability, cost, potential to improve air quality, potential for municipal support, and
timing of implementation. 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.
It is true that many of the recommendations – both those submitted by the public and
those developed by MassDOT – scored poorly in this qualitative evaluation, pointing to
the challenge of effectively providing equivalent short-term compensation for the
myriad benefits to be brought by the Green Line Extension project. MassDOT is
continuing to work to develop viable mitigation measures, and will make any new
Massachusetts Department of Transportation
January 23, 2013
Page 19
information available to the public. All information to date, including the qualitative
evaluation, is available at: http://www.greenlineextension.org/documents.html.

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.
MassDOT has long committed to developing final designs of the Somerville Community
Path extension 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. However, MassDOT is unable to take on the additional
costs and responsibility associated with constructing the Community Path extension at
this time.
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, but MassDOT believes that such a connection
could have meaningful transportation and economic benefits and hopes to continue to
work with the cities of Somerville and Cambridge on this issue.
Information about the qualitative evaluation of these recommendations can all be found
at: http://www.greenlineextension.org/documents.html.

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.
MassDOT has been consistent in its support of an ultimate terminus from the Green Line
Extension at Mystic Valley Parkway/Route 16, but has proposed that this final segment
of the project be planned and constructed as a later phase. This is the case for financial
reasons – the Commonwealth simply cannot afford it at this point – but also for
planning and policy reasons. MassDOT learned a wealth of lessons from the release of
the Draft Environmental Impact Report (DEIR), and feels that there is still a meaningful
lack of consensus for a station at Mystic Valley Parkway/Route 16. We hope to continue
to work and develop such consensus for this potential station area. In the recent past,
Massachusetts Department of Transportation
January 23, 2013
Page 20
that has involved supporting the process undertaken by the Metropolitan Area Planning
Council which helped to detail some of the local issues around the station, and identify
some further recommendations.
Since the release of the MAPC report and findings, the Boston Region MPO has voted to
include Congestion Mitigation and Air Quality funds (originally designated as highway
funds but ‘flexed’ to transit projects) for the 2016 planning year as part of the most
recent regional Transportation Improvement Program. This will allow for further design
and environmental work to be undertaken at that time. MassDOT and the MBTA will
engage in that process at the appropriate time.
In the intervening period, MassDOT will not commit to a Mystic Valley Parkway / Route
16 terminus as an interim offset measure for any project delay. Committing to Route 16
would be against the stated aims of interim offset measures, and would be infeasible to
complete in the timeframe necessary by the SIP regulations.

MassDOT and the Boston MPO have moved to proceed with the Route 16 Station design
and planning without true environmental studies.
As noted above, the Boston MPO, in 2012, ‘flexed’ money for the design and permitting
of the Mystic Valley Parkway / Route 16 station, with the intention of work being
undertaken in 2016. Through these efforts, all required environmental and design steps
will be completed in order to have a fully-permitted station design. This is a common
path for the design and permitting of major infrastructure projects, and MassDOT is not
attempting to subvert or ignore any pertinent regulations.

[We] remain opposed to needlessly expending limited public resources on studying and
then building an extension [to Route 16] that will encroach on neighbors and further
invite unwanted development to the city. This is analogous to the West End
redevelopment that displaced an entire neighborhood.
MassDOT understands and acknowledges the continued lack of consensus around the
need for and impacts of a Mystic Valley Parkway / Route 16 station. Many of those local
issues were discussed at length in the MAPC process around the station area. However,
it is important to state clearly that MassDOT intends not to take or remove any
residences in the process of designing or building any part of the Green Line Extension.
For this reason, and many others, the Green Line Extension project is not analogous to
redevelopment of Boston’s West End, and any comparisons to that effort are misguided
and inappropriate, serving only to confuse and stifle public discussion.
Massachusetts Department of Transportation
January 23, 2013
Page 21
State Implementation Plan Public Meeting
Department of Environmental Protection and the Massachusetts Department of Transportation
September 18, 2012 – 1:30pm to 2:30pm and 5:00pm to 6:15pm
Mass DEP
One Winter Street
Washington Street Conference Center
Boston, MA
Attendees at Afternoon Session:
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection (DEP)
Christine Kirby, Director of Transportation Program, Department of Environmental Protection
David Mohler, Executive Director, Office of Transportation Planning, Massachusetts
Department of Transportation (MassDOT)
Bill Deignan, City of Cambridge
Stephen Kaiser, Association of Cambridge Neighborhoods
Maureen Kelly, Central Transportation Planning Staff
Rafael Mares, Conservation Law Foundation
Anne McGahan, Central Transportation Planning Staff
Alan Moore, Friends of the Community Path, Somerville resident
Denise Provost, State Representative
Wig Zamore, Somerville resident
Attendees at Evening Session:
Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of
Environmental Protection
Christine Kirby, Director of Transportation Program, Department of Environmental Protection
David Mohler, Executive Director, Office of Transportation Planning, Massachusetts
Department of Transportation
Maureen Kelly, Central Transportation Planning Staff
Ken Krause, Medford Resident
Anne McGahan, Central Transportation Planning Staff
Ellin Reisner, Somerville Transportation Equity Partnership, Somerville resident
Carolyn Rosen, Green Line Advisory Group of Medford
Dr. William Wood, Green Line Advisory Group of Medford
Wig Zamore, Somerville resident
Introduction
Nancy Seidman, Assistant Commissioner, MassDEP opened the public meetings on MassDOT’s
annual status report on the commonwealth’s State Implementation Plan (SIP). MassDEP requires
MassDOT to report annually on its progress for implementing uncompleted SIP projects under
Page 1
its authority pursuant to M.G.L. Chapter 111, Sections 142A through 142M, subsection (7) of
310 CMR 7.36, the Transit System Improvements regulation. MassDEP is seeking public
comment on the annual update and status report for these transit projects.
Within 120 days of this meeting, MassDOT is required to summarize and respond to public
comments. Within 60 days of the summary and response, MassDEP must then determine
whether the public process requirements of the regulation have been met. Written comments will
be accepted until 5:00 PM on September 25, 2012. Comments should be submitted 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, MassDEP, Bureau of Waste
Prevention, Boston, MA 02018 or Jerome.Grafe@state.ma.us.
This meeting was originally scheduled for September 6, but was rescheduled so as not to conflict
with the primary elections.
Attendees were asked to limit their spoken comments to five minutes.
MassDEP held a public hearing on September 13 regarding MassDOT’s request to amend the
SIP to remove the requirement to complete the design of the Red/Blue Line Connector project.
The public comment period closes on September 24 at 5PM.
MassDEP issued a certification letter on the 2011 SIP report on March 15, 2012.
MassDEP has approved MassDOT’s petition to delay the Fairmount Line Improvement project.
Status Report
David Mohler, Executive Director of MassDOT’s Office of Transportation Planning, provided a
summary of the status on the SIP projects.
The Fairmount Line Improvement project was required to be complete by December 31, 2011.
The project includes the construction of four new MBTA stations and the reconstruction of two
stations. The Morton Street and Upham’s Corner Stations are complete and open. The Four
Corners Station is 80% complete and expected to be complete in April 2013. The Talbot Station
is 90% complete and expected to be complete in January 2013. Newmarket Station is 70%
complete and expected to be complete in June 2013.
Blue Hill Avenue Station is being designed. The project was at the 60% design stage in 2009. As
a result of concerns expressed by neighbors and abutters to the station, MassDOT is submitting
its designs for a peer review. The station will probably not be open until 2015. MassDOT has
implemented two projects to mitigate for the delay: a new shuttle bus between Andrew Square
and the Boston Medical Center, and increased to frequency of MBTA bus route 31.
The 1,000 New Park and Ride Parking Spaces project is complete. MassDOT was required to
construct 1,000 new parking spaces in the Boston MPO region by December 31, 2011.
Page 2
Wonderland Garage opened on June 30, 2012, six months behind schedule. To mitigate for the
delay, MassDOT increased Saturday service on MBTA bus route 111.
MassDOT was required to complete the final design of the Red/Blue Line Connector project by
December 31, 2011. MassDOT is petitioning MassDEP to remove this requirement from the SIP.
MassDOT is required to complete the Green Line Extension to Medford Hillside with a spur to
Union Square in Somerville by December 31, 2014. State environmental review has been
completed and the federal government has issued a Finding of No Significant Impact (FONSI).
The Federal Transit Administration (FTA) gave approval to enter into preliminary engineering
under the New Starts Program on the condition that MassDOT be able to solve its transit
underfunding problem. MassDOT has selected a firm to conduct the preliminary design work.
The MBTA is reviewing proposals for Green Line vehicle construction and expects to present a
recommendation to the MassDOT Board this fall. MassDOT has hired a relocation consultant for
right-of-way work.
The Green Line Extension project will be conducted in four phases. Phase 1 is the widening of
the Harvard Street Bridge in Medford and the Medford Street Bridge in Somerville, and the
demolition of the building at 21 Water Street in Cambridge. Phases 2 and 2A involve the
relocation of Lechmere Station and construction of the Union Square spur. The second phases
are expected to be complete by mid-2017. Phase 3 is the construction of a maintenance and
storage yard. Phase 4 will provide service from Washington Street to College Avenue. The
Construction Manager/General Contractor (CM/GC) delivery method will be used. The project
cost estimate is $1.1 billion exclusive of finance charges. Projects to mitigate for the delay are
being selected.
Oral Testimony – Afternoon Session
Denise Provost, State Representative
Rep. Provost expressed dismay about the prospect of the elimination of the Red/Blue Line
Connector project from the SIP. She then advocated for the Green Line Extension project
emphasizing the importance of the project for Somerville residents to get justice and for access
to good transit, for improving air quality, and for improving the region’s economy.
She expressed concern about efforts in the legislature to stop the expansion of the transit system
and the Green Line Extension project, and she expressed the need to recommit to the expansion
of the transit system. She referenced the Global Warming Solutions Act and noted that cities in
the urban core have lower emissions contributions than those in the suburbs, and that transit
expansion would allow other communities to reduce their emissions. She also referenced the
state’s Healthy Transportation Compact and called for a health analysis to be conducted for the
Green Line Extension project. Lastly, she explained how the Green Line Extension would allow
for an increase in availability of work force housing as Somerville is zoned for density.
Rafael Mares, Conservation Law Foundation
Mr. Mares suggested that the deadline for the Red/Blue Line Connector project be extended
rather than eliminating the project from the SIP.
Page 3
He expressed satisfaction with the progress of the Fairmount Line Improvement project and
asked that an eye be kept on delays so that the project can be completed. He noted that the SIP
requires measures to increase service and ridership on the Fairmount line.
He also expressed satisfaction that interim offset measures have been put in place for the 1,000
New Park and Ride Parking Spaces project. He urged DEP to require MassDOT to report on this
project next year. He expressed concern that MassDOT has no measures in place to ensure that
only MBTA customers can use the South Garage at the Wonderland Garage. He also questioned
whether the requirement to create 1,000 new parking spaces has been fulfilled since not all the
spaces are new ones.
He asked that MassDOT also continue to report on the Blue Line Modernization project. He
noted that the Government Center Station has not yet been modernized.
He stated that the public should continue to be involved in the development of the interim offset
projects for the Green Line Extension project.
Stephen Kaiser, Association of Cambridge Neighborhoods
Mr. Kaiser referenced the laws governing the SIP process and gave a reminder that government
is for the common good of the people, not for the profit of any individual or class (as noted in the
Article 7 of the Declaration of Independence). He called on the government representatives to be
wary of actions that will use public funds for the benefit of private developers.
He cited a study by the Urban Land Institute that reported that the MBTA system is already at
capacity. He cautioned that the system cannot support the additional riders that would result
from development. He stated that developers should pay to support that extra transit capacity,
since they are the beneficiaries of the development.
He stated that the air quality goals for the MBTA should focus on running the system efficiently
and providing as much service as possible. He expressed concern that funding capital projects
will detract from that goal. He noted that MassDOT has $26 million worth of debt.
He suggested that the requirement to complete the Red/Blue Line Connector project be replaced
with a requirement that MassDOT report its budget (capital and operating) to DEP. This
information could be used to monitor whether any new project would result in failures of the
transit system.
Alan Moore, Friends of the Community Path, Somerville Resident
Mr. Moore expressed thanks to the DEP for requiring the Green Line Extension project in the
SIP, to EOEEA secretaries for ensuring that the Community Path project was not precluded, to
former MassDOT secretaries for including the Community Path to Inner Belt in the Green Line
Extension design contract, and to MassDOT and the MBTA for agreeing to build some shared
infrastructure between the two facilities.
He noted that the Community Path will deliver more riders to the MBTA stations and thereby
reduce emissions. He called for the Community Path to be constructed along with the Green Line
Page 4
Extension to minimize costs. He suggested that the project be used to mitigate for delays in the
Green Line Extension project. He also requested that MassDOT design the Community Path
between the Inner Belt area and Cambridge.
Bill Deignan, City of Cambridge
Mr. Deignan commented on the Green Line Extension project and expressed the City of
Cambridge’s support for the project. He suggested that interim offset projects should allow for
transit capacity increase, and that MassDOT should concentrate on making peak hour
improvements and enhance bus connections. He also suggested that consideration be given to
expanding the Hubway bike share program. Lastly, he expressed support for building a bridge to
North Point as part of the Green Line Extension project.
Wig Zamore, Somerville resident
Mr. Zamore responded to a couple of points made by previous commenters. He noted that there
is a jobs deficit in Somerville that correlates with a fiscal deficit, and he expressed his hope that
transit would be used to develop a better balance between jobs and the work force. He also
expressed that everyone should pay their share for transit and proposed that broad-based
measures be employed, such as a gas tax or diesel tax.
He then discussed the SIP as a means to improve air quality, particularly with regard to ozone
and particulate matter. He discussed the failure of the U.S. EPA to institute health protective
standards with regard to these pollutants. He said that the next ozone standards will have to take
into account mortality associated with ozone.
He submitted documentation regarding health protective standards, a study on air quality
monitoring in Somerville, and a Canadian study on particulate matter.
Oral Testimony – Evening Session
During Ms. Seidman’s opening remarks two attendees made comments regarding the time
allotted for attendees to speak. Dr. William Wood requested additional speaking time due to his
health issues. Carolyn Rosen stated that the public notice for the meeting did not specify that
members of the public would have only five minutes of speaking time. She also noted that
someone who attended the afternoon session was in attendance at this evening session, and that
he would be getting a total of 10 minutes of speaking time. Dr. Wood asked for 20 minutes of
speaking time, and the panel accommodated his request.
Ellin Reisner, Somerville Transportation Equity Partnership, Somerville resident
Ms. Reisner expressed appreciation to the MBTA staff for reaching a milestone on the design
and engineering of the Green Line Extension project. She called for the commonwealth to move
forward on the interim offset projects and emphasized that mitigation becomes more important
the longer the project is delayed. She advocated for building the extension to Route 16.
She recommended that DEP direct MassDOT to complete the design and construction of the
Community Path from North Point to the Inner Belt, an environmental justice community. She
stated that the Community Path meets the sustainable transportation goals of the federal
Page 5
government and the commonwealth. She expressed frustration that MassDOT is not meeting is
own sustainability goals.
She expressed support for roadway improvements in the Brick Bottom and Inner Belt area and
for bus service from Sullivan Square to Lechmere, Kendall, and the Longwood Medical Area.
Lastly, she expressed disappointment that the Red/Blue Line Connector project is not moving
forward as the project would reduce car ridership.
