Massachusetts Department of Transportation Massachusetts Bay Transportation Authority
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Massachusetts Department of Transportation Massachusetts Bay Transportation Authority State Implementation Plan – Transit Commitments 2011 Status Report Agency Responses to Public Comments Submitted to the Massachusetts Department of Environmental Protection January 11, 2012 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 (617) 973-7313 January 11, 2012 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 27, 2011). 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 13, 2011. 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 (617) 973‐7844 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 3170, Boston, MA 02116 Tel: 617-973-7000, TDD: 617-973-7306 www.mass.gov/massdot State Implementation Plan – Transit Commitments 2011 Annual Status Report Agency Responses to Public Comments I. MassDOT Certification II. List of Public Comments Received III. Agency Responses to Public Comments IV. 2011 Annual Status Report V. Public Comments (available on included CD) a. Emails b. Letters c. Oral Testimony d. MassPIRG Petition e. Friends of the Community Path Petition Leading the Nation in Transportation Excellence Ten Park Plaza, Suite 3170, Boston, MA 02116 Tel: 617-973-7000, 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 11, 2012 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 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 8/17/2011 Title Doreen Charbonneau 8/24/2011 Jeffrey Swan 8/31/2011 Doug Carr 9/3/2011 Transportation Chair John Kyper 9/5/2011 Miranda Banks 9/5/2011 Sylvia Romm 9/5/2011 Jimmie Ye 9/5/2011 Rachel Gordon 9/5/2011 Erica Schwarz 9/5/2011 Joel Weber II 9/6/2011 Arun Sannuti 9/6/2011 Chris Austill 9/6/2011 Jennifer Dorsen 9/6/2011 Yolanta Kovalko 9/6/2011 Matthias Siebler 9/6/2011 Michael Monroe 9/6/2011 Patricia Wild 9/7/2011 Jennifer Lawrence 9/7/2011 Michelle Apigian 9/7/2011 Jonathan Buck 9/7/2011 Gladys Maged 9/7/2011 Don MacKenzie 9/8/2011 Dianne Haas 9/8/2011 Emily Arkin 9/8/2011 Alex Feldman 9/8/2011 Dorie Clark 9/8/2011 Micah Silver 9/8/2011 David Marcus 9/9/2011 Kate Legodar 9/9/2011 Ken Krause 9/9/2011 Larry Rosenberg 9/9/2011 Satori Bailey 9/9/2011 Victoria Thompson Affiliation Additional Authors Sierra Club Ami Feldman Page 1 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 9/9/2011 Title Jill Clarke 9/9/2011 Marcus Rozbitsky 9/9/2011 Gloria Korsman 9/9/2011 Steven Morr-Wineman 9/9/2011 Cynthia Snow 9/9/2011 Joanna Herlihy 9/9/2011 Dorothy Fennell 9/9/2011 Property Manager Robert Martel Affiliation Additional Authors Brickbottom Condominium Trust Joseph Curtatone, Mayor of Somerville; Sal 9/9/2011 Representative Michael Capuano United States Congress DiDomenico, State Senator; Timothy Toomey, State Representative 9/9/2011 Tai Dinnan 9/9/2011 Jamie Glass 9/9/2011 Alex Epstein 9/10/2011 Glen Fant 9/10/2011 Steve Mulder Anne-Marie Wayne 9/10/2011 President Nina Garfinkle 9/10/2011 Maggie Villiger Liveable Streets Alliance 9/10/2011 Jane Parkin Kullmann 9/10/2011 Bob Nesson 9/10/2011 Diane Andronica 9/10/2011 Susan Moynihan 9/11/2011 Ellen Shea 9/11/2011 Tanya Paglia 9/11/2011 Daniel Brockman 9/11/2011 Maureen Barillaro 9/11/2011 Joe Beckmann 9/11/2011 David Dahlbacka 9/11/2011 Andy Pyman 9/11/2011 Janine Fay 9/11/2011 Sara Rostampour Page 2 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date Title First Name Last Name Affiliation Medford Green Line Neighborhood 9/11/2011 Alliance 9/11/2011 Jill Richard 9/11/2011 Ethan Contini-Field 9/12/2011 Todd Kaplan 9/12/2011 Henry Lieberman 9/12/2011 Alice Grossman 9/12/2011 John Wilde 9/12/2011 Alp Sipahigil 9/12/2011 Zehra Cemile Marsan 9/12/2011 Naomi Slagowski 9/12/2011 Stacy Colella 9/12/2011 President Barbara Broussard 9/12/2011 David Phillips 9/12/2011 Rachael Stark 9/12/2011 Lynn Laur 9/12/2011 Susann Wilkinson 9/12/2011 Richard Blewett 9/12/2011 Dennis Dunn 9/12/2011 Lois Grossman 9/12/2011 Luke McDermott 9/12/2011 William Messenger 9/12/2011 Jeff Reese 9/12/2011 Rachelle Magill 9/12/2011 Eric Becker 9/12/2011 Pauline Lim 9/12/2011 Mark Chase 9/12/2011 Catherine Valentine 9/12/2011 David Scott 9/12/2011 Marla Rhodes 9/12/2011 Melissa Lowitz 9/12/2011 Michael De Lisi 9/12/2011 Eileen Levett East Cambridge Planning Team Page 3 of 8 Additional Authors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 9/12/2011 Title Jeffrey Quinlan 9/12/2011 Clarice Pingenot 9/12/2011 Ruth Alfasso 9/12/2011 Susan Piver Browne 9/12/2011 Peter Micheli 9/12/2011 Rachel Fitchenbaum 9/12/2011 Ted Bach 9/12/2011 Anne Tate 9/12/2011 Taryn LaFlamme 9/12/2011 Matt Timmins 9/12/2011 Kristine Lessard 9/12/2011 John Hostage 9/13/2011 Sara Zucker 9/13/2011 Bathsheba Grossman 9/13/2011 Fred Berman 9/13/2011 Esme Blackburn 9/13/2011 Jane Sauer 9/13/2011 Sarah Shugars 9/13/2011 Brett LaFlamme 9/13/2011 Jonah Petri 9/13/2011 Christine Casalini 9/13/2011 Amanda King 9/13/2011 Tim Sackton 9/13/2011 Abbe Cohen 9/13/2011 Leigh Lozano 9/13/2011 Michelle Liebetreu 9/13/2011 Gwen Wilcox 9/13/2011 Scott Campbell 9/13/2011 Courtney Petri 9/13/2011 Alex Krogh-Grabbe 9/13/2011 Catherine Thompson 9/13/2011 Gerald Herb Wilmoth 9/13/2011 Resa Blatman Affiliation Additional Authors Gavin Schnitzler Andy Brandt Page 4 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 9/13/2011 Title Paul Morgan 9/13/2011 Derek Prior 9/13/2011 City Clerk John Long 9/13/2011 Jeanine Farley 9/13/2011 Andrea Yakovakis 9/13/2011 Joel Bennett 9/13/2011 James Bride 9/13/2011 Enid Kumin 9/13/2011 President Ellin Reisner 9/13/2011 Lynn Weissmann 9/13/2011 Douglas Rhodes 9/13/2011 Rachel Burckardt 9/13/2011 Executive Director Wendy Blom 9/13/2011 John Wilde 9/13/2011 Staff Attorney Rafael Mares 9/13/2011 Marguerite Avery 9/13/2011 Elisabeth Bayle 9/13/2011 Rich Lee Affiliation Additional Authors City of Somerville Board of Alderman Somerville Transportation Equity Partnership Somerville Community Access Television Edua Wilde Conservation Law Foundation Alison Lee 9/13/2011 Board President Nancy Bernhard 9/13/2011 Carl Wagner Groundwork Somerville 9/13/2011 Denise Taylor 9/13/2011 Michael Prange 9/13/2011 Elizabeth Kazakoff 9/13/2011 Lisa Brukilacchio 9/13/2011 Julia Petipas 9/13/2011 Mayor Michael McGlynn City of Medford 9/13/2011 Executive Director Mimi Graney Union Square Main Streets 9/13/2011 Emma Oster 9/13/2011 Vanessa Vega Page 5 of 8 Livingston Parsons III, President, Board of Directors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 9/13/2011 Title Karen Molloy 9/13/2011 Adelaide Smith 9/13/2011 Jared Worful 9/13/2011 President Neil Osborne 9/13/2011 Andy Hinterman 9/13/2011 Jim McGinnis 9/13/2011 Tom Eagan 9/13/2011 Joanna Hale 9/13/2011 Anita Nagem 9/13/2011 Michael Chiu 9/13/2011 Richard Nilsson Affiliation Additional Authors NAACP, Mystic Valley Branch Ramon Bueno; William Kipp; Robert Martel; 9/13/2011 Trustees Brickbottom Condominium Trust Cynthia Dana Pellegrini; Randal Thurston; Heather Van Aelst 9/13/2011 James Moodie 9/13/2011 President / CEO Stephen Mackey 9/13/2011 John Reinhardt Somerville Chamber of Commerce Aly Lopez; John Robinson; Bernal Murillo; Leanne Molloy; Danny McLaughlin; Claudia 9/13/2011 Advisory Team Peter John Marquez Community Corridor Planning Rabino; Sal Islam; Rosemary park; Rolare Dorville; Edson Lino; Mekdes Hagos; Lenora Deslandes; Santiago Rosas; Shelia Harris; Sarah Shugars; Josh Wairi; Jen Lawrence 9/13/2011 Natasha Burger 9/13/2011 Executive Director Chris Mancini 9/13/2011 Phoebe Hackett 9/13/2011 Erin Hemenway 9/13/2011 Jane Bestor 9/13/2011 Mitch Bogen 9/13/2011 Linda Goulet 9/13/2011 Debra Olin Groundwork Somerville Page 6 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date Title First Name Last Name 9/13/2011 Richard Turcotte 9/13/2011 John Schneider 9/13/2011 Dan Hamalainen 9/13/2011 Adam Friedman 9/13/2011 Leonard Tower Jr. 9/14/2011 