Wig Zamore, Somerville resident
Mr. Zamore expressed agreement with Ms. Reisner’s comments, though he said that he would
prefer light rail in the urban core rather than buses. He then spoke about health issues associated
with air pollution.
He noted that the World Health Organization has declared diesel emissions to be a Class 1
carcinogen, a fact, he said, which does not support the intense use of diesel vehicles in the urban
core. He provided the panel with various studies that report on the associations between
transportation emissions and heart attacks and with mortality associated with living in proximity
to highways. Due to health impacts from emissions, he advised against putting bicycle
accommodations on arterial highways. Rather he suggested choosing routes for bicycles that are
on less heavily traveled streets.
He expressed support for extending the Green Line to Route 16 and for completing the
Community Path.
He noted that the Fairmount Line Improvement project is problematic because it will expose a
population in a densely-settled area to diesel emissions.
Ken Krause, Medford Resident
Mr. Krause recognized the progress that has been made on the Green Line Improvement project
and the Boston Region MPO’s commitment to extending the project to Route 16. He noted that
DEP should be aware that the Harvard Street Bridge project, which is part of Phase 1, will
address a flooding issue. He expressed his hope that DEP will continue to be an advocate of the
project and for getting funding for the project.
He discussed the need for the project considering traffic congestion problems in the Medford
area. He noted that the Green Line Extension project’s DEIR identifies the intersection of Mystic
Valley Parkway and Boston Avenue as having the second largest traffic count in the project area.
He expressed some disappointment with the interim offset projects (further detailed in written
comments) and with the removal of the Red/Blue Line Connector project from the SIP. He noted
that a potential funding source for the latter could come from the development of the casino in
Revere. If the project is removed from the SIP, he said that the $50 million designated for the
project should be directed toward interim offset projects for the Green Line Extension project.
Carolyn Rosen, Green Line Advisory Group of Medford (GLAM)
Page 6
Ms. Rosen expressed opposition to the Green Line Extension project to Route 16. She remarked
that Congressman Capuano voiced concerns about state’s ability to pay for the project and she
said that the commonwealth has no funding to build the project beyond Lechmere and North
Point.
She noted that the NAACP is also opposed to the Route 16 terminus and that the group has stated
that position at an Boston Region MPO meeting. She claimed that the MPO discriminated by
holding a meeting to discuss the project financing that only white project proponents attended.
She also expressed her belief that the disabled and environmental justice community in Medford
is being marginalized from design working group.
She stated that the FONSI for the Green Line Extension project should be challenged because it
is based on old air quality data. She expressed concerns about particulate pollution from diesel
vehicles and noise pollution, and she called for environmental studies to be done. She referred to
the work of Dr. Marlene Warner, an environmental advisor to GLAM.
Ms. Rosen submitted written documentation.
Dr. William Wood, Green Line Advisory Group of Medford
Dr. Wood spoke regarding the Green Line Extension project and called for civil rights issues to
be addressed. He expressed opposition to extending the line beyond College Avenue to Route 16.
The extension to Route 16 would benefit Tufts University the most while destroying the oldest
African-American community in America, he said.
He called for a study on particulate pollution and a human rights study, and he called for the
project to be delayed until the state gets a report on the human rights element. He referred to the
work of Dr. Marlene Warner, an environmental advisor to GLAM.
He discounted the “highest and best use theory” as not proven an not considering low or
moderate income workers or blue collar workers.
He stated that the project would benefit developers, universities, and the political career of the
mayor of Somerville. He warned that the project would be “another Big Dig.”
Dr. Wood stated that he would be filing a complaint against the Boston Region MPO because he
believes that the MPO held meetings at which funding decisions were made, that did not involve
project opponents. He believes that opponents were only invited to meetings after the funding
decision had been made. He remarked that there will be significant opposition, including from
himself, to obtaining the necessary funding for the project.
He also voiced a complaint about DEP’s public notice for this meeting and stated that he was not
offered appropriate accommodation. He accused the agencies of not following FTA’s rules.
Page 7
EXECUTIVE OFFICE OF TRANSPORTATION TRANSIT COMMITMENT
SUBMISSIONS ASSOCIATED WITH THE STATE IMPLEMENTATION PLAN
PUBLIC HEARING DATED SEPTEMBER 18, 2012
DEPT. OF ENVIRONMENTAL PROTECTION
and
MASSACHUSETTS OFFICE OF TRANSPORTATION
SUBMITTED BY
Green Line Advisory Committee for Medford (GLAM)
c/o 25 Bussell Road
Medford, Mass. 02155
SUBMITTED TO
Katherine Fichter
Mass. Dept. of Transportation
Office of Transportation Planning
Room 4150
Ten Park Plaza
Boston, Mass. 02116
Katherine.fichter@state.ma.us
and
Mr. Jerome Grafe
Mass DEP
Bureau of Waste Prevention
One Winter Street
Boston, Mass. 02018
Jerome.grafe@state.ma.us
September 18, 2012
Public Comments on State Implementation Plan - Transit Commitments 2012
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 2012 Annual Status Report.
Based upon our participation within the Mass DOT citizen participation process over the
last year, these public comments are essentially our report 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 2011 Annual Status Report. Our
public comments submitted on September 18, 2012 are as follows:
In a recent article on the proposed Green Line expansion project in the Metro Boston
newspaper, August 21, 2012, Congressman Michael Capuano is noted as being
skeptical about the commitment of the Commonwealth concerning the building of this
project. When questioned as to whether the project would be completed on time,
Congressman Capuano is quoted as stating in his well known direct style, “I’m willing to
take a bet right now that there will not be a Green Line station here (meaning Union
Square) in 2017. . . I mean they’re making promises to everybody and I don’t see how
they can keep them all.” And he should know as he sits on the Congressional
Transportation Committee at the federal level.
This quote comes soon after Congressman Capuano’s Somerville Journal column of
June 22, 2012 where he states: "The options are clear - either we roll the dice for an
all-or-nothing approach and hope the legislature and future governors are committed to
the GLX, or we work thoughtfully within the funding limitations we now know are real
and get the biggest-bang-for-our-buck in a way that preserves all future possibilities for
GLX." In response to the Congressman’s position of going against conventional
political rhetoric and proposing a step toward progress, a major proponent group,
Somerville Transportation Equity Partnership (STEP) instead announces “The State
can't simply decide not to build it. We shouldn't give an inch.” In other words, STEP
assumes the all or nothing approach. Is Congressman Capuano being the
unreasonable man while STEP takes the reasonable position of Too Big to Fail?
As George Bernard Shaw once pointed out:
"The reasonable man adapts himself to the world: the unreasonable one
persists in trying to adapt the world to himself. Therefore all
progress depends on the unreasonable man." George Bernard Shaw
Should we equivocate about those things we know cannot be done? Should proponents
and agencies such as Mass DOT mislead the public and let politics override what can
and cannot be accomplished in economic bad times? It is not hard to go out on a limb of
going all the way to College Avenue and have yourself chopped off by reasonable
2
politics and those who view themselves as reasonable, thereby, hindering true progress
on the proposed Green Line. Yes, the SIP depends on finances that are never really
clear. Nor is the SIP really clear because Mass DOT is trying to be reasonable instead
of unreasonable. Does this reasonableness lead to a truthful SIP year after year? We
quote another writer, Shakespeare, “To Be or Not to Be”.
The SIP is like the literary argument about George Bernard Shaw versus Shakespeare.
Which is really right and in that argument whose eyes do you see literature through? In
this case being reasonable is what the SIP is trying to say which never reaches the mark
of reality because it never can predict the financial situation. Instead the SIP appears
like a chicken running around with its head cut off since it is forced by politics to be an all
encompassing project. Unfortunately the politics has led the unreasonable man to
oppose this type of politics since it should be about the art of compromise and
transparency. Instead you have to understand the subtext of what the SIP does not say,
which Congressman Capuano has surely picked up in his assessment of the proposed
Green Line project.
If Republicans win the election, this project may be out the window. For the
unreasonable man, this is reasonable. There is confusion between the theoretical and
the reality. Though a plan can change reality cannot. The SIP is not completely looking
at reality and it would be a better document if it was more realistic and compromising
since actions at the MPO, in conjunction with the SIP, are trying to put Route 16 Mystic
Valley Parkway (Route 16/MVP) into the SIP year after year.
The local chapter of the NAACP in the proposed Green Line area has joined the
argument in full context of what the Green Line will do if actions continue, as at the
MPO, to discriminate against people. Yet you see nothing in the plan to end
discrimination as is now being investigated by the Federal Transit Administration (FTA)
or in the end of environmental studies. In fact, it is not clear how you stack up one of the
oldest environmental justice groups in the country against the so-called social equity
analysis of Mass DOT. Something based in unreasonable becomes more reasonable
when you recognize fully what is taking place.
How the state and FTA Region I can say a final Environmental Impact Statement does
not need to be done is a contradiction and should be in contention by environmentalist.
Yet it takes the unreasonable to bring out the facts that the data is so old that in other
professions they would throw out the process. Constant updating of data is necessary to
give a reasonable assumption. Yet it is only the unreasonable person stating this.
Again, Shaw’s unreasonable man makes change happen, not a manipulated political
body that is in investigation of not following its own policies. This is the disgrace of the
reasonable report of the SIP. We, at GLAM, represent people from both political parties,
independents, the environmental justice and disability populations, as well as, small
business owners. We have observed in the last seven years how the art of political
compromise is not followed to accomplish the project of the proposed Green Line to
College Avenue. Yet, there is no deterrent by the state for doing this. We, the
unreasonable, feel uncomfortable that the reasonable people are at our door step. As
Congressman Capuano has said, you could lose it all (referring to the Green Line
Expansion) if you do not compromise.
3
After the presidential elections, we will know what will follow for funding. As some GLAM
members are elected members of their respective political party at the local and state
level, we know and understand politics. We believe the state administration and Mass
DOT should report the reality versus the theoretical concerning the proposed Green Line
Extension and other SIP projects. Instead of letting politics run the SIP, it should be the
reality running the SIP.
Because of the political foothold concerning the proposed Green Line project within the
SIP, born out of a Memorandum of Understanding between the Conservation Law
Foundation and Mass DOT without consulting the public, this SIP project is becoming a
political boondoggle much like the Big Dig with an environmental assessment that holds
no one accountable and no consequences or penalties if environmental or social equity
degradation occurs. This is inexcusable according to professionals in equity studies.
Mass DOT and Mass DEP owe a responsibility to the taxpayers of this state not to return
to the ways of the Big Dig.
FTA Region I has determined that a further environmental impact statement is not
warranted because an environmental assessment has been done. An environmental
assessment that is based upon:
A. old air quality data, now three years old, as evidenced by a November 2, 2011
Mass DEP letter to Mass DOT offered as response to public comments within the
EA process. A document our independent environmental reviewer, Dr. Marlene
Warner who serves on the Houston Galveston Area Council ‘s Environmental
Health committee and its Air Quality subdivision, calls full of holes and written
more on political motivation. We hereby state that Dr. Warner is not connected
to the Massachusetts political sphere. She is independent and continues to be
independent for GLAM, who wishes an independent, objective study. Not so for
the Somerville/Tufts interest. Yet, the environmentalist of Medford and
Somerville run from the issue, even though one of their own, Wig Zamore, goes
on about particulates in Somerville after GLAM reports on the particulate problem
as stated by the California Air Resource board and as other studies from New
York point to the same problem.
This document supposedly offers “Emission reduction offsets" but does not account
for pcbs and other carcinogens in the air from vehicles. Nor is there an accounting
for separation of diesel particulates from ambient air quality measures. Diesel fumes
cause cancer, asthma and COPD, and result in lost work days and school days. Yet
there is no separation of these particulates in air quality studies. The scope of an EA
should extend to all aspects of a project that are likely, directly or indirectly, to cause
damage to the environment, 301 CMR - 11.06 (9), which by definition includes any
actual or probable impairment (other than insignificant) to a natural resource,
including air pollution, 301 CMR - 11.02. Such scope is authorized by the
requirements for the contents of an EA at 301 CMR - 11.07 (6) and should apply to
this project.
Yet, Mass DOT in its infinite arrogance has decided that diesel particulate impact is
outside the proponent’s Proposed Action. Mass DOT is using what is known as
Semi-Transitive thought defined as embracing the vision of change through simplistic
approaches of discrete acts that disassociate themselves from larger social
structures and process impacts shaping transit and land use within the region that
4
may perpetuate injustices based upon cumulative effects. 1 Semi-Transitive thought
is the reasonable way of planning that is tied to the status quo of political power
structures.
On the other hand the unreasonable man unmasks this antiquated thought process
by using a more progressive critical social consciousness process in planning by
utilizing enlightened awareness of tangible social and environmental structures that
affect the community. They include resource allocations, planning, and decisionmaking policies, as well as less tangible structures such as values and beliefs that
influence perceptions as to what is possible, appropriate, and desirable in
environmental sustainability and in achieving social equity.2 Mass. DOT and the
state are falling behind in new thoughts on environmental planning and social equity,
using the reasonable instead of the unreasonable, the latter which precipitates the
real change. This statement of critical social consciousness represents the true
environmentalist versus those who exploit the environmental issues for financial
gain.
This project required an enhanced analysis because the diesel trains from the
commuter rail emit air contaminants into environmental justice communities that
suffer statistically significant high rates of diseases that could be caused or
exacerbated by those air contaminants. Such analyses are also required because
residents already suffer from unhealthy levels of diesel particulate matter in the air
and the project would add to that burden by not remedying the current situation. In
performing the analysis for the Green Line, Mass DOT has failed to determine local
air quality data. The project proponent should have determined air pollution data
local to the project that would have a local impact. By failing to do so, it failed to
assess potential environmental impacts, or to identify mitigation measures that could
be taken for those in the environmental justice and disability communities.
Analysis of local impacts, taking into account local air conditions, is required by the
Massachusetts Air Pollution Control Regulations, which prohibit emissions of air
contaminants that alone or in combination with other air contaminants cause a
condition of air pollution. 310 CMR - 7.01(1). Air pollution means the presence in the
ambient air space of one or more air contaminants or combinations thereof in such
concentrations and of such duration as to cause a nuisance, be injurious, or be on
the basis of current information, potentially injurious to human or animal life, to
vegetation, or to property, or unreasonably interfere with the comfortable enjoyment
of life and property or the conduct of business in the area of concern and
surrounding areas. It is not enough to compare the emissions to state and
metropolitan area standards.
B. Mass DOT has denied the need for Public Health studies of the impact of diesel
upon communities, specifically those in the environmental justice and disability
populations. Their answer is they have no responsibility beyond the Proposed
1
Kyle, D. Brown, Ph.D., Justice in the Context of Environmental Sustainability, Implications,
InformeDesign, Vol 6, Issue 11.
2
Critical social consciousness was coined by Brazilian Educator Paolo Freire as he outlined stages of
critical social consciousness. In the context of Environmental Sustainability the citizen through the
planning process can increasingly see themselves as embedded in a historic social context defined by
relationships of power, oppression, and privilege.
5
Action. They say so, so it must be true. Yet the movement of commuter rails
closer to homes is part of the proposed action. Diesel exhaust emissions from
diesel engines used during construction must be added to the toxic burden
considered for resident species, including vulnerable humans. This was
mandated in the EENF and was not done in the EA.
The question is why is this not being done? Is it economics since the delay in the
project allows time to perform such study? Or may it have to do with the magnitude
required for a lawsuit? Then it must be that planners know more than
environmentalists. In years to come this Massachusetts project could become as
well known as other programs that were created to hurt the environmental justice
and disability communities (i.e. the Tuskegee experiment (health issues) and the
West End urban development project (displacement and health issues). Both
incidences are well documented for their social injustice.