cdiminico@comcast.net 9/14/2011 John Recinito 9/14/2011 Aileen Bellwood 9/14/2011 Jeff Reese 9/14/2011 Stephen Kaiser 9/15/2011 Nancy Lincoln 9/15/2011 Karen Galil 9/15/2011 Arnold Reinhold 9/15/2011 John MacDougall 9/16/2011 Fernando Collina 9/16/2011 Margaret Collins 9/18/2011 Justin Hunt-Hahn 9/18/2011 Margaret Weigel 9/18/2011 Joel Weber II 9/18/2011 Jeff Levine 9/18/2011 Kevin Block-Schwenk 9/18/2011 Joel Weber II 9/19/2011 Maria Daniels 9/19/2011 Stephen Linder 9/19/2011 John Sieber 9/19/2011 sheehan.t@gmail.com 9/19/2011 Charles Marquardt 9/20/2011 Ethan Gilsdorf 9/20/2011 William Wood 9/20/2011 Kimberly Gosselin 9/20/2011 Arun Sannuti Affiliation Arlington Transportation Advisory Committee Additional Authors Howard Muise; Jeffrey Maxtutis Marilyn MacDougall Elizabeth Hunt-Hahn Deborah Block-Schwenk Page 7 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Email Comments Date First Name Last Name 9/20/2011 Title Greg Kindel 9/20/2011 Antonio Lasalletta 9/20/2011 William Harnois 9/20/2011 Chris Meiman 9/20/2011 Lara Petrak 9/20/2011 Jeff Kaufman 9/20/2011 Lawrence Paolella 9/20/2011 Jim Gallagher Stephen Kaiser Kathryn West 9/20/2011 Erika Tarlin 9/20/2011 Ethan Haslett 9/20/2011 Alan Moore 9/20/2011 Seth Minkoff 9/20/2011 Marco Rivero 9/20/2011 John Roland Elliot 9/20/2011 Ken Krause 9/20/2011 Laurel Ruma 9/20/2011 Sarah Lim 9/20/2011 Katjana Ballantyne 9/21/2011 Josiah Lee Auspitz 9/21/2011 President and Founder Renata von Tscharner 9/23/2011 Wig Zamore 9/20/2011 9/20/2011 Vice President of Real Estate and Facilities Affiliation Additional Authors Partners HeathCare System Tony Lim Charles River Conservancy Page 8 of 8 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Letter Comments Date Title First Name Last Name Affiliation Additional Authors Patricia Jehlen, State Senator; Sal DiDomenico, State Senator; Denise Provost, State 9/12/2011 Masachusetts General Court Representative; Timothy Toomey, State Representative; Carl Sciortino, State Representative; Sean Garballey, State Representative 9/13/2011 Co-Presidents Friends of the Community Path 9/13/2011 Staff Attorney Rafael Mares 9/13/2011 Stephen Kaiser 9/13/2011 Consumer Associate Micaela Preskill MassPIRG Green Line Advisory Committee for 9/13/2011 9/14/2011 Conservation Law Foundation Medford Fred Salvucci 9/16/2011 Mary Anne Adduci 9/19/2011 City Manager Robert Healy City of Cambridge 9/20/2011 Executive Director Marc Draisen Metropolitan Area Planning Council Page 1 of 1 Lynn Weissman; Alan Moore Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Oral Testimony (Public Hearing 09/13/2011) Date Title First Name Last Name Affiliation 9/13/2011 Mayor Joseph Curtatone City of Somerville 9/13/2011 Stephen Kaiser Association of Cambridge Neighborhoods 9/13/2011 State Representative Denise Provost Massachusetts House of Representatives 9/13/2011 Alan Moore Friends of the Community Path 9/13/2011 Brian Clements 9/13/2011 Jonah Petri 9/13/2011 Staff Attorney Rafael Mares 9/13/2011 Elisabeth Bayle 9/13/2011 Merideth Levy Conservation Law Foundation Somerville Community Corporation 9/13/2011 John Elliot 9/13/2011 Daniel LeBlanc 9/13/2011 Mark Chase 9/13/2011 Bill Deignan City of Cambridge 9/13/2011 Ellin Reisner Somerville Transportation Equity Partnership Somerville Bicycle Advisory Committee Somerville Community Corporation 9/13/2011 Alex Epstein 9/13/2011 Wig Zamore 9/13/2011 State Senator Patricia Jehlen Massachusetts Senate 9/13/2011 State Representative Carl Sciortino Massachusetts House of Representatives 9/13/2011 William Wood Green Line Advisory Group of Medford 9/13/2011 Carolyn Rosen Green Line Advisory Group of Medford 9/13/2011 Stephen Kaiser Association of Cambridge Neighborhoods 9/13/2011 Karen Malloy 9/13/2011 Jim McGinnis 9/13/2011 Rachel Stark Walk Arlington 9/13/2011 Micaela Preskill MassPIRG 9/13/2011 Heather Van Aelst 9/13/2011 Lynn Weissman 9/13/2011 Julia Prang 9/13/2011 Ethan Contini-Field 9/13/2011 Ken Krause Friends of the Community Path Page 1 of 2 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Oral Testimony (Public Hearing 09/13/2011) Date Title First Name Last Name Affiliation 9/13/2011 Hayes Morrison City of Somerville 9/13/2011 Brad Rosen City of Somerville 9/13/2011 Fred Berman Somerville Community Corporation 9/13/2011 Robert LaTravoy 9/13/2011 Patricia Davis 9/13/2011 John Kramer 9/13/2011 Jason Fuller Page 2 of 2 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/16/2011 Barbara Buell 9/16/2011 John Katzmaier 9/16/2011 Jessica Boyatt 9/16/2011 Micaela Preskill 9/16/2011 Rachel Bartolomei 9/16/2011 Marc Davidson 9/16/2011 R. Frances Regan 9/16/2011 Wendi Quest 9/16/2011 Heidi Smith 9/16/2011 Rebecca Tippens 9/16/2011 Roberta Fox 9/16/2011 Joseph Robert Dorkin 9/16/2011 Daniel Dibble 9/16/2011 Gary Martin 9/16/2011 Carol Duke 9/16/2011 William Rowe 9/16/2011 Larry Rosenberg 9/16/2011 Jeff Gang 9/16/2011 Kimberly Gosselin 9/16/2011 Amnique Boomsna 9/16/2011 Phyllis Miller 9/16/2011 Mark Rosenstein 9/16/2011 Eric Becker 9/16/2011 Glen Hassard 9/16/2011 Matthew Agen 9/16/2011 Mark Eckstein 9/16/2011 Jaylin Dibble 9/16/2011 Liz Breadon 9/16/2011 Randy Hammer 9/16/2011 Nathan Proctor Affiliation Page 1 of 7 Additional Authors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/16/2011 Barbara Roman 9/16/2011 Elaine McCool 9/16/2011 Jonathan Hohl Kennedy 9/16/2011 Gita Manaktala 9/16/2011 Andrew Billeb 9/16/2011 Annie Laurie 9/16/2011 Karen Molloy 9/16/2011 Marcia Cooper 9/16/2011 Sharon MacNeil 9/16/2011 Katie McGillicuddy 9/16/2011 Dianne Brooks 9/16/2011 Devin Meyer 9/16/2011 Matthew Reardon 9/16/2011 Affiliation Butterfiles and Blueberries Inn 9/16/2011 Jonah Sacks 9/16/2011 Kostia Bergman 9/16/2011 Peter Cohen 9/16/2011 Shawn Gillpatrick 9/16/2011 Samantha Rothberg 9/16/2011 Peter Reynolds 9/16/2011 Andrea Yakovakis 9/16/2011 Susan Lemont 9/16/2011 Nina Duncan 9/16/2011 Amy Manganelli 9/16/2011 John McGrath 9/16/2011 Cory Mann 9/16/2011 Owen Watson 9/16/2011 Phillip Gerstein 9/16/2011 Dorothy Anderson 9/16/2011 Eric Ranvig Page 2 of 7 Additional Authors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/16/2011 Julie Bogart 9/16/2011 Costa Chitouras 9/16/2011 William Gay 9/16/2011 Joan Lindeman 9/16/2011 Pat Moloney-Brown 9/16/2011 Janis Mcquarrie 9/16/2011 AA Hopeman 9/16/2011 Leah Cartmell 9/16/2011 Selene Gisholt 9/16/2011 Carol Rosenblith 9/16/2011 David Clarke 9/16/2011 John Hess 9/16/2011 Kim Peperson 9/16/2011 Laura Paul 9/16/2011 Elaine Kelly 9/16/2011 Jacqueline Royce 9/16/2011 Trudi Burrows 9/16/2011 Olivier Resca 9/16/2011 Robert Costa 9/16/2011 Nicola Moore 9/16/2011 Catherine Martin 9/16/2011 Katelyn King 9/16/2011 Danielle Miele 9/16/2011 Rosemary Hewett 9/16/2011 Ryan O'Connor 9/16/2011 Isavah Shalom 9/16/2011 Julia Petipas 9/16/2011 Marie-Louise Jackson-Miller 9/16/2011 F Corr 9/16/2011 Sybil Gilchrist Affiliation Page 3 of 7 Additional Authors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/16/2011 Richard Punko 9/16/2011 Jeffrey Tan 9/16/2011 John Kramer 9/16/2011 Christine Roane 9/16/2011 Rand Barthel 9/16/2011 Joanne Bernot 9/16/2011 Patrick Greene 9/16/2011 Emily White 9/16/2011 Ryan Houlette 9/16/2011 Heather Platt 9/16/2011 Matthew Weyant 9/16/2011 Nicholas Panganella 9/16/2011 Alex Epstein 9/16/2011 Donald Avery 9/16/2011 Beth Zonis 9/16/2011 Richard Harding 9/16/2011 Sybil Schlesinger 9/16/2011 Sean Hooley 9/16/2011 Jill Shoenleber-Hoel 9/16/2011 Cynthia Snow 9/16/2011 Kyle York 9/16/2011 Marilyn Glover 9/16/2011 Dianne Gove 9/16/2011 Patricia Panitz 9/16/2011 Joyce McNeil 9/16/2011 June Pearson 9/16/2011 Marilyn Mullane 9/16/2011 John Rhodes 9/16/2011 Diana Esteves 9/16/2011 Ted Curtin Affiliation Additional Authors Theod Panitz Page 4 of 7 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/16/2011 Frank Kreimendahl 9/16/2011 Jill Penn 9/16/2011 Nancy Free 9/16/2011 Noni Davies 9/16/2011 Barry Hart 9/16/2011 Louise Smith 9/16/2011 Loraine