C. The Executive Office of Environmental Affairs (EOEA), Environmental Justice
Policy (EJ Policy) aims to ensure that high minority, non-English speaking, and
low income neighborhoods have a strong voice in environmental decisionmaking; receive the full protection of existing environmental rules and
regulations, and have increased access to investments that will enhance their
quality of life by restoring degraded natural resources, enhancing open space,
and building the urban park network. In so doing, it recognizes that low income
and communities of color in Massachusetts suffer a hugely disproportionate
amount of environmental harm. These groups have all ready documented their
concern.
As documented in the report, Unequal Exposure to Ecological Hazards 2005:
Environmental Injustices in the Commonwealth of Massachusetts, by Professors D
Faber and E Krieg, environmentally hazardous sites and facilities are
disproportionately located in communities of color and working class communities in
Massachusetts, placing residents of those communities at substantially greater risk
of exposure to environmental health hazards. You do not find authentic
representation of these voices on the GLX Design Working Group, a group of
proponents hand picked by Mass DOT to advocate mitigation for the community.
Yet when Mass DOT, the reasonable person, had the chance to appoint the
environmental justice community such as the President of the local branch of the
NAACP representing the impact area or those from the disability community living
near the impact area who applied to sit on this working group, Mass DOT denied
these appointments. The current Green Line Design Working group showed little
expertise or concern for anything but pushing through this project in the experience
of GLAM members who attended each GLX Design Working group meeting and their
subcommittee meetings.
The disparity of representation on the GLX Design Working group is illustrated in this
example. Two families live across the street from each other. One is white and was
appointed to sit on the GLX Design Working group. The other is an African
American and President of the local chapter of the NAACP, who application for
appointment was denied for the GLX Design Working group by Mass DOT. The
majority of people recognize that the white person is a member of a political family.
How was discrimination helped in this situation? A right delayed, is a right denied
(Martin Luther King, Jr.) Where were the politicians in this situation, Senator Jehlen,
6
Rep. Sciortino, Rep. Garballey? They were being reasonable in not spelling out their
position on this kind of discrimination.
The NAACP chapter recognizes it as discrimination since no African American was
appointed to the GLX Design group. The state, even after being told of this situation,
continues to support the effort, another reasonable decision. This white appointee
never walked across the street and invited the NAACP President to be involved in
this project in over 20 years of planning of this project. This same man, non disabled
man, has told the disability community that he knows all about disabilities because
he is a planner. This man as a member of other groups has tried to represent the
disability community and has denied authentic representation of this community in
those projects, especially those with legal standing in a historical project where laws
and regulations require their participation. Yet, the state upholds that type of
discrimination, again the reasonable man. When does the state stop using politics
and start using the concept of the unreasonable man who seeks changes in the
inequitable application of environmental justice and disability rights. In the 1950’s
and 1960’s this type of denial of rights and participation was called discrimination.
Yet, Mass DOT has accepted this as reasonable action.
And the GLX Design Working Group has shown its ugly head when accepting the
kind of equity study as presented by Mass DOT. Yet, the equity study based on old
data around fare rates and service levels does not state that an elderly person living
at Capen Court on Route 16 can pay $4.00 on paratransit, called The Ride, to get to
a) proposed Route 16 station (if ever done), b) to College Avenue (when completed)
or c) to Davis Square (Red Line) and then have to pay the extra dollars to take light
rail to get on the T for health care appointments. But students on reduced discount
fare programs can pay much less as well as college students through college
discount programs.
Here is an example of how the GLX Design Work group conducts itself. At a
subcommittee meeting held by this group in November 2010 at the VNA in
Somerville, the public was asked to submit prior written public comments to be
addressed in the subcommittee meeting agenda, which GLAM did. When attending
the meeting as chair of GLAM and a person with a disability, but not a member of the
GLX Design Work Group subcommittee, I observed the following. The meeting was
delayed in commencing because the GLX Design Work Group chair showed up over
20 minutes late to the meeting and then proceeded to continue to delay the meeting
for another 15 minutes by fiddling with set up of computer equipment she brought to
the meeting. There appeared to be no sound system in the room. Once the meeting
proceeded The GLX Design Group chair set her own agenda and the public
comments that were asked to be presented to this group on station design principles
were never considered or discussed within the agenda. To use an analogy it was if
the child had been given the keys to candy store and the public was not invited to
share in the process. This also is an inequity factor as a result of Mass DOT’s
inability to appoint people of differing view points that would ensure greater objective
representation in advocacy of the community. Again the unreasonable doubter was
the environmental justice and disability community. As chair of GLAM, I was
appalled at the recognized politics of leaving out crucial groups that it was once
stated this project was going to help.
7
These examples give unreasonable people the sense that we are looking only at
university expansion, supported by university students, and that the state is pushing
out and marginalizing the person with a disability or the person from the
environmental justice community. The unreasonable person can see this goal by the
state, especially when the Chronicle of Higher Education predicts a 25% increase in
university intake from overseas to the U.S. university population. This planning
action can cause frustration of disparate impact in populations being tossed from
their life time homes, as in the situation of the West End urban development project.
Where does this leave equity and the mitigation of taking property at today’s prices
and not at tomorrow’s prices. The West Medford environmental justice and disability
community see this environmental burden as they are marginalized around issues of
gentrification and displacement, all ready rearing its ugly head in Somerville over the
fight about affordable housing in Union Square and in environmental concern of
undue burden.
We, who are unreasonable people, want an explanation of how, what, when and
where in looking at disparate impact and in achieving equitable means. We, who
want to participate, have had to take the slings and arrows for asking these kinds of
questions. And now all we have to do is look at the current situation in Somerville
and the fight over affordable housing, which represents nothing less than the legacy
of the West End, Kendall Square and Davis Square in social and racial inequity. The
West End has been well documented in its disparate impact while the Red Line
extension from Harvard Square to Davis Square resulting in inequity, documented by
Reconnecting America and in Professor Charles Olgetree’s book, Presumed Guilty,
on the Professor Gates arrest case.
D. Mass DOT claims the GLX Design Working group as part of its Public
Involvement Plan and in their FTA EA response to public comments they state
the Design Working group has been meeting quarterly. But in looking at our
records and on the Mass DOT greenline website, this group has not met in over
a year.
E. We also find misrepresentation in the social equity study that Mass DOT included
in the EA. They claim that fare increases and services are equal for the
environmental justice and disability community, again using old data from 2011.
Yet they were fully aware in preparing their response to public comments in
January 10, 2012 that they would be increasing fares and making service
reductions, particularly the jump in paratransit fares upon the elderly and
disability community. Our understanding from the Disability Policy Consortium,
of which we are a member, that paratransit ridership has seen an unofficial drop
of 20% in ridership within the first three weeks of July when rate increases took
affect. This means that the elderly and disability community are once again
being isolated within their community. In the midst of a compliance review audit,
where is the transportation reform of this progressive administration?
Unreasonable doubters see a reform that is worst in disparity impact than before
the reform. The Green Line project seems to be more about planners and
private developers and university expansionism than it is about the people of the
state.
This issue needs to be addressed in an updated social equity analysis and expanded
upon as discussed earlier in these comments. Social equity studies should also
8
incorporate the fact that expansion of transit brings more cost in operation, maintenance
and capital spending. None of these factors were evident in analysis documentation
Mass DOT provided to justify their position of equitable distribution.
These are a few of the many fallacies we have seen within the EA process. And we do
believe that there is conflict of interest when the technical assistance of the FTA Region I
also is allowed to sign off on the Environmental Assessment. Therefore, we believe that
this EA on this project must be taken to a higher level of review by those who have no
political vested interested in this project. When a proponent can state that construction
noise will be mitigated by piles of soil excavation without acknowledging environmental
consequences of whether that soil is contaminate or will wash into the stormwater
management system, there is something clearly wrong with this environmental picture.
Conclusion
If there is one thing we can agree with Mass DOT on, that is that Route 16 is not
Medford Hillside and is not part of the mandated commitment under the SIP. But GLAM
is aware that the MPO and Mass DOT has approved the paper movement of money into
the TIP for 2016 to fund the station design and planning of a Route 16 site without true
environmental studies. Even if this station design and planning is to occur, the
environmental and disability community have a role which has been denied by Mass
DOT and its planners. This is what unreasonable people think since history has proven
it correct that these communities have been disenfranchised and marginalized from their
proper roles. We understand this is an attempt by proponents and Mass DOT to
manipulate the political system for their benefit and that the proponents will likely in this
SIP process push for Route 16 to become a mandated destination.
But Mass DEP should be aware that we have contended to the FTA Office of Civil Rights
that MPO violated the intent of the 23 CFR 450.212 (Public Involvement) in its April 19th
meeting where they voted upon these funds by encouraging invitation only of white
proponents while leaving out those constituencies and other interested parties who will
be impacted by this Route 16 station and may have opposing or other points of view.
These populations include the environmental justice and disability communities that will
be impacted by diesel particulates, large traffic and parking problems and other issues.
The impact of contamination that could occur if piles of dirt are allowed in construction to
seep to the Mystic River. The impact to historical canals under the land that could occur.
Therefore we support the Mystic Valley Regional chapter of the NAACP in its opposition
to the Route 16 site based on the marginalization of this community and that
environmental studies must be requested and done within the MPO and Mass DOT
process even though new “unqualified” experts at Mass DOT and the MPO can state we
don’t need an final environmental impact assessment. The question arises where is the
true environmentalist in speaking out about these issues of Route 16 as they speak to
particulate issues in Somerville. Have some environmentalist lost their way for the gain
in economics and for status in a university? These questions need to be answered. Yet,
the reasonable person contends they need no final environmental study. Therefore,
GLAM can also claim you do not need the MPO, the Mass DOT and the kind of reform
we have seen, which is no reform.
9
We have asked once before in this forum where is the reform in this administration?
Where are the environment checks and balances? When these checks and balances do
not happen, disruption happens. Where are the environmental justice and disability
checks and balances in equity studies that take into consideration all the factors, not just
what Mass DOT wants to show in their discrete studies of disassociation of larger social
structures and process impacts?
According to 23 CFR 450.212, a federal regulation, “Public involvement processes shall
be proactive and provide complete information, timely public notice, full public access to
key decisions, and opportunities for early and continuing involvement.” GLAM contends
that the environmental justice and disability community’s voices were marginalized within
the MPO Route 16 process against regulation 23 CFR 450.212.6.a “A process for
seeking out and considering the needs of those traditionally underserved by existing
transportation systems, such as low-income and minority households which may face
challenges accessing employment and other amenities.”
We also understand that the FTA has provided only a medium rating for this project to
College Avenue due to the significant instability of the MBTA finances. The Patrick
administration and Mass DOT have proposed to the FTA in our opinion a hypothetical
financial plan that is not based in political reality of these uncertain economic times. We
also know that the FTA based upon the civil rights compliance review we precipitated
around Title VI and ADA has found deficiencies, just as we have found additional civil
rights deficiencies around the MPO process of which we have notified the FTA. And the
FTA is requiring these issues be addressed as part of the mitigation of this project in the
background as its letter points out.
But these deficiencies pointed out to Mass DOT over and over again through the Green
Line process by GLAM were only addressed by forcing the issue at a higher level of
scrutiny at the federal level and moving it out of the region. We conclude that this also is
an option when reviewing the lack of true environmental assessment concerning the
Green Line project and the continual lack of a proper social equity analysis. Although
the pretty language that Mass DOT uses around social equity sounds good, the intent is
in the action and we believe that intent is lacking in the environmental assessment.
As we doubters and unreasonable people have noted before in the political situation,
projects like the proposed Green Line create the disrespect for planning, the disrespect
for financial planning and transit planning as the state uses and abuses the system.
Unlike Mass DOT or the MPO, GLAM does not discriminate. Hence, we have operatives
from the Republican Party who see what we see. Operatives in the Democratic Party
who see what we see as well as other groups such as the NAACP chapter and other
disability groups. Whom do you think is causing the most disruption in government,
these people or the Commonwealth of Massachusetts? Do you think these political
people will not bring up these very issues in the next four years, no matter who is
President? This situation can lead to a tremendous disruption between the body of
politics and groups of people who support the environment, the environmental justice
and disability communities in working toward cooperation and compromise. Believe us,
we understand this very well. We are stating that you are creating the problem by your
reasonableness in not using up to date data and purveying of discrimination.
No one is stating they cannot support this project to College Avenue. We are saying you
are delaying the project and it is time to correct the problems for those unreasonable
10
problems count and you should be mitigating those problems with the planners and the
people.
After College Avenue you are burdening unduly the very people you claim you are
supporting, yet we cannot find any of these people participating in Mass DOT’s process.
Even the Regional Transit Advisory Council did not ask for input from these people, the
unreasonable or the NAACP. Again, discrimination by the MPO and Mass DOT who like
a friendlier crowd as they state in a meeting after the disability community left the room
of one of their meetings. Or the discrimination conducted by the MPO recently in inviting
only proponents to their meeting on the proposed Green Line/Rte 16 while the abutters,
environmental justice and disability communities were omitted, justifying their position
using an outdated minor petition made by supporters many years ago. A broadly
defined petition that did not mention or address social equity issues pertaining to the
environmental justice and disability community even though these issues were plainly
out there to be addressed. Mass DOT is well aware there are groups of business
people in Medford not in support of this project and who voted against this project at a
meeting Mass DOT attended. Just as they are aware that the NAACP chapter has its
grave concerns and do not support the Route 16 station. But in Mass DOT’s view, the
only representation to be considered in Medford is only those who support this type of
discriminatory effort.
Yet, no one addresses the MBTA car barn issue in Haines Square Medford, one of the
oldest unresolved environmental problems in the city between the MBTA and Medford.
But it is so important that we reach Tufts University that all else does not matter.
The excuse that the legal court has mandated the proposed Green Line Extension does
not seem to hold regard when speaking to other SIP projects such as the Fairmont Line
or the extension to Jamaica Plan or the Red Line/Blue Line connector.
Is the future more discrimination as pertains to the proposed Green Line project? It
surely looks that way and discrimination is reinforced through infrastructure projects for
university expansionism programs that are not necessarily inclusive of the environmental
justice or disability populations within their student bodies. Nor do these projects
represent the intellectual arguments used by the environmental justice or disability
community concerning the pushing out of these populations. This SIP project continues
to keep out and weed out the process for groups that are the unreasonable people
seeking change and progress and doubters asking for the truth. Instead of saying how
do we protect from the onslaught, government agencies like Mass DOT create the chaos
of continuing social inequity. This is where true educational scholarship needs to apply.
These comments are respectfully submitted by GLAM and have been approved by its
Executive Committee, listed at the end of this document, at its board meeting of August
15, 2012.
Carolyn Rosen
Chairperson
GLAM
11
Respectfully Submitted by:
Ms. Carolyn Rosen, MBA, MTS
ADA Coordinator/CFO
Chairperson of GLAM
Elected member of the Medford
Democratic Party and officer
Member of the Zonta Club of Medford
25 Bussell Road
Medford, Mass. 02155
William Wood, M.S., M. Ed., Ph.D.
Retired Business Owner, Wood &
Associates
Elected Medford Democratic Party
member and Ward Chair
Kiwanis Club board member
Disability Advocate
25 Bussell Road
Medford, Mass. 02155
Neil Osborne, Esq.
President of NAACP Mystic Valley Area
Branch
122 Boston Avenue
Medford, Mass. 02155
Gwen Blackburn
Retired Dir. Of Multi-Cultural Dept.
SPED & Harassment liaison,
Civil Rights Officer
Medford Public Schools
233 Arlington St.
Medford, Mass. 02155
Ms. Mary Anne Adduci
Secretary of GLAM
Board of Director of Arthur D. Little
Alumni Association
2 North Street
Medford, Mass. 02155
Mr. Henry Milorin
Elected Member of the Medford
Democratic Party
Disability Advocate
8 Temple Street
Medford, Mass. 02155
Mr. Bernie Green
Chairperson of the Medford
Republican Party
Former Elected state representative
for the state Republican Party
608 Main Street
Medford, Mass. 02155
Mr. Felix Blackburn
EEO/Affirmative Action Officer
State Transportation Authority, Retired
Commission Member of the Medford
Traffic Commission
233 Arlington Street
Medford, Mass. 02155
Paul Morrissey
Business owner, Aerocycle
642 Boston Avenue
Medford, Mass. 02155
12
13
From:
To:
Subject:
Date:
Neil Osborne
Fichter, Katherine (DOT); jerome.grafe@massmail.state.ma.
us;
NAACP Public Comment Greenline Extension
Sunday, September 23, 2012 1:24:28 PM
I am the President of the Mystic Valley Area Branch of the NAACP. As
the local entity of the National Association for the Advancement of
Colored People the Mystic Valley branch services the cities and towns
of Medford, Arlington, Malden, Everett, Winchester and Woburn. The
primary mission of the NAACP and the Mystic Valley branch locally is
to ensure the political, educational, social and economic equality of
rights of all person and to eliminate racial hatred and racial
discrimination.
I am compelled to comment on the continued un-addressed concerns of my
fellow West Medford neighbors about needlessly extending the Greenline
all the way down to Route 16. Historically, West Medford has
maintained a high concentration of African American households. Our
West Medford community has always been a vibrant open and diverse
community.
The Mystic Valley Area NAACP remains opposed to needlessly expending
limited resources on studying then building an extension that will
encroach on the property of neighbors and further invite unwanted
development in the part of the city with a historically high
concentration of African American families.
It is important for the planners involved in this Greenline extension
project to know and understand that a majority of the African American
community does not welcome the Greenline at Route 16.
We ask the question who is in a better position to absorb the burdens
of the Greenline terminus? We see terminating the Greenline at
College avenue as a better solution for the Medford community then
forcing this process on West Medford.
If you would like to discuss our position further please feel free to
contract me directly at 617-482-1160 or you may want to speak with
members directly which can also be arranged.
I hope you find this correspondence helpful as we felt compelled to
share how unwanted this project is viewed in our community.
Neil Osborne, Pres.
Mystic Valley Area Branch NAACP
September 24, 2012
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: 2012 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 2, 2012 (“2012 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 escalation of estimated project delays, particularly those announced last
year, and the lack of sufficient expenditure of funds to ensure that all of the remaining SIP
projects are completed on schedule. The Commonwealth’s legal obligation to complete these
projects is binding under the federal Clean Air Act and pursuant to the settlement agreement in
CLF v. Romney et al., United States District Court for the District of Massachusetts, Civil Action
No. 05-1048 (hereinafter, CLF v. Romney); the projects are crucial to achieving attainment of
ambient air quality standards, and are vital to the health and mobility of the area’s residents.
The SIP requires that status reports be filed annually to ensure that projects do not fall
behind schedule and the necessary steps are taken so that compliance with the Clean Air Act is
not delayed in the event that challenges arise. We urge the Massachusetts Department of
Transportation (“MassDOT” or “Department”), the Massachusetts Department of Environmental
Protection (“DEP”), and the U.S. Environmental Protection Agency (“EPA”) to take all
necessary actions to respond to the 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 interim
emission reduction offset projects or measures. See 310 CMR 7.36(4). Such interim offset
projects or measures should be identified through a transparent and thorough community public
participation process. In addition, CLF requests that DEP require a mid-year status report to be
filed by MassDOT by December 31, 2012, 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 are significantly 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 the 2012 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.
Earlier, in June of 2012, the MBTA also received approval from the FTA for the Green Line
Extension project to enter preliminary engineering. 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 SIP Status Report, 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.
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). Since last year’s SIP report, MassDOT has 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.
2
Specifically, the following feasible and effective suggestions were not analyzed: 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 last year’s and the previous year’s SIP Status Report omission, the 2012 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 states 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 Commonwealth in 2013 will address its transportation finance challenges in
general and the MBTA’s budgetary needs specifically.
CLF continues to be troubled by the proposed segmentation of the Green Line Extension
Project, which 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 most recent Transportation
Improvement Program. To comply with the SIP, MassDOT must construct an extension of the
Green Line “from Lechmere Station to Medford Hillside” by December 31, 2014. See 310
C.M.R. 7.36(2)(j)1. The Green Line Extension Project, as proposed, does not comply with the
SIP, since Medford Hillside’s well-documented historical boundaries do not include the location
3
of the proposed terminus at the intersection of College Avenue and Boston Avenue.1 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
Although significant progress has been made on the construction of the Fairmount Line
Improvement project, e.g., construction of the Talbot Avenue Station and the Talbot and
Woodrow Avenue bridges rehabilitation projects is 90% complete, further delays continue to
proliferate. While last year the MBTA anticipated final completion of the Newmarket Station by
February 2013, the new estimate, August 2013, adds another six months of delay. Likewise, the
Four Corners Station was expected to be open for service by November of 2012 and now is
estimated to be complete six months later, in May of 2013. Last year’s update anticipated
construction of the Blue Hill Avenue Station to start by May of 2012, but as of July of 2012 the
station had only reached the 60% design stage and this year’s update states that “it is unlikely
that the Blue Hill Avenue Station will be completed before 2015 at the earliest.” See 2012 Status
Report at 5.
To this end, MassDOT has implemented 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. We were pleased to see that the offset measures
incorporate one of the ideas that the Fairmount/Indigo Line Coalition (the “Coalition”) put
forward (shuttle bus service from Andrew Square to Boston Medical Center) and that both
measures are targeted to benefit the neighborhoods most impacted by the delay in the Fairmount
Line.
At the same time, we were disappointed that the MBTA did not include a fare reduction
on the Fairmount Line during the period of delay as one of the interim emission offset measures,
as was proposed by the Coalition last year. By fare reduction, we refer to making the $2.00
transit fare applicable to the whole line, including the two stations in Hyde Park (Fairmount and
Readville) which now have fares of $5.50 and $6.00 respectively. The Coalition proposed this
offset measure because it would most directly help the people impacted by the delay in the
construction of the stations. Moreover, it would have offered a great opportunity to help market
the Fairmount Line as the stations are being built and work towards increasing ridership, whereas
the increased bus service proposed distracts from the opportunity to promote usage of the
Fairmount Line. Measures to improve service and increase ridership on the Fairmount Line are
1
For a more detailed explanation of this issue, please see CLF’s comments on the Draft and Final Environmental
Impact reports for the project available at
http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.
pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf
respectively.
4
required by the SIP. See 310 CMR 7.36(2)(h)1. CLF therefore respectfully requests that DEP
require the inclusion of the fare reduction as one of the interim emission offset measures to
counter the negative impacts of the delays of the Fairmount Line Improvement Project going
forward, particularly since the completion of the project has been delayed even further.
Construction of 1,000 New Parking Spaces
CLF appreciates that after originally planning to delay the construction of the 1,000 new
parking spaces required by the SIP without implementing an interim offset project or measure, in
response to CLF’s comments, MassDOT provided increased Saturday bus service on MBTA
Route 111. This additional service began on January 7, 2012, the first Saturday following the
December 31, 2011 deadline, and continued until parking at the Wonderland Station was
completed.
CLF, however, cannot agree that the Commonwealth has fulfilled this SIP requirement.
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. After CLF pointed out
last year that the MBTA was not listing any parking spaces at the Savin Hill Station on its
website, the MBTA now states that there are eighteen parking spaces. See
http://www.mbta.com/schedules_and_maps/subway/lines/stations/?stopId=14289&lat=42.31109
9&lng=-71.053175 (last visited September 14, 2012). MassDOT, however, is counting twenty
spaces towards the completion of this requirement. See 2012 Status Report at 9.
In addition, CLF continues to remain concerned 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,
unlike the garage planned for the Waterfront Square project, include 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
5
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 appears, 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. The contribution of sufficient transit commuter parking spaces from South
Garage to meet the SIP requirement can therefore not be guaranteed.
We therefore urge DEP to require MassDOT to address these issues and to continue
report on this requirement in SIP status updates until there is full clarity that this requirement has
been completed.
Blue Line Platform Lengthening and Station Modernization
MassDOT failed to include the Blue Line Platform Lengthening and Station
Modernization project in its 2012 Status Report. CLF disagrees with MassDOT’s continued
claim that its obligations under this SIP commitment are complete by virtue of implementing sixcar train service despite the failure to modernize all Blue Line stations. The SIP requires both
Blue Line platform lengthening and station modernization. See 310 CMR 7.36(2)(g) (“Before
December 31, 2008, construction of the following facility shall be completed and opened to full
public use: Blue Line Platform Lengthening and Modernization.” (emphasis added)).
MassDOT’s failure to report on this commitment therefore violates the law. Furthermore, both
components of this project are necessary to achieve the increased ridership and attendant
improved air quality required under the Clean Air Act through the SIP. Increased ridership is a
function of available capacity, access, and attractiveness of service. Modernization of old,
inaccessible, uncomfortable, and otherwise non-user friendly stations and facilities leads to
increased ridership and thus to improved air quality.2
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 2012, 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.
2
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).
6
We are pleased that construction at the Orient Heights Station has commenced this year
and 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 will
include 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 and that fencing has been
erected to separate the current work zone from the temporary station, which will allow Orient
Heights to remain open to the public during the lion’s share of the construction period. The
MBTA has indicated that it expects the project to be completed by the spring of 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.
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. Last
year, 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
7
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.
Ultimately, the SIP must facilitate the Commonwealth’s attainment of compliance with the
NAAQS. Currently, classification and designation status for the 1997 eight hour ozone standard
in Eastern Massachusetts remains moderate non-attainment. See 77 FR 31496 (May 29, 2012).
DEP should therefore reject MassDOT’s flawed logic and should not amend the Transit System
Improvement Regulations, as recently proposed.3
Despite MassDOT’s grim prognosis of the availability of federal funding, increasingly
only projects that are shovel-ready are eligible to apply when federal funding opportunities arise.
Thus designing a transit project, more than anything else, raises its chances of ever being built.
One new opportunity for potential funding, for example, only recently became apparent and, 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 last year
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
3
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
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 under
two percent 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 453 (September 2009). Thus, a careful review of MassDOT’s numbers reveal that the “dramatic
increase” in project costs it describes in its letter is also a result of the application of a
particularly and deliberately conservative budgeting approach for the Red Line/Blue Line
Connector.
Amending the 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.
9
Conclusion
The projected delays for the Green Line Extension, the Fairmount Line Improvements,
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
Kenneth J. Krause
50 Mystic Street Medford, MA 02155
781-396-0920 kenneth.krause@comcast.net
September 25, 2012
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, 6th Floor
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 (2) (f) through (j) that was submitted by the
Massachusetts Department of Transportation (MassDOT) to MassDEP on July 2, 2012.
Green Line Extension to Somerville and Medford
Unlike the 2011 annual update and status report, which announced another substantial
delay in the completion timetable for the Green Line Extension (GLX), the 2012 report
summarizes what I would term the most constructive year of work and progress on this
project in the eight-plus years I have been engaged as an interested citizen and former
advisory group appointee.
While we all would like to see the extension completed before the current mid-2019
estimate, for the first time, I believe the project team has a realistic and achievable
construction timetable in place, outlined in the four-phase scenario introduced in the
past year. It is encouraging to see firm dates projected for each phase of the GLX
timeline, the most exciting of which is the long-awaited start of construction this fall.
Other positive developments as stated in the report are the advanced station designs,
including the pedestrian, bicycle and bus networks around them; approval of the CMGC
delivery method for certain segments of the project; and the completion of the state
environmental review process and progress on the federal level environmental review.
I would also like to commend the HDR/Gilbane consultant team for its professionalism
(and candor) in performing its work, and to recognize all parties involved for the smooth
and seamless transition of the project from MassDOT’s direction to the MBTA.
Two other positive developments over the last year but not mentioned in the report
were:
Kenneth J. Krause - 2012 SIP Annual Report
+ The continued support of the Green Line Extension by the Boston Region
Metropolitan Planning Organization—allocating funds not only for the scope of work to
Union Square and College Avenue, but also recommitting $190 million to design and
construct the final leg of the extension to its permanent terminus at Mystic Valley
Parkway, action that had the support of Medford Mayor Michael J. McGlynn at Tufts
University, in addition to Somerville Mayor Joseph Curtatone.
+ The year-long Mystic Valley Parkway Community Visioning Process, conducted by the
Metropolitan Area Planning Council, which thoroughly and thoughtfully examined the
impacts and opportunities surrounding a Green Line station at Route 16 and
summarized them in a very readable and useful report that will be a valuable tool for the
cities of Medford and Somerville as they analyze potential redevelopment of the area.
The Mystic Valley Parkway station is integral to the state fulfilling its legal requirement to
extend the Green Line to Medford Hillside. While the MPO funding designation is
critical, it is equally important that planning for the Route 16 station move forward in
order to correspond with the detailed funding scheme approved by the MPO for each of
federal fiscal years 2016 through 2021:
This is an issue I would like MassDEP to address in the course of approving the 2012
update and annual status report by asking MassDOT for clarity around its plans to
formalize its schedule, and devote planning resources, for the Mystic Valley Parkway
station.
If there was one area in which I felt the project team fell a bit short in the last year it is in
failure to engage the Green Line Extension Design Working Group in any meaningful
way. While there were three station workshops conducted, and public meetings on the
Phase I construction scheme and on Noise and Retaining Walls, there has not been a
Kenneth J. Krause - 2012 SIP Annual Report
meeting of the Design Working Group since early December 2011. This is a very
knowledgeable and capable advisory group, willing and eager to contribute to the
success of this project, and it should not be excluded from the process.
With Phase I construction about to begin in a matter of weeks, a new consultant team
coming on board to execute final design, and several new and lingering design issues
identified in the latest monthly status report (September 20, 2012) for the GLX, it would
behoove the project team to have a full Design Working Group meeting as soon as one
can be scheduled.
My other criticism regarding the last year’s project developments pertains to MassDOT’s
initial analysis and response to public suggestions for Interim Offset Projects that
MassDOT must implement for missing the GLX completion deadline of December 31,
2014. In presenting a summary grid of the suggested projects, MassDOT dismissed
virtually all of them for one reason or another, even before any modeling for their
potential air quality benefits had been done. There were many worthy and feasible
projects proposed, two of which I will address in the following section.
Red Line/Blue Line Connector Design
As stated in a separate comment letter, I urge MassDEP to reject MassDOT’s request
to be relieved of its legal obligation to complete the design of the Red Line/Blue Line
Connector. The need to connect 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.
More significantly, Suffolk Downs – on the Blue Line in East Boston – is a leading
candidate for a casino gambling license that, if granted, would trigger a huge
redevelopment of the race track into a resort casino that would attract thousands of
visitors and employees daily. (And, according to the September 21, 2012 Boston
Herald, a developer also is examining the possibility of South Station – on the Red Line
in Boston – as a casino location.)
The introduction of a casino in one of these locations is just one more reason why the
Red/Blue Connector design should not be removed from the SIP transit commitments. If
anything, this should elevate the importance of the project and jump-start work on the
next phase – with the financial support of Suffolk Downs should it be granted a casino
license, as is widely expected.