Ferrara 9/16/2011 Susan Anderson 9/16/2011 Patricia Bashford 9/16/2011 Andrew Lenz 9/16/2011 Lise Hildebrandt 9/16/2011 Rebecca Hill 9/16/2011 Carol Carbonell 9/16/2011 Van Blakeman 9/16/2011 Christopher Llop 9/16/2011 Carole Donlan-McAuliffe 9/16/2011 Kate Stanley 9/16/2011 Stephen Milkewicz 9/16/2011 Nilah MacDonald 9/16/2011 Anne Jochnick 9/16/2011 Brenda Crawshaw 9/16/2011 Jonathan Snyder 9/16/2011 Sandra Myers 9/16/2011 Isbell Ambiel 9/16/2011 Ellen Ander 9/16/2011 James Spaulding 9/16/2011 James Hadcroft 9/16/2011 John Hostage 9/17/2011 George Sopel 9/17/2011 Andrew Fischer Affiliation Additional Authors Steve Crawshaw Page 5 of 7 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/17/2011 H. Paul Santmire 9/17/2011 John Harris 9/17/2011 Rob Fleagle 9/17/2011 Derek McCarthy 9/17/2011 Fusun Fufanyazici 9/17/2011 Peter Sampou 9/17/2011 Laurie Friedman 9/17/2011 Peter Lundell 9/17/2011 Susan Rubel 9/17/2011 Leslie Moye 9/17/2011 Dale Malabarba 9/17/2011 Franziska Amacher 9/17/2011 John Santos 9/17/2011 Bernice Lofchie 9/17/2011 Sarah Mc Kee 9/17/2011 Marin Kress 9/17/2011 Pamela Lyons 9/17/2011 Mark Boswell 9/17/2011 Claudia Heller 9/17/2011 Paul Ezust 9/17/2011 Ellen Levine 9/17/2011 Andrea Doukas 9/17/2011 Sally Barney 9/17/2011 Cheryl Vallone Rigby 9/18/2011 Kenneth Hasenfus 9/18/2011 Mary Hoffmann 9/18/2011 Mark Koppelkam 9/18/2011 Martha Simon 9/18/2011 Sally Soluri 9/18/2011 Mark Zimmerman Affiliation Additional Authors Miriam Ezust Page 6 of 7 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) MassPIRG Petition Date Title First Name Last Name 9/18/2011 Catherine Farrell 9/19/2011 Brian Kolek 9/19/2011 Michelle Moon 9/19/2011 Clara Gagnon 9/19/2011 David Reich 9/19/2011 Steve Bandler 9/19/2011 Maureen Barillaro 9/19/2011 Peter Kahn 9/19/2011 John Cox 9/19/2011 Susan Castillo 9/19/2011 Patricia Ascione 9/19/2011 Allerlaroo Loftfield 9/19/2011 Sydney Berkman 9/20/2011 Shirley Astle 9/20/2011 Robert Ryan 9/21/2011 Tina McBride 9/23/2011 John Prance Affiliation Page 7 of 7 Additional Authors Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Joel Ana Barrett Justin Cohen The Campe Family Nora O'Brien Hannah Jenkins Elizabeth Aureden John Wilde Charles Denison IV Matt Carty Abby Bower Rachel Freudenburg Kristine O'Brien Jesse de la Rosa Patrick King Jennifer Kapuscik Joan Kreie Justin Launderville Kristine Dunn John Lewis Joanna Launderville James Castignoli Michael Quan Catherine Anne Tweedie Nathan Bale F.J. Zandbergen John H. Covert Linnea Van Griethuijsen Curtis E. Townsend Kate Keleher Page 1 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Nancy Gittelson Megan Sebasky Susan Hamilton Sarah Perlmutter Charles Bend Julia Malik Marcello Murray Gerald Hershkowitz Lisa David Rebecca Schor John F. Summerstein Ethan Contini-Field Lauren Mayher John Cullimore Cian Rath-Cullimore Daniel Toner Jeanie Mills Judith Klausner Stephen Pomeroy Adam Rocha Josh Wairi Michael Heyman Mark Vasnussa Roger May M. Halevi Timothy Butler Reverend Ellen M. Frith Ashley Coleman-Fitch Jean Gerald Victorine Page 2 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Philip Kim Neher Alex Bombard-Fitch Richard Dorgherty George Smith Judy Smith Margorie Crockett Elisabeth Brigham Rebecca Abbott Patricia M. Cordeiro Mark Fellenz Christian Rodriguez Miranda Banks Louis Epstein Nix Goldowsky-Dill Maggie Kaiser Daniel H. Reis Ranga Natasujan Dion Mraz Christine Mraz Susan Bloom Cassandra Baxter Meridith Greene Eben S. Cross Rahela Zdunic Stephen LoVerme Erin Genett Becky Ernes Paula Pomianowski John Collins Page 3 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Tim Curtin Ariyeh Weissman Bennett Kate Penrose Kate Sheehan Rachel Fichtenbaum David Anderson Roy O Elizabeth B. Hardy Brian Cagney Mark Jewell John M. Jackson Meghan Misset Seth Heidkamp Juhi K. Chandalin Sam Christy Jeff Greenweld Janie Katz-Christy Kelly Richburg Chris Richburg Rob Caruso Zackary Weissman Bennett Derek Astles Dan Brunelle John