Suffolk Downs officials already have pledged financial support for roadway
improvements on Route 1 near the race track, but have overlooked the need to improve
public transit service to the area. Meanwhile, other private entities have recently
stepped up and offered financial contributions to the creation of commuter rail stations,
most notably New Balance Company for its new campus in Brighton, and Raynham
Park in Taunton should it receive a slot parlor license. Suffolk Downs should be
approached for a similar commitment.
Kenneth J. Krause - 2012 SIP Annual Report
Also, MassDOT’s major reason for asking to be relieved of its SIP Red/Blue
requirement – that it has been unable to identify funding to construct the Red/Blue
Connector “at any point in the next 20 years” – is not a sound one, in my view. Few
projects in that time horizon have a fully identified funding source, yet planning wisely
continues on the projects deemed most valuable (which I submit the Red/Blue
Connector is one) so they are shovel-ready when funding is secured for them.
Curiously, MassDOT continues to aggressively pursue the South Coast Rail project –
with Governor Patrick as recently as last week meeting with EPA officials and others in
Washington to try to advance this project past regulatory hurdles – despite the fact that
it is neither a SIP Transit Commitment project, nor does it have any construction money
appropriated at this time.
My opinion is that the Red/Blue Connector is an immensely valuable project that is
integral to the efficiency of the MBTA system and its ability to meet increasing ridership
demands, and therefore should not be removed as a SIP requirement.
However, should MassDEP agree with MassDOT’s request to cease work on the
Red/Blue Connector, it must require MassDOT to identify substitution projects and
commit to building them via inclusion in the SIP. The most logical, practical and
environmentally beneficial substitution project to add is construction of the permanent
terminus for the Green Line Extension at Mystic Valley Parkway (Route 16).
Not only is this location MassDOT’s Preferred Full Build Alternative for the Green Line
Extension and has unanimous support from all major stakeholders, but it is a project –
unlike Red/Blue – for which the state has identified a funding source, and not over a
20-year horizon, but in the next eight years, as noted above in reference to the Boston
Region MPO’s funding support.
It is imperative that the state align its planning and funding resources so that they are
focusing on the same goals (and the same projects). The addition of construction of the
Green Line Extension to Route 16 to the SIP would be the perfect substitution project
for the elimination of the Red/Blue Connector design (which already had been scaled
back from the original SIP commitment, which was for design and construction).
My final suggestion regarding MassDOT’s amendment request is for MassDEP to
require MassDOT to appropriate $26 million – the difference between the original $29
million estimate for the Red/Blue Connector design and the $3 million already spent on
it – toward the Interim Offset Projects that the state is required to implement as a
penalty for missing the deadlines to complete two other SIP projects: the Fairmount
Commuter Rail enhancements, and the Green Line Extension.
Specifically, a large portion of this money should be designated to be spent on two
Interim Offset Projects in the Green Line Extension corridor:
+ Construction of the multi-use pathway from Harvard Avenue at the West
Medford/Arlington line to the Malden Bridge between Somerville and Everett, as
described and mapped in the Mystic River Reservation Master Plan of November 2009.
Kenneth J. Krause - 2012 SIP Annual Report
+ Construction of the extension of the Somerville Community Path in all applicable
geographic areas contained in Phase I of the Green Line Extension construction, which
has a completion timetable concurrent with the deadline for implementation of the
Interim Offset Projects (December 31, 2014). In particular, this should include the
design and construction of the Community Path from Inner Belt to North Point, where
development construction is under way and increasing rapidly. Now is the time to
integrate the Community Path in this area.
Both of these projects will provide significant regional mobility and air quality benefits by
providing safe, accessible and inviting routes for bicycling and walking (including
improved access to transit) that will make these modes an attractive and viable
alternative to driving in this badly congested and polluted corridor.
MassDEP’s role
Finally, I would like to stress the important role that MassDEP must play in seeing to it
that these vital transit projects are completed as soon as possible.
There is a reason the Green Line Extension, unlike quite a few other transportation
projects, has survived over the 21 years since it became a SIP commitment and eightplus years of intense planning: it is a phenomenal project with positive implications for
regional mobility, air quality, economic development, and transit equity that become
more profound with each passing year.
Just look at the development in progress currently along the GLX corridor, from several
buildings at North Point, to Maxwell’s Green at Lowell Street in Somerville, to the
expansion of the 200 Boston Avenue building in Medford. These projects are all being
executed with the anticipation and expectation of the Green Line Extension becoming a
reality. I shudder to think what are roads and air will be like should these and other
developments proceed apace, while the Green Line Extension languishes, or worse.
I encourage MassDEP to remain fully engaged in the state’s progress toward fulfilling its
obligations of the remaining SIP projects, and also to be a vocal advocate for the state
legislature to create 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
Ken Krause
50 Mystic St.
Medford, MA 02155
781-396-0920
cc:
David Mohler, Boston Region MPO
Richard Davey, Secretary of Transportation
Kenneth J. Krause - 2012 SIP Annual Report
33 Broad Street I Suite 300 I Boston, MA 02109
Tel: 617-502-6240 I Fax: 617-502-6236
WWW.AB ETIERCITY. ORG
BOARD MEMBERS
U::Jwrt:nce S D•Cara •
September 25, 20I2
(Chamn:m)
M•cllael Cantalupa ·
( V•ce Chairman)
Theodcre Oat1s •
(Vee Charrman)
Ed,uard H Lac td ·
(V•::e Cflrmman)
Susan Wol ~ off •
(Treasurer)
Douglas M McGarrah"
(Secretary-Clerk)
r<atl1aru1e E Ba:t na
Andrew Bal.fT11n
Rebert L Ber;l"
J~ffrey P. Bco e
':\':~yne Bouchard
r<ev111 Boyl€
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Den Criggs
Enc Buehren~
Charles T Bu• !Ck
~...arry Ca1crc
Joserh Carroll'
Bnan Cha•sson
Jonn C'cr.art::ll
Kate Fichter
MassDOT Office of Transportation Planning
I 0 Park Plaza, Room 3I70
Boston, MA 02I I6
Jerome Grafe
MassDEP Bureau ofWaste Prevention
One Winter Street
Boston, MA 020 I8
Via e-mail: katherine.fichter@dot.state.ma.us
Jerome.grafe@state.me.us
Re: MassDOT Transit System Improvements: SIP - Transit Commitments, 20 I2 Status Report
Dear Ms. Fichter and Mr. Grafe:
D:natd E. Conover
Pa .I Crcwley
Jot n Curley
Jo atnan G Dav1s
Pame 3 Delphenich
Ge:01 Ocn<:erlc'n
iJIChael J Donovan
.!0 1111 E . .Jrew'
R~nald M. On1~ e;·
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Jonn cerno dez
C'1r stopher Gale'
R c'"'ard t... Ga,v1n
Thomas Goern:;r:t
On behalf of A Better City (ABC), I am pleased to submit the following comments on the 20I2
status report on transit commitments of the State Implementation Plan. We are particularly
focused on the expected delay in implementation of the Green Line Extension Project, which is a
critical part of the overall transit system that will serve the region in the future. Air quality
benefits associated with this project are an important contribution, along with its transportation
improvements. Both sets of benefits should be provided in the near term with implementation of
effective offset measures.
Dav d Greaney
P~tnr:k Ha~v:ell
P. ~ard Heller
't1o 11as J. Hynvs Jr ·
loa 1ne l' .l<!.dl ':le:
Mar~ R .!O~lflS'Jn'
Cdward C. Johnson 1·.'·
Damun .Jcnes
W11i13m Koroc
Colleen !'"eat1rg
Ja:nes Keefe
R1c'1arc1 Knr~'l
SC.Fldra M Lally"
i',e·Jir. Lem·m
Nc.rman 3 Leventhal' t
Paul Levy
Je~fley
A Better City is a membership organization that advocates for sustainable transportation and
development policies and projects that achieve high standards of design, support economic
development, enhance mobility, and provide environmental benefits.
We remain concerned that the proposed interim emission offset projects being considered for
mitigating the delay in Green Line Extension Project implementation do not provide sufficient
transportation and other associated benefits in addition to the air quality improvements in the
project corridor.
Lcx:.kwood
Ct-r•51Cpller 'JI.' ~-;:~he'
?aul t.1cJ:tera
R CK fv'!athla
~ J~d R M dr.lleto'l
Adam 1.-i•tt.:lwl
Althur Mcrn!::;:. uqueiH
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'"11 0th~ G ~/urii;Jfl€"
l)Jn :.1u pry
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MJrga:et 1'-lon·"Jn"
David f,. O'Shaughne'i:iv
We have reviewed the list.ofproposed measures and the analysis by CTPS. We believe that
there are many fine candidates for implementation within the Green Line transit ridership area,
with a variety of benefits associated with each measure. One approach to selecting options is to
choose measures that will not only provide air quality benefits, but will also address other
worthwhile objectives and provide high levels of transportation, economic development,
environmental justice, and environmental benefits.
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re<1P.
One such measure that deserves further consideration is construction of a bridge between North
Point in Cambridge and Inner Belt in Somerville that provides benefits in these areas. The
bridge in this location would serve several important functions:
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It provides the critical link of the "community path" bicycle trail through Somerville,
which has been prioritized as part of Green Line Extension planning, through North Point
to the Charles River Basin, which is a very significant element in the "Green"
environmental contribution of the Green Line Extension.
R1chard;. Dun1llO
(P,esiC1em & CEO)
• E ,..ecu: 'Je Ccmm1:tee
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Cha man
TRANSPORTATION • lAND DEVELOPMENT • ENVIRONMENT
(2) It provides for important connectivity from the North Point development to the Inner Belt
area of Somerville and Sullivan Square, reducing the pressure on the heavily congested
McGrath and O'Brien Highway, and greatly enhancing the economic development
potential of the Inner Belt/Brickbottom area.
(3) It provides an efficient path for bus service connecting the Orange Line at Sullivan
Square to the Green Line at Lechmere and the Red Line at Kendall, which is a connection
identified as important in the Needs Assessment ofthe Boston MPO's recently adopted
Regional Transportation Plan. This connection is a "missing link" in the transit network
that will provide essential connectivity between the dynamic Kendall Square area, the
newly revitalized North Point development at Lechmere, the Inner Belt/Brickbottom area
of Somerville, and the regional node at the Orange Line Sullivan Square station, as well
as potentially beyond to brownfield areas in Everett and Chelsea. Beyond Chelsea, the
corridor will to connect to Logan Airport via the new Chelsea Bridge and the East
Boston/Chelsea Bypass Road, currently under construction by Massport.
Completion of this bridge would be another link in the incremental implementation ofthe Urban
Ring concept currently in various stages of design and construction in Roxbury, East Boston, and
the Fenway. The Urban Ring initiative is vital to the continued expansion of the Boston region's
knowledge-based economy. It can also help to reduce congestion in the central subway system
recently highlighted as an issue in a study prepared by the Urban Land Institute.
When the State suspended planning on the Urban Ring in January 2010, it was with the explicit
commitment to continue to prioritize the Northern Tier, an important segment of the Urban Ring
corridor serving the Environmental Justice community in Somerville, Everett, and Chelsea by
improving connections to the Orange Line and the Blue Line.
We concur with many comments made in past public hearings and in previous communications
from interested parties regarding objectives for the offset measures, including:
• The desire to complete the bridge from Inner Belt Road to North Point to accommodate
the community path and bus service along the Urban Ring route.
• Locating interim offset measures in the Green Line Extension corridor.
• Reducing headways on MBTA bus routes in the Green Line corridor in Somerville,
Medford, and Cambridge to help reduce vehicle miles traveled.
• Using low-emission buses in these and other routes in the area to improve air quality.
ABC believes that the most significant mitigation for Green Line Extension slippage is not only
to plan for the Urban Ring, but to actually implement early action transportation improvements in
the Urban Ring corridor, at least from Kendall to Sullivan. This can be done in two stages:
( 1)
As soon as possible, but in no case later than 2014, institute a new bus service from
Kendall Square/MIT Station via Third Street, Binney Street, and First Street to the
existing Lechmere Station, and beyond to Sullivan Square Station. Because the North
Point Boulevard to Inner Belt link does not yet exist, the component of the new Urban
Ring service between Lechmere and Sullivan Square may have to be routed temporarily
via O'Brien Highway, Poplar Street, Joy Street, and Washington Street.
(2) Include the construction of the North Point Boulevard to Inner Belt Road Bridge as part
of the Green Line Extension design-build construction. It may be possible to have this
link completed by December 2014, and MassDOT should make best efforts to achieve
this, but it certainly should be achievable prior to December 2016, by which time
Secretary Davey has committed to infrastructure completion of the Green Line Extension
and operation to Washington Street and Union Square. As soon as the bridge construction
is complete, the Urban Ring early action service between Lechmere and Sullivan Square
should be routed over it to achieve superior travel time and access for the Inner
Belt/Brickbottom area.
ABC recognizes that MassDOT must continue to conduct additional analysis of the offset options
to determine which are expected to be the most effective mitigation to partially offset the air
quality impact of the Green Line Extension schedule slippage. We point out that in the CTPS
testing of alternatives of the Urban Ring for the November 2008 Revised Draft EIR!Draft EIS, the
ridership and associated air quality benefits were significant. In the Urban Ring "Northern Tier"
important Environmental Justice benefits were projected by providing improved transit access to
an underserved community. The Northern Tier segments also attracted significant ridership and
can facilitate the growth of the knowledge economy into brownfield conversion sites.
We suggest that the link in the Urban Ring corridor from Kendall to Lechmere to Sullivan
Squares be tested at a range of suitably high frequency headways: 5-10 minutes during peak
periods, which we expect would be justified by the high demand and anticipated ridership in that
segment.
Other suggested measures such as improving headways on the CT2 and CT3 bus routes are also
worthwhile as short term measures that would benefit users in the Green Line transit ridership
area and should be evaluated and implemented.
In summary, ABC strongly supports the speedy implementation of the Green Line Extension,
with the inclusion of the critical Urban Ring Red Line/Green Line/Orange Line link from Kendall
to Lechmere to Sullivan, not just planned for, but actually implemented and operated. This is a
key opportunity for MassDOT to demonstrate its commitment to support the 2006 SIP, and honor
its recent commitment to the advancing Urban Ring as opportunities present themselves.
Thank you for your consideration of our recommendations.
5780/1
glxlt925
Paul Morrissey
Aero Cycle Co.
642 Boston Ave.
Medford, Ma.02155
781-395-9966
September 25 2012
Katherine Fichter
Mass D.O.T.
Office of Transportation Planning
Room 4150, Ten Park Plaza
Boston, Ma.02116
Jerome Grafe
Mass DEP Bureau of Waste Prevention
One Winter St.
Boston, Ma.02108
Re: SIP Plan- Transit Commitments 2012- Green Line Extension
Dear Ms.Fichter and Mr.Grafe,
I wish to voice my concerns regarding the Green Line expansion plans into Medford.
Due to the MBTA currant fiscal uncertainties I believe that Boston area commuters
would be better served by focusing on improving the system we now have. Deferred
upkeep of equipment and infrastructure denies the current users and potential new
customers of confidence in our transportation system. If we don’t have the funds to keep
our current system running well where are we to find the necessary capital to maintain an
expanded Green Line?
The mandate from 30 years ago to offset the air quality impact of the Big Dig I believe is
in need of review. Automobiles are dramatically smaller and less polluting than when this
initiative was envisioned. I believe studies have shown that the air quality is actually
improving in Medford. How much of an improvement to the health of local Medford
residents would be realized if the thirty year old commuter locomotives that currently
belch diesel particulates were to be upgraded?