Sadoff Andrea Broggi Joseph Keane Kristjan Varnik Alex Feldman Ami Feldman Ana Olgi Page 4 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Ian Boardman Adelaide Smith Mitch Stoltz Kate Daniel Adam Elisabeth Fine Chad Laurent Jordayna Laurent Sasha Krushnic Janet Wood-Spagnoli Amy Mendosa Mary Anna Gram Patricia J. Hawkins Enxhi Popa Jean Monroe Daniel Gurwitz Juan Jose Cragnolini Heather A. Maclean Heidi Burke C. Garrett Laws Karen Edlund David A. Bank Stewart Jester Peter Lee Margaret Weigel Gianna M. Ericson Dr. Keith M. Ericson Michelle Vincow James Hanley Martin Jaspar Page 5 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Michael J. Coro Emba Cook Naomi Stein Kara Suffredini Sarah Winaveer-Wetzel Michael Schechton Danielle Ulanet Chirstopher Eschenbach E Wiest Debra Lytle Ilana Galil Michael D. Edge Kristen Irvin Gregory Saia Rachel Borgatt Jennifer Gifford Lee Stoiser Anthony Smith-Grieco Ulysses Latenher Allison Strochlic Sally Chapman Matthew Farrellee Christopher Boua Rebekah M Christina Epstein Pallas Snider John Bunzick Carol Parker Chris Hearse Amanda Breneman Page 6 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Matthew Banos G. R. Schnitzler Micah Sachs Edward Gorden Sarah Phillips James Scott Arnold Holly Hatch Geoff Sheinfeld J. Rosenstock Vita Waters Gillian Carter Ellin Reisner Andrea Yakovakis Dor Mang Zehra Cemile Marsan Catherine Anne Cabrera Justin A. Haber John Fuller Joe Shermin Alana L. Parkes Louisa Bradberry Beverly Hsu Molly Swanson Bem Gleason Jane Gillooly Cathy Thomason Avelar R. J Jack Cushman J. D. Duke Ryan Evens Page 7 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Kimmy Chan Jesse Mott C Leonardi Sharon Zimmerman Alaine C. Thaler Holly Parker Ron Brunelle Louisa Stephens Dan Von Lossnitzer Meg Rose Charles Rose Andy Joseph Lucilia Valerio Rain Robertson Zoe Robertson Megan Curtis Mark Niedergang Karen Molloy Christopher Vaughan Ted Bach Kathryn Johnson Margaret Puncost Victoria M. Thompson Todd Easton Brian Murphy Lisa O Joanne B. Pascar Melanie Magnan Kate Doiron Laura Ma Page 8 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Ryan Ma Silvia Rimolo Doreen Charbonneau John C. Chamberlain Jennifer Argivas John Taylor Cate LaRoche Panos Argiras Stephanie Bielagus Ritu Sharma Chris Yang Alexis Gates Yvonne Yamanalca James Zou Neils LaWhite Kyle Barrett Matthias David Siebler Meghan Bailey Tiffany Knight Evan Reynolds Rui Zhong Christine DiBurno Lisa Gould Catherine Boyson Arah Schuur Cynthia Yeomans Eric Krupka Iyah Romm Carmel Kozlov Sylvia Thompson (Romm) Page 9 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name Thomas Hobson Leslie Caiola Ellen Stoolmacher Joanna Sebik Kathleen Eldridge Michelle Becker Monica Luke Diego Garcia Carolyn Grantham Maureen Strode Harold Boll Dip Parikh Lakshmi Jayaraman Zoe Rath Priya Gupte Amelia Ehrens Elizabeth Bergman Pauline Katz Kara A. Morris Kathryne Kinder Charles Snow Edward B Laura Roberts Megan Murphy Stuart Mendelson Jennifer Haefeli Glenn Patrick Joes McKellar Joshua Elvander Elaine Strunk Page 10 of 11 Comment Letters Received on the MassDOT 2011 Annual SIP Status Report (by format and date) Friends of the Community Path Petition First Name Last Name James Barr Galea Murton Brian Brady Graham Twibell David Snyder Rebecca Moses Barry Polsky Karen Gardner Gabriela Cafalano Michael Conte Max Poulsson Chris Pouliot Jennifer Gutbezahl Cindy Vojnovic Zorangeli Ramos Randall Winchester Alissa Weiss Eric Weiss Carson Campe Page 11 of 11 Massachusetts Department of Transportation Massachusetts Bay Transportation Authority State Implementation Plan - Transit Commitments 2011 Annual Status Report Agency Responses to Public Comments Submitted to the Massachusetts Department of Environmental Protection January 11, 2012 For questions on this document, please contact: Massachusetts Department of Transportation Office of Transportation Planning 10 Park Plaza, Boston, Massachusetts 02116 617-973-7342 