Finally, I wish to voice my concerns about the impact this project will have on my
community. The proposed trolley line, I believe, will encourage real estate speculation
that will impact the current residents negatively. Medford currently benefits from a
diverse racial neighborhood makeup that I don’t believe was able to participate in this
decision process.
Thank you for your attention to this issue.
Sincerely,
Paul Morrissey
The Commonwealth of Massachusetts
House of Representatives
State House, Boston, MA 02133-1054
Denise Provost
Representative
27th Middlesex
District
Committees:
Transportation,
Higher Education,
Personnel and
Administration, &
State House Room 473B
Boston, MA 02133
Tel. (617) 722-2263
September 25, 2012
Kate Fichter
MassDOT, Office of Transportation Planning
Ten Park Plaza, Room 4150
Boston, MA 02116
Jerome Grafe
MassDEP, Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
Re: State Implementation Plan
Dear Ms. Fichter and Mr. Grafe:
Thank you for giving me the opportunity to comment today on the progress being made on the
SIP commitments. While I am dismayed at the prospect of the Red/Blue Line connector being
dropped from the SIP list, the focus of my remarks will be the long-delayed Green Line
Extension (GLX) project, and the choice of appropriate mitigation. I hope to provide a bit of
historical, geographic, and statutory context for thinking about the GLX, and mitigation for its
delay, as legal commitments of the Commonwealth of Massachusetts.
Somerville Air Quality Impacts
During constriction of the “Big Dig,” in its project office near South Station was a model of the
Big Dig infrastructure, superimposed on a regional map. Boston, Cambridge, and other
communities were identified on the map; Somerville’s transportation infrastructure was there
too, but its existence as a place was not acknowledged – an omission that remains emblematic.
Historically, Somerville has served the state as a transportation corridor; for freight, commuter
rail, and motor vehicle traffic. The MBTA is the city’s biggest landowner, with vast rail yards,
and the Boston Engine Terminal (consider the property tax implications of this fact). The
multiple commuter rail lines through the city do not stop. Regional motor vehicle traffic through
the city, on state roads 16, 28, and 38, and on I-93, negatively affects the quality of life, the
quality of air, and hence, public health in Somerville; having so much pavement also creates an
unpleasant heat island effect in summer.
Yet Somerville is in the lowest tier for auto-related annual carbon dioxide emission per
household, in metropolitan Boston (see Urban Land Institute (ULI)’s “The Boston Regional
Challenge” report, page 15). That study notes that “[i]nterestingly, the transportation sector
accounts for 41% of all carbon dioxide (CO2) emissions in Massachusetts, compared to 33%
nationally.” As Somerville Transportation Equity Partnership (STEP) members who are
participating in Tufts Medical School’s CAFEH (Community Assessment of Freeway Exposure
and Health) will have presented evidence to DEP during this hearing process, Somerville suffers
perversely high exposures to tailpipe toxins, and has the negative health outcome data that one
would expect in a community situated in what is perhaps the Boston region’s most heavily
travelled transportation corridor.
Legal Context for SIP Commitments
The “Big Dig” represented massive expansion of roadway capacity for motor vehicles in metro
Boston. Federal funding for the project required commitments for expansion of mass transit,
grounded in the increasing focus on multi-modal transportation that gave rise to the federal
ISTEA transportation funding legislation, and its successors. This evolution of federal
transportation policy away from the primacy of automobile travel, along with the regional air
quality stands of the Clean Air Act, formed the legal context in which the SIP projects were
affirmed as legal commitments.
In the years since the 2006 consent agreement that settled the Conservation Law Foundation
(CLF)’s lawsuit against the Commonwealth for its failure to construct the transit mitigations
associated with the Big Dig, Massachusetts has adopted important legislation that strengthens
these commitments, and that provides a clear framework for choosing delay mitigation projects.
In 2008, Massachusetts passed the Global Warming Solutions Act, which requires that the state’s
greenhouse gas emissions be reduced to 80% of 1990 levels by 2050. As the ULI report notes,
“[o]ne strategy for reducing transportation-related CO2 emissions is to reduce the number and
length of car trips, often measured in vehicle miles traveled (VMT). High-density residential
areas that can support – and are zoned to allow – nearby services, amenities, and employment
have been shown to reduce VMT by 25 to 30%, on average.”
The ULI report’s suggested fast track to reduce transportation-related CO2 emissions describes
Somerville. The most densely-populated cit in New England, its actual density, and potential
capacity, is seen to be even greater when one subtracts the vast rail yards in the east, and the
underdeveloped expanses in the Brickbottom and Boynton Yards areas. Somerville’s zoning
supports not only its high-density housing, but the mix of uses that encourages proximity to
amenities, services, and employment; Somerville’s growth along the expanding railroads during
the 19th century made it the original transit-oriented development.
But regional passenger rail, and, until the opening of the Davis Square Red Line stop in 1984,
Somerville had no MBTA train service. Completion of the GLX, with a completed Community
Path included as delay mitigation, could rectify the longstanding transit service inequity to which
Somerville has been subjected. It will also result in a project that is completely in alignment with
another major piece of post-2006 transportation policy legislation, the Transportation Reform
Act of 2009 (Chapter 25 of the Acts of 2009).
Specifically, Section 33 of that statute establishes a “healthy transportation compact,” which
mandates the cross-silo creation of “a healthy transportation policy.” That policy is one that will
“develop… transportation alternatives that reduce greenhouse gas emissions… and increase
opportunities for physical activities,” including “methods to increase bicycle and pedestrian
travel…” viewed as implementation of the Compact, the GLX and completed Community Path
clearly fulfill and promote its legislative goal.
As the attorney for CLF testified, it would indeed be a great injustice if interim offset measures
for the delay in the GLX were not implemented in the same community as the GLX. Yet it must
be acknowledged that an expedited, complete GLX, and a fully designed and constructed
Community Path will not only benefit the GLX communities. Making Somerville a corridor for
off-road bicycling and walking, as well as for light rail, would be a benefit to the region, and to
the Commonwealth.
Thank you for your consideration of these comments.
Respectfully submitted,
Memo to:
Jerome Grafe
MassDEP, Bureau of Waste Prevention
One Winter Street, 6th Floor
Boston, MA 02108
Kate Fichter
MassDOT Office of Transportation Planning
Room 4150, Ten Park Plaza
Boston, MA 02116
From: Fred Salvucci
Subject: Mitigation for Strategies Appropriate for Delay on Green Line Extension
Date: Sept 25, 2011
I am writing to comment on the Annual Status Report of transit projects in the
State Implementation Plan, and provide my comments on the appropriate actions that should be
required of Mass DOT to mitigate damage to the environment caused by the slippage in timetable
on the SIP commitments. SIP commitments were entered into in 2006 pursuant to an agreement
settling litigation with the Conservation Law Foundation concerning prior slippage on the
commitments of the 1993 SIP. Furthermore, MassDOT is also in violation of the more extensive
commitments entered between MassDOT predecessor agencies with CLF in 1990, and the
conditions attached by the DEP to the ventilation shaft permits of 1991, required for the
construction of the Big Dig.
This Green Line Extension was committed to by 2014 in the 2007 SIP (service should have
commenced to Medford Hillside by 2011, according to the 1993 SIP). In 2011 MassDOT has
announced further slippage to 2018, or even possibly 2020 for the completion of the entire
extension. Because of the heightened attention that the Conservation Law Foundation lawsuit
settlement has brought, and the prior litany of failures to honor their original commitments and the
various Administrative Consent Orders entered into in the late 1990s and early 2000s (which are
themselves mitigation for previous failure and slippage) it is all the more important for the DEP to
hold MassDOT to a very high standard of mitigation for the delayed delivery of air quality and
transit access benefits.
Appropriate mitigation for the Green Line Extension implementation delay
• Accelerated Timeline for Green Line Extension Construction and Gilman Street Station
The first obligation of MassDOT is to mitigate the extent of the schedule slippage, which will
otherwise cause both cost increases because of construction cost inflation, and delay of air quality
benefits, service, economic development, and other benefits to Somerville and the region. The July
2012 Memorandum of Understanding between the City of Somerville and MassDOT, which makes
a commitment to start construction of the first phase of the extension to Union Square and
Washington Street by Spring 2014 and have stations operational by early 2016, is an encouraging
development.
Much of the timeline slippage has been self-inflicted by the Commonwealth. Significant delay was
caused by the MassDOT effort to locate the maintenance facility at an unacceptable location (Yard
8) and by Mass EOEA insisting on an additional environmental process to address the revised
maintenance location. Furthermore, the maintenance facility, while possibly desirable, is not
necessary to complete the extension and commence service, nor is the facility an essential element of
the extension promised in the SIP. It could be added later if necessary, as long as the appropriate
track and switches are put in place to access the area.
Nevertheless, the construction schedule for the GLX, prioritizes the construction of the
maintenance facility in phase 3, leaving the construction of the stations beyond Washington Street to
the final phase.
MassDOT should instead be required to revise its construction schedule and prioritize the
construction GLX stations before the maintenance facility. This should be especially so for the
Gilman Street Station, which contributes disproportionately to the air quality benefits of the project
since it has the highest projected ridership. MassDOT should be required to construct the GLX at
least up to Gilman Street (and ideally all the way to College Ave) in phase 2/2A or phase 3 of the
extension, and defer construction of the maintenance facility until this is achieved.
• Inner Belt Road to North Point Boulevard Bridge and Preliminary Urban Ring Service
It is clear that there are significant features of the Green Line Extension project that have substantial
transit and air quality value, which MassDOT has been proposing to defer, and which should be
implemented as part of early action phase 1 and phase 2/2A construction of the GLX. These
include the bridge connecting Inner Belt Road to North Point Boulevard, essential to facilitate the
Urban Ring connection between Lechmere and Sullivan Square, enable the transit-oriented
economic redevelopment of the Inner Belt area, and establish a critical link of the community path
and bicycle connection from Alewife through Somerville to the Charles River. This critical link
should be built as part of the earliest construction, linking Lechmere to Washington Street and
Union Square that has been promised to be in construction by 2014 and completed by 2017. With
the staged opening of the GLX to Washington Street and Union Square prior to completion of
Medford Hillside, the Urban Ring connection to Sullivan Square can help to mitigate the delay by
improving transit and expediting the transit-oriented development, both of which will contribute air
quality benefits.
MassDOT should be required to construct this bridge as part of its mitigation obligations, and to
model the effectiveness of a CT-4 frequent bus route (3 minutes) as an interim Urban Ring service
that will connect Sullivan Square, “old” Lechmere and Kendall.
• Grand Junction Rail Service
In 2010, the Commonwealth purchased key rail corridors in order to use them to improve public
transportation service, and last year the MassDOT undertook a process to examine the preliminary
feasibility of running commuter rail service on the Grand Junction Railroad from
Framingham/Worcester to North Station. The results of this effort were the initial findings that
Commuter Rail service on the line has the ability to provide additional public transit capacity and
reduce auto trips, and associated benefits to air quality. As mitigation for the delay on the GLX,
MassDOT should be required to further examine the feasibility of rail service on the Grand
Junction. It is recognized that the previous plan faced community opposition in Cambridge due to
concerns regarding emissions from trains and competing interests for using the corridor as a
walk/bike trail. However, it has since been demonstrated that a community trail and rail service
could both be accommodated in the corridor. Further, MassDOT should be required to work with
the CTPS to model an alternate service plan that could be more satisfactory to the community and
more beneficial to air quality and transit ridership: providing urban service using DMUs.
It would be appropriate for MassDOT to purchase or lease Diesel Multiple Units (DMUs) and
initiate frequent 10 minute service, to make the Grand Junction a truly urban quality rail service.
MassDOT should be required to model and test the potential effectiveness of frequent DMU
service (as well as the presumable reduced air pollution that should be feasible with “clean diesel”
DMUs), along with a sensitivity analysis of different service frequencies for discussion with the city
and community groups, and then implement a suitably frequent schedule. If found suitable, DMU
service on the Grand Junction could be implemented in as little as two years by late 2014.
Funding for Required Mitigation
It is important to recognize that SIP and transit commitments were made by the Commonwealth
and MassDOT, not primarily by the MBTA, so that these are financial obligations by the
Commonwealth and all its agencies, including MassDOT, Massport, and Administration and
Finance, and not only the MBTA. Morally, MassDOT and Mass Administration & Finance are
obliged to fund the transit commitments of the Big Dig, which are necessary to achieve the benefits
identified in the 1990 SFEIS and the 1991 vent shaft permits. The troubling fiscal condition of the
MBTA is no excuse for avoiding the responsibility to provide adequate and meaningful mitigation
that involves a substantial and meaningful increase and expansion in public transit service.
The current budget problems at the MBTA have been created by the Commonwealth. The 1964
enabling act that created the MBTA established the understanding that 90% of capital MBTA debt
service would be funded by the Commonwealth to enable the expansion and modernization of the
system. The so-called “forward funding” budget structure initiated in 2000 has crippled the MBTAs
ability to maintain service, expand service and meet its legal commitments for transit expansion,
mitigation and SIP requirements.
Fortunately, there are encouraging signs from MassDOT, the Governor, the Secretary of
Transportation and Beacon Hill for legislation to restructure and alleviate the transportation funding
problem in the Commonwealth. It is essential that DEP take a strong position that any new
transportation funding bill release the MBTA of its unfair debt burden, thereby enabling not only
the reversal of destructive service cutbacks that hurt air quality, economic development and
environmental justice, but also for the MBTA to focus on expanding service and investing in new
capital. Again, it must be underscored that the transit mitigation projects agreed to by MassDOT
and its predecessors are obligations of the Commonwealth, not MBTA, and that “flexing” of
“highway” funds, and “creative finance” options with the support of Administration and Finance
must also be available.
SIP projects are supposed to be prioritized over other transportation projects in the TIP and longrange transportation plan. Continued failure to implement is not a legitimate option. DEP should
require that any funding bill include a mechanism to ensure that the Commonwealth’s delivers on its
responsibility to implement the commitments in the SIP and CLF agreement, with a particular
emphasis on the Green Line Extension, the design and construction of the Red-Blue connector as a
priority, Urban Ring bus service, and the missing link of the Sliver Line.
Of the many valuable transit improvement projects which are being left in varying states of disarray
by MassDOT, the Blue-Red is the one project whose implementation is achievable in a relatively
shorter time frame which addresses a critical failure point in the current Boston transit system:
namely, the lack of capacity in our core transit system which depends on the convergence of our
major radial transit lines in the Boston regional core (Red, Green, and Orange as well as Blue Lines).
It is also important to remember that the predecessor to MassDOT committed to having the BlueRed connector in operation by the year 2000 in the 1991 DEP ventilation shafts permit. It is
encouraging to see the recent support to keep the completion of engineering design for the RedBlue connector in the SIP. However, the appropriate mitigation action is to achieve actual service on
the Blue-Red connection at the earliest achievable date, by conducting a value engineering review of
the current state of design, preparing design-build procurement documents, and including the BlueRed connector construction in the Green Line extension project, in order to achieve economy of
scale and timely implementation at a reasonable price.
Methodology for Evaluating the Effectiveness of Possible Mitigation Strategies
Typically, MassDOT has used a methodology to predict regional air quality impacts based on vehicle
miles of travel by autos (VMT). But the methodology is inadequate for evaluating the damage of
schedule slippage, particularly for the Green Line extension and the Blue-Red connector.
First, the entire basis of the air quality calculations for the Big Dig was not VMT, but VHT (vehicle
hours traveled by auto). VHT is a better indicator of air quality impact, but requires the ability to
measure and predict congestion effects of growth in auto use. Because the CTPS methodology
predicts traffic volumes which exceed the capacity of key highway facilities, the predictions of the
methodology do not properly reflect the fundamentally congested nature of key parts of the highway
system. Congestion causes more delay, more VHT, and more air pollution. Therefore, the
methodology is inadequate as a tool to model air quality for the purpose of enforcing the SIP or for
evaluating conformity. The core of the transit system is similarly predicted to carry significantly
more passengers than is possible, underscoring the inadequacy of this methodology. Because of this
fundamental flaw in methodology the entire SIP revision proposal should be rejected by DEP. It
should be sent back to MassDOT for appropriate modification of the methodology, and
reconsideration of the entire proposal based on the revised results.
Secondly, the most significant drivers of VHT are land use, trip distribution, and mode share. Delay
in implementing the Blue-Red connector and the Green Line extension affect not only the transit
and auto mode share of a fixed set of trips, they affect the distribution of activity and trips being
made, as well as land use. For these reasons the methodology used to estimate the damage done to
air quality by schedule slippage on transit improvements needs to be based upon a more
fundamental review comparing the land use and trip distribution and VHT projected in the 1990 Big
Dig FEIS, and the originally assumed transit improvements in the 1990 model, in comparison with
what has actually occurred, to measure whether the improvement in air quality predicted for the year
2010 actually occurred or not, the differential air quality impacts as a result of differences identified,
and the likely effectiveness of various mitigation strategies.
It is highly likely that using appropriate methodology which identifies the projected state of VHT in
the year 2010 according to the Big Dig versus what has actually transpired, the mitigation options
suggested in section 1 would be useful but not sufficient to fully mitigate the excessive VHT being
generated by the actual measured land use, trip distribution, and VHT, and that additional transit
improvement is required to address the adverse impact of late delivery of transit improvements
assumed in the base documents of the 1990 FEIS, the 1991 vent shaft DEP permits, and the 1993
SIP. It would be useful and appropriate to consider the various measures proposed in these original
documents, as well as in the various Administrative Consent Orders, such as the Urban Ring and the
missing link of the Silver Line, to identify suitable additional mitigation measures to not only achieve
the state of performance of the transportation system initially projected to result from the Big Dig,
and the resultant state of air quality, but to deal with the new challenges to improve both economic
and environmental performance for the next century.
Sincerely,
Fred Salvucci
Friends of the Community Path
112 Belmont Street
Somerville, MA 02143
617.776.7769
friendspath@yahoo.com
www.pathfriends.org/scp/
September 25, 2012
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, 6th Floor
Boston, MA 02108
Dear Ms. Fichter and Mr. Grafe,
Re: Annual SIP Update and Status Report for Transit Projects
Thank you for the opportunity to comment on the Update and Status Report for Transit Projects
As required by 310 CMR 7.36 (2) (f) through (j) that was submitted by the Massachusetts
Department of Transportation (MassDOT) to Mass DEP on July 2, 2012.
The Friends of the Community Path is a regional group with over 1200 members. Our mission is
to extend the Community Path 2 miles to Cambridge to thereby link the 23-mile Minuteman
Bikeway network to the 23-mile Charles River path network, along the coming Green Line
Extension (GLX) route, thereby connecting 11 Boston MPO cities and towns.
Our Request: To include, as an Interim Offset Project in the Green Line Extension corridor,
final design and construction of the extension of the entire Somerville Community Path (CPX)
prior to or together with (as appropriate for the construction schedules) the Green Line Extension
construction contract. In particular, this should include both the design and construction (neither
which MassDOT has agreed to) of the “missing link” CPX from Inner Belt to North Point, where
development construction is under way and increasing rapidly. Because of the time frame of the
Phase I GLX work in this area, now is the time to integrate the CPX into the GLX. The CPX will
deliver air quality benefits both with the GLX (be bringing riders cost-effectively to the new
GKX stations) and independently as an active transportation corridor from the northwest to
Cambridge, Boston and the Charles River paths. The CPX is one the projects listed and
evaluated as an Interim Offset Project and it received high points for many reasons.
page 1 of 2
We also wish to thank the DEP for continuing to require that the SIP includes the GLX and to
thank previous Environmental Affairs secretaries for requiring in environmental impact reports
that the GLX not preclude the CPX from being extended.
They’ve done this realizing that the CPX is a connective regional bike/pedestrian project that
meets the State’s GreenDOT, Healthy Transportation Compact, and Mode Shift goals; meets SIP
requirements; meets Federal Healthy and Sustainable Transportation goals; and is already
included on state, regional, and local planning efforts.
We are delighted that MassDOT and the MBTA has agreed to build the shared infrastructure of
the GLX and CPX and the Path itself for several hundred feet for station accessibility and
emergency egress. However, the CPX must really be constructed together with the GLX to
minimize its construction cost. This can be accomplished by making the CPX an integral part of
the GLX project and/or as an Interim Offset Project for the GLX delays. Please use your
authority to make this happen.
Sincerely,
Lynn Weissman
Alan Moore
Co-Presidents, Friends of the Community Path
cc:
Mayor Joseph Curtatone, City of Somerville
Hayes Morrison, City of Somerville
Richard Davey, Secretary, MassDOT
Somerville Transportation Equity Partnership
page 2 of 2
To:
Jerome Grafe
Kate Fichter
MassDEP, Bureau of Waste Prevention
MassDOT Office of Transportation Planning
One Winter Street, 6th Floor
Room 4150, Ten Park Plaza
Boston, MA 02108
Boston, MA 02116
Date: Sept 25, 2011
RE: Mitigation for Strategies Appropriate for Delay on Green Line Extension
This memo contains comments on the Annual Status Report of the transit projects in the
State Implementation Plan, focusing on the appropriate actions that should be required of MassDOT
to mitigate the damage to the ecological, social, and economic environments resulting from slippage in
the timetable on the SIP commitment for the Green Line Extension.
Requirement for Mitigation
Air Quality
The Green Line Extension (GLX) is the most significant air quality mitigation measure remaining from
the Central Artery/Third Harbor Tunnel Project. Constructing the GLX is a key component of the
Clean Air Act State Implementation Plan (SIP), and therefore, the Commonwealth is legally required by
Federal law to build the GLX to Union Square and Medford Hillside and have service operational by
2014. The recent July 26, 2012 Memorandum of Understanding signed between the City of Somerville
and MassDOT/MBTA has made a commitment only to begin construction of the first phase of the
extension by Spring 2014, and have two operational stations (Union Square and Washington St) by late
2016 or early 2017. Further, it is important to recognize that according to the 1993 SIP service on the
GLX to Medford Hillside should have commenced by 2011. This commitment was renegotiated due to
the failure of the Commonwealth to make adequate progress toward meeting the promised timeline.
Simply put there has been and continues to be a significant delay in the implementation timeline of the
GLX commitment in the SIP, and likewise the failure to deliver anticipated air quality benefits from the
project to the people of the Commonwealth. This delay triggers the need to provide interim emission
reduction offset measures for the entire period of the delay.
Environmental Justice
Equally important as the air quality benefits, the GLX addresses longstanding transportation access and
equity issues in the City of Somerville. The proposed GLX right of way occupies the corridor of the
former Boston and Lowell Railroad, and the GLX stops at Gilman Square, Lowell St, Ball Square, and
College Avenue replace historic service at the Prospect Hill, Winter Hill, Somerville Junction and North
Somerville stations.
Furthermore, when plans for Interstate highways and the Inner Belt (I-695) were stopped in the 1970s
through Jamaica Plain and Roxbury and replaced with the MBTA Orange Line relocation, in Somerville
I-93 was built as an elevated structure and no transit alternatives were provided. Somerville, the most
densely populated city in the Commonwealth, still remains significantly underserviced by the MBTA
rapid transit network. The regional transit connectivity promised by the GLX is key for enabling access
to economic opportunities for Somerville residents, and also for catalyzing economic development and
the growth of jobs within the City.
The history of continual delay on the project, the significant air quality benefits of the GLX, and the
economic development and environmental justice aspects of the Extension, make it imperative for
DEP to hold the MassDOT and the MBTA to a very high standard of mitigation for slippage on the
SIP timeline.
Appropriate Mitigation Actions
The Green Line Extension project is anticipated to deliver major air quality and transit access benefits,
and according to the 2011 Federal Environmental Assessment of the project the GLX accounts for
more than 80% of all emissions benefits in the 2009 SIP package of projects. It is not likely that any set
of mitigation actions will manage to achieve this level of benefit for air quality and transit access.
Therefore, it is all the more important that any set of mitigation measures be focused on actions that
provide a substantial and meaningful increase to public transit access within Somerville and the same
neighborhoods that would benefit from the GLX.
However, the Green Line Extension SIP Mitigation Inventory released from CTPS and MassDOT on
January 23, 2012 is a disappointing document, since the most relevant and appropriate mitigation
measures seem to be prematurely scoped-out due to a lack of support from MBTA and/or MassDOT.
The MBTA position of limiting peak-period service expansion severely handicaps the potential to
provide meaningful mitigation for the GLX delay, however, this limitation can be overcome through
the use of contracted services such as the EZRide shuttle equipped with MBTA fare boxes.
MassDOT, the Governor, and the Secretary of Transportation have made it clear to the public that new
legislation to address the structural financial challenges facing transportation in the Commonwealth is
imminent. It is essential that DEP ensures the required resources to satisfy all legally required SIP
commitments and mitigation actions are included in any new transportation funding bill.
Local Area Context
Due to the schedule and scope of planned MassDOT construction projects over the next several years,
there will likely be severe disruptions to the transportation system in Somerville. Mitigation actions for
the GLX delay should be considered in this context, and should help offset these disruptions related to
the construction of the Green Line Extension itself as well as other major roadway projects in the
surrounding area.Of particular concern is the relationship between GLX construction and work on the
Route 28/McGrath Highway corridor.
• Reconstruction of the Washington Street Bridge to accommodate the Green Line tracks will
significantly limit access along one of the only corridors linking east and west Somerville across
McGrath Highway. The EA/EIS for the GLX has noted this requires mitigation.
• Rehabilitation of the Medford Street Bridge to enable the Union Square branch of the GLX has been
committed as an early action item but will reduce capacity on this link that is used (as a neighborhood
cut-through) for traffic headed to Kendall.
• Reconstruction of the Gilman St Bridge and Cross Street Bridge as part of the Accelerated Bridge
Program will substantially reduce the capacity of the McGrath corridor to connect origins in north
Somerville to destinations in Lechmere and Kendall and Boston – a travel pattern that would be well
served by the Green Line Extension.
This context further heightens the critical need for meaningful public transit service as appropriate
mitigation action for the GLX implementation delay.
Recommended Actions
1) Sullivan Square to Kendall Square Circumferential Bus Service via Brickbottom to Inner-Belt Embankment
Connection
MassDOT should be required to model and test the effectiveness of frequent bus service (4-5 minute
frequency) on a new “CT4” route connecting Kendall Square, Lechmere Square, Sullivan Square and
Assembly Square. This precursor service to the Urban Ring would provide meaningful transit access to
Somerville and an important connection to the employment center in Kendall. This service could be
feasibly implemented prior to 2014 using contracted bus operations. Initially, this service can run from
Kendall to Lechmere via priority bus lanes on First Street that have been committed to by the City of
Cambridge, and then to Sullivan Square via McGrath Highway. In order for this service not to be
trapped in traffic related to construction at the Washington/McGrath intersection and under the
Washington Street GLX Bridge, the mitigation action should include a roadway connection (at or near
Poplar Street) underneath the future GLX viaduct/Lowell Line MBTA tracks to connect the
Brickbottom and Inner-Belt neighborhoods. This will enable busses to reach Washington Street east of
the GLX construction disruption.
2) North Point Boulevard to Inner-Belt Road Bridge for CT4, future Urban Ring and Community Path
MassDOT should be required to construct this bridge as part of its mitigation obligations. Although it
has been noted that the bridge may not be ready by Jan 1, 2015 (the first day mitigation will be
required), the bridge could be completed by 2016 and constructed as part of the first phase of the GLX
which has been committed to by the Commonwealth. Therefore, the bridge would provide mitigation
value for several years until the entire GLX is completed by 2020 on the current anticipated schedule.
The bridge, which risks being physically precluded if not designed in tandem with the GLX, is essential
for enabling an Urban Ring connection between Lechmere and Sullivan Square, for the critical link of
the Community Path extension from Somerville to the Charles River, and for supporting the transitoriented economic development of Inner-Belt and North Point. All of these outcomes contribute air
quality and local transit access benefits that are appropriate mitigation measures for the delayed and
staged opening of the GLX. The bridge will also be necessary mitigation for the grounding of McGrath
Highway and demolition of the McCarthy Viaduct (discussed below).
3) McGrath Highway and Grounding McCarthy Viaduct
As mentioned above, the GLX and McGrath Highway corridor should be considered together.
MassDOT has made it a matter of policy that the McCarthy Viaduct is an obsolete structure, and has
expressed to the public that it is committed to removing the elevated structure and reconceptualizing
the McGrath Corridor as an at-grade boulevard. In 2003 the Boston MPO concluded that bicycle travel
along the McGrath corridor “is not safe” and that pedestrian crossings under the structure are difficult
and lead to circuitous route choices.
These physical conditions have an adverse impact on the desirability of walking and bicycling to access
the future Washington Street GLX station. This is particularly troubling since over 90% of the
projected ridership to the station will be arriving by walk and bike. The proposed phased opening of
the GLX with Washington Street as the line terminus, will also increase the catchment area of people
trying to reach the station by walk and bike. The presence of the McCarthy Viaduct and the
substandard conditions at grade undermine the ridership of the Green Line Extension. Worse yet,
MassDOT is proposing a timeline to remove the McCarthy Viaduct and reconfigure McGrath as an atgrade boulevard only after the GLX station at Washington Street is completed. These construction
activities, which will last for years, will significantly disrupt or even cut off access to the Washington St
station. Therefore, the existing conditions of McGrath and the future plans for the corridor threaten to
set back attaining the transit access and air quality benefits of the project which are already being
substantially delayed. In order to avoid these consequences, MassDOT should be required to do the
following:
• As immediate mitigation for the construction disruption related to the rehabilitation of the Medford
Street Bridge, MassDOT should be required to close and demolish the Southbound off ramp from the
McCarthy Viaduct at Somerville Ave. Doing so will have the dual benefit of reducing the number of
vehicles entering the area of reduced capacity surrounding the construction, and also be an early action
in the direction of removing the Viaduct.
• MassDOT should be required to redesign the Washington St/McGrath intersection to improve and
signalize pedestrian crossings. This action is specified as required mitigation in the EA, however, it
should be completed as an early action now to improve access to and usage of existing transit options
in the area (MBTA bus lines, CT2, 86, 88, 91).
• MassDOT should be required to redesign the Somerville Ave /McGrath intersection to improve and
signalize pedestrian crossings, and to provide a vehicular connection from Somerville Ave to Polar
Street to enable better access to Brickbottom and alternative paths to the Washington St / McGrath
intersection connecting east and west Somerville. This action is consistent with the goal to ground the
McCarthy Viaduct, and should be completed as an early action now to improve access to and usage of
existing transit options in the area (MBTA bus lines 80, 87). Currently, access to these bus lines at
Poplar St / McGrath Highway requires crossing six lanes of high-speed highway traffic with no
pedestrian signal.
• MassDOT should be required to develop a construction, implementation and funding plan for the
grounding of the McCarthy Viaduct. This plan should be timed to coincide with the Gilman Street
Bridge reconstruction in 2015 which will inevitably reduce the throughput capacity of McGrath
Highway by as much as 50%. At this time, the capacity provided by the McCarthy Viaduct will be
redundant, and MassDOT should be required to reconfigure the existing surface/frontage roads of
McGrath Highway to accommodate the reduced traffic load in the corridor. Preliminary analysis of this
configuration has demonstrated its feasibility. With the frontage road system in place and all traffic
operating at-grade, MassDOT should be required to demolish the McCarthy Viaduct structure before
the 2017 opening date of the Washington Street Station. These actions will greatly enhance the viability
and safety of pedestrian and bicycle access to the Washington Street Station, as well as the potential for
transit oriented economic development – all of which contribute to improving air quality. Also, this
sequence of actions is not inconsistent with, and does not preclude a more comprehensive corridor
design process to reconfigure the McGrath Highway as a multi-modal boulevard.
4) Green Line Service to Lechmere at 3 Minute Headway
The commitment in the GLX project is to run the two branches of the extension with a 3 minute
combined headway to Lechmere station. MassDOT should be required to implement this service
improvement to the existing Lechmere station on an immediate timeline as a mitigation measure.
5) Green Line Extension Service to Gilman Street Station
The Gilman Street Station on the GLX has the highest forecast ridership, and therefore, contributes a
significant share of the air quality benefits of the project. The current construction phasing of the GLX
does not include an operational Gilman Street Station until phase 4, but prioritizes the construction of a
maintenance facility in phase 3. The maintenance facility, although desirable for the MBTA, it is not a
key element of the GLX commitment promised in the SIP nor necessary to commence service up to
Gilman Street. Therefore, MassDOT should prioritize the construction of the GLX to Gilman Street in
phase 2/2A or phase 3 of the extension, and defer construction of the maintenance facility until the
rest of the extension is completed.
Sincerely,
Vig Krishnamurthy
20 Glenwood Ave, #2
Cambridge, MA, 02139
Ellin Reisner
51 Mt. Vernon St.
Somerville, MA, 02145
Jim McGinnis
jim02143@gmail.com
Karen Molloy
kmolloy@gmail.com
SIP Transit Project Comments submitted to DEP by Ellin Reisner, resident of Somerville and
member of the Somerville Transportation Equity Partnership on September 18, 2012.
I first want to acknowledge the important milestone that was reached last week when the
MassDOT/MBTA Board of Directors voted funding of $45 million to move the Green Line extension
(GLX) project forward with the new contractors AECOM and HNTB working on detailed design and
engineerir:'g including the lechmere, Union Square and Washington Street stations. It is great to
that the project is moving forward and I appreciate the work completed by the MBTA staff and
HDR led design team. Also, although I have not been involved in the Fairmount Line, it is also
good to see this project moving toward completion.
It is important to yet again make clear that the Commonwealth must move forward in
implementing the SIP interim replacement projects to meet the air pollution reduction benefits
that the GLX will offset because of the continuing delays in opening the GLX. Initially the GLX was
to open in 2011, and then it was delayed to 2014. Now, we are faced with the opening of service
to Washington St. and Union Square by 2016, with service to College Avenue delayed to 2019. As
the delays mount, the importance of mitigation increases.
Over the past year many people have commented on recommended interim offset projects. Now
is the time to commit to and prepare Interim replacement projects that will provide the required
mitigation between 2014 and the expected opening of the GLX to College Ave. in 2019 and to
Route 16 in a separate project phase. My recommendations address several goals that reduce
mobile pollution and meet sustainability goals.
First, I strongly recommend that Mass DEP direct MassDOT to complete the design and
construction of the Community Path from Inner Belt to North Point in order to complete the
regional bike and community path network from Bedford to downtown Boston that links to the
Charles River paths. This critical section of the path serves an environmental justice neighborhood
that lacks safe bicycle and pedestrian connections both within Somerville and to Boston. The Path
meets sustainable transportation principles of the US DOT I EPA/ HUD partnership the MassDOT's
GreenDOT go-als. As an advocate for sustainable transportation that serves all modes it is
troubling and frustrating to continually face the Commonwealth's inconsistency in meeting its
own sustainability commitments. This project needs to be made shovel ready as soon as possible.
Secondly, there is an opportunity to increase transit use during the interim years, by constructing
new bridge and roadway connections within Brickbottom/lnner Belt and North Point. A new bus
route connecting Sullivan Station to Lechmere and Kendall Station would prove an attractive
transit alternative that could remove many vehicles from the corridor and provide an economic
stimulus to the region. This route could be started up prior to completion of the bridge and road
work in lnnerbelt/Brickbottom, but would eventually be routed through lnnerbelt/Brickbottom.
Ultimately transportation planning in the region should demonstrate a long term vision for
addressing transit needs with a light rail line in the Grand Junction that would connect all of the
transit lines and highways from Wellington and 193N to MIT/Kendall Square and the Longwood
Medical Area.
I also urge moving forward with planning and design of the Route 16 GLX station to meet the long
term connectivity (including linking bicycle and pedestrian access, economic development and
mobile pollution reductions in the corridor.
I also think that it is a mistake to eliminate the Red/Blue connector as a SIP commitment. The
decision to only develop a design when the SIP commitments were revised was a mistake. While I
know that funding is an inescapable issue, the connector would enable more people to use public
transit to get to jobs and school, reducing auto trips. It would also relieve overcrowding in the
Central subway. Elimination of this project is short sighted, but it needs to not just be a design
project, it needs support for construction.
Lastly, because of Somerville's excessive exposure to diesel pollution from commuter rail,
maintenance of commuter rail at the Boston engine terminal and high volumes ofhighway traffic, I
strongly recommend that the MBTA diesel reduces its use of diesel in the entire MBTA system
and in particular within the Northwest corridor.
Ellin Reisner
51 Mt. Vernon St.
Somerville, MA 02145
,.
Wig Zamore
13 Highland Ave #3
Somerville MA 02143
Logan Health Study CAC (DPH)
Logan Airport CAC (Noise Study)
MBTA Rider Oversight Committee
MAPC MetroFuture Steering Com. (to 2008)
Somerville Transportation Equity Partnership
Mystic View Task Force (of Somerville)
617-625-5630
wigzamore@gmail. com
August 31 , 2012
The Honorable Lisa P. Jackson, Administrator
U.S. Environmental Protection Agency 1200 Pennsylvania Avenue. N. W. Washington, D. C. 20460 Via Email: jackson.lisap@epa.gov
Via Email: a-and-r-Docket@epa.gov
Re: EPA Proposed PM Rule June 2012 Docket tfo. EPA-HQ-OAR-2007-0492 Dear Administrator Jackson,
Of the six criteria pollutants, Carbon Monoxide was significantly reduced via the catalytic converter after
removal of Lead from gasoline, as were Nitrogen Oxides and VOC precursors to Ozone. Sulfur Dioxide
has seen significant reduction via stationary source controls and use of lower sulfur coal and diesel.
Nevertheless, Particulate Matter (PM) and Ozone remain significant pollutants in the air of many regions.
In fact, during recent EPA criteria pollutant reviews, both PM and Ozone are now associated with greater
health effects, including pre-mature mortality, than at any prior time since the creation of the EPA and
the Clean Air Act Amendments of 1970. This is largely due to the recent recognition of an Ozone
mortality concentration response curve, better exposure assessment for PM health studies and
abandonment of the concept of a safe threshold for manmade PM, including PM2.5. As environmental
health research has improved, the burdens associated with Ozone and PM, especially those attached to
pre-mature mortality thro~h Value of Statistical Life analyses, have increased dramatically even though
the air has gradually been getting cleaner in many parts of the US.
When EPA fails to set standards every five years which fully incorporate the latest science, and provide
protection to susceptible populations with an adequate margin of safety, the older NAAQS standards fall
into attainment through default. This is happening in many areas of the US right now as 1997 Ozone and
PM2.5 standards come to meet regional attainment, with the result that abandonment looms for decades
of Transportation Control Measures and other parts of State Implementation Plans, even in the face of
the scientifically acknowledged increase in recognized health impacts. This is true· for eastern and
western Massachusetts. With up to date Ozone and PM standards we would be working furiously on new
SIP TCMs. Without them, decades of good work by MA DEP and US EPA may simply go down the drain.
I
'
With regard to PM2.5, I would urge you to take the bold step of setting the annual standard at 10
micrograms per cubic meter and the daily at 25. The Lepeule 2012 EHP update to the Harvard Six Cities
study found a linear dose response curve down to 8 micrograms and the Crouse 2012 EHP national
Canadian PM2.5 analysis found reliable dose response curves, similar to those in the American cohort
studies for all cause mortality and for ischemic heart disease mortality, at even lower PM2.5 levels. If
you are unable to set the annual standard at 10, please seriously consider a standard of 11. PM2.5 has a
robust association with pre-mature mortality differences between metropolitan regions of the US.
With regard to within region air pollution gradients, PM2.5 is not robust. This was first shown by the
California Children's Health study as it evolved from a concentration on Ozone and PM2.5 to a
concentration on N02 and proximity to large traffic sources. The California Children's Health Study has
shown that childhood asthma and lung function are related to mobile pollution, highway and busy local
arterial proximities of residences and schools. Similarly, all cause, lung cancer, heart attack, ischemic
heart disease and cardiovascular mortality have been shown to be closely related to exposure to traffic in •
Germany, Sweden, Norway, Toronto and Vancouver. The Vancouver studies of Gan and Brauer are
especially telling as their within city multi-pollutant analyses of PM2.5, N02 and Black Carbon (BC) found
significant associations of BC with cardiovascular mortality, nearly significant associations for N02
(another marker for traffic pollution) and no significance at all for PM2.5. In a separate analyses of near
highway Vancouver residents, those who lived within 50 meters of a major highway had nearly an order
of magnitude higher relative risk of cardiovascular mortality (1.6) than for the interquartile range for BC
(1.06 ). Near highway residential exposures are associated with relative mortality risks similar to those of
long term truck drivers and diesel rail engineers. Additionally, Black Carbon has recently been
determined by the International Agency for Research on Cancer to be a Class I carcinogen for lung
cancer.
As ultrafine particles (equal to or less than 100 nanometers in diameter) contain much larger
concentrations of black carbon and air toxics, such as phenanthrene and other PAHs, than do fine or
coarse particles, it would be prudent for EPA to declare new standards for ultrafine particles. I would
suggest an annual standard of 15,000 UFP per cubic centimeter (lower cut point 5 nanometers) and an
hourly standard of 100,000. Until near roadway exposures and health effects are taken seriously by EPA
in its standard settings, it will not be possible to incorporate the science of within city exposures into
healthy community design and sustainable regional development. Until that happens, "smart growth"
will remain pretty dumb. Housing, schools and active playgrounds will continue to be placed in risky
locations; bike paths will continue to be built in the middle of or alongside arterial highways
notwithstanding that bicyclists' effective dose is 5 or 6 times as high as vehicular or transit passengers
due to increased ventilation; and healthy clean transit/walk/bike facilities will not take precedence over
diesel rail, continued highway building and excess fossil fuel consumption.
We really need EPA to act responsibly rather than politically in its NMQS PM standard setting. Please
come through for us! There is a huge amount of health and quality of life dependent on your actions.
With Great Respect and Thanks,
Wig Zamore
The following articles were appended to this comment. For copies of the articles, please contact Wig
Zamore at wigzamore@gmail.com.
Luz T. Padro-Martinez, Allison P. Patton, Jeffrey P. Trull, Wig Zamore, Doug Brugge, John L. Durant,
“Mobile monitoring of particle number concentration and other traffic-related air pollutants in a nearhighway neighborhood over the course of a year, ” Atmospheric Environment 61 (2012): 253-264.
Michael Jerrett, Richard T. Burnett, C. Arden Pope III, Kazuhiko Ito, George Thurston, Daniel Krewski,
Yuanli Shi, Eugenia Calle, Michael Thun, “Long Term Ozone Exposure and Mortality,” The New England
Journal of Medicine 360 (2009): 1085-1095.
Jonathan M. Samet, “Clean Air Scientific Advisory Committee Response to Charge Questions on the
Reconsideration of the 2008 Ozone National Ambient Air Quality Standards,” letter to Lisa P. Jackson,
Administrator, U.S. Environmental Protection Agency, March 30, 2011.
Maggie L. Grabow, Scott N. Spak, Tracey Holloway, Brian Stone Jr., Adam C. Mednick, Jonathan A. Patz,
“Air Quality and Exercise Related Health Benefits from Reduced Car Travel in the Midwestern United
States,” Environmental Health Perspectives 120-1 (2012): 68-76.
Luc Int Panis, Bas De Gus, Gregory Vandenbulcke, Hanny Willems, Bart Degraeuwe, Nico Bluex, Vinit
Mishra, Isabelle Thomas, Romain Meeusen, “Exposure to particulate matter in traffic: A comparison of
cyclists and car passengers,” Atmospheric Environment 44 (2010): 2263-2270.
Wen Qi Gan, Lillian Tamburic, Hugh W. Davies, Paul A. Demers, Mieke Koehoorn, Michael Brauer,
“Changes in residential proximity to road traffic and the risk of death from coronary heart disease,”
Epidemiology 12-5 (2010): 1-8.
Wen Qi Gan, Mieke Koehoorn, Hugh W. Davies, Paul A. Demers, Lillian Tamburic, Michael Brauer, “Longterm exposure to traffic-related air pollution and the risk of coronary hearth disease hospitalization and
mortality,” Environmental Health Perspectives 119-4 (2011): 501-507.
Tim S. Nawrot, Laura Perez, Nino Kunzli, Elke Munters, Benoit Nemery, “Public health importance of
triggers of myocardial infarction: a comparative risk assessment,” www.thelancet.com February 24,
2011, DOI: 10.1016/S0140-6736(10)62296-9.
Nicholas L. Mills, Hakan Tornqvist, Manuel C. Gonzalez, Elen Vink, Simon D. Robinson, Stefan Soderberg,
Nicholas A. Boon, Ken Donaldson, Thomas Sandstrom, Anders Blomberg, David Newby, “Ischemic and
thrombotic effects of dilute diesel-exhaust inhalation in men with coronary heart disease,” The New
England Journal of Medicine 357-11 (2007): 1075-1082.
International Agency for Research on Cancer, “Diesel Engine Exhaust Carcinogenic,” Press Release, June
12, 2012.
Donald G. McNeil Jr., “WHO Declares Diesel Fumes Cause Lung Cancer,” New York Times, June 12, 2012.
International Agency for Research on Cancer Monograph Working Group, “Carcinogenicity of dieselengine and gasoline engine exhausts and some nitroarenes,” www.thelancet.com June 15, 2012, DOI:
10.1016/S1470-2045(12)70280-2.
Dan L. Crouse, Paul A. Peters, Aaron van Donkelaar, Mark S. Goldberg, Paul J. Villeneuve, Orly Brion,
Saeeda Khan, Dominic Odwa Atari, Michael Jerrett, C. Arden Pope III, Michael Brauer, Jeffrery R. Brook,
Randall V. Martin, David Stieb, Richard Burnett, “Risk of nonaccidental and cardiovascular mortality in
relation to long-term exposure to low concentrations of fine particulate matter: A Canadian nationallevel cohort study,” Environmental Health Perspectives 120-5 (2012): 708-704.
Johanna Lepeule, Francine Laden, Douglas Dockery, Joel Schwartz, “Chronic exposure to fine particles
and mortality: an extended follow-up on the Harvard six cities study from 1974-2009,” Environmental
Health Perspectives 120-7 (2012): 965-970.