planning@dot.state.ma.us INTRODUCTION This document summarizes and responds to public comments received by the Massachusetts Department of Transportation (MassDOT) on the State Implementation Plan - Transit Commitments 2011 Annual Status Report (the Status Report) submitted to the Massachusetts Department of Environmental Protection (DEP) on August 1, 2011 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 20, 2011, following a twopart public meeting (September 13, 2011) at which staff from MassDOT presented on the content of the Status Report and members of the public asked questions and provided their feedback. 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 MassDOT and MBTA 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. Throughout this document, the SIP regulation (310 CMR 7.36) is referenced. Additional information and detail on the regulation (310 CMR 7.36) can be viewed at: http://www.eot.state.ma.us/default.asp?pgid=content/transitCommitment&sid=about . 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.eot.state.ma.us/default.asp?pgid=content/transitCommitment&sid=about. 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 SIP projects. Those recommendations are being compiled and analyzed by MassDOT and will shortly be released for public review and comment as part of a separate process. Public Input The projects described in the Status Report each have public input processes associated with them, but the public process associated with the SIP itself provides an additional opportunity for MassDOT and the MBTA to hear from interested individuals and organizations about the progress and direction of our projects. This is a valuable reminder that our projects serve real people in real communities, and we strive to shape our efforts to meet the needs of the users of the transportation network, both present and future. At the same time, the framework of the SIP obliges us to retain a regional perspective and to understand that the portfolio of projects mandated under the SIP is intended to work together to bring Massachusetts Department of Transportation January 11, 2012 Page 1 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. MassDOT also wishes to register its concern about a recent coarsening of the public dialogue about the SIP projects, about MassDOT and MBTA staff, and about transportation policy and projects in general. The passion and intensity brought to the public debate by many people is both admirable and important; however, anger and insult only feed the fires of alienation between government and the general public, contributing to cynicism and disaffectation on all sides of the debate. We must work together to complete the SIP projects – and to advance good transportation planning and policy in general – in an environment of scarce resources and enormous demand. With all of these issues in mind, we are grateful to the individuals and institutions who participated in this public comment process and who participate in the ongoing development of transportation projects. This document follows the general format of the Status Report submitted on August 1, 2011, which is also included in this binder. Massachusetts Department of Transportation January 11, 2012 Page 2 I. GENERAL COMMENTS MassDOT is violating the law by failing to implement the SIP projects by their designated deadlines. SIP projects should be funded prior to any other MassDOT or MBTA projects. This is a violation of the Clean Air Act and potentially jeopardizes the federal transportation funding received by the Commonwealth. This is not correct. The regulation that underlies the commitment to the SIP projects (310 CMR 7.36) provides a mechanism for handling projects that are delayed or otherwise overdue, specifically the provision of ‘interim offset projects or measures.’ MassDOT is following the requirements of the SIP regulation and is working closely with DEP to define appropriate interim offset measures, which it will implement as appropriate – and therefore is not violating the law. MassDOT also works in partnership with the Federal Highway Administration and the Federal Transit Administration on all aspects of the Commonwealth’s federally funded transportation program, including the progress of the SIP commitments. The Regional Transportation Plan for the Boston Region Metropolitan Planning Organization was just found by the federal government to be in conformity with our regional air quality goals, meaning that MassDOT can anticipate no interruption in the federal transportation dollars received by the Commonwealth. 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 last addressed this issue in 2010. See: http://www.eot.state.ma.us/downloads/sip/SIP_CommentResponses011110.pdf. MassDOT is required to mitigate any delays in the implementation of SIP projects with interim measures that will provide 110% of the air quality benefits promised by the delayed projects. This is not correct. MassDOT is required to mitigate any delays in the implementation of SIP projects with interim measures that will provide 100% of the air quality benefits promised by the delayed projects. Should MassDOT seek to substitute a new project for one of the existing SIP commitments, then benefits of 110% or greater would be required. This is, however, not the case here. See 310 CMR 7.36, Section 4 for more information. SIP commitments are contractual agreements, and MassDOT is violating the contracts by not completing the SIP projects on time. This is not correct. The SIP commitments are transportation projects to be implemented by the Commonwealth, the requirements for which are embedded in state and federal regulations. They are also the product of a negotiated settlement between the Commonwealth of Massachusetts and the Conservation Law Foundation. The SIP regulation spells out a mechanism for mitigating delays in project implementation, substituting projects, and amending the SIP regulation itself. The proposed Green Line Extension terminus at College Avenue in Medford does not meet the SIP requirement for the Green Line to be extended to ‘Medford Hillside.’ MassDOT and the MBTA are therefore in violation of the SIP. As we have stated before, MassDOT and the MBTA feel confident not only that College Avenue offers the best balance of benefits and impacts of any potential station location in the immediate area of ‘Medford Hillside,’ but that it also fulfills the commitment by the Commonwealth for the Green Line Extension to reach ‘Medford Hillside’ and to serve the ‘Medford Hillside’ neighborhood. MassDOT believes that a terminus at College Avenue not only serves the ‘Medford Hillside’ area but also promises to draw riders to the Green Line and create a sense of Massachusetts Department of Transportation January 11, 2012 Page 3 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. 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. Potential future phases will be decided in the future. DEP is unable to effectively police MassDOT on the implementation of the SIP projects. MassDOT feels that the partnership currently in place between the two agencies is an effective one for advancing the SIP projects during a challenging fiscal time. SIP projects should be funded by the Commonwealth, not by the MBTA. The MBTA should not be burdened with debt related to the completion of the Central Artery/Tunnel project. 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. The MBTA currently carries and is responsible for the payment of debt related to the implementation of certain improvements to the MBTA system associated with the Central Artery/Tunnel project, including expansions to the Commuter Rail system and the modernization of the Blue Line. The value of this debt is approximately $1.4 billion of the overall $5.7 billion of outstanding MBTA debt. Although it is a topic of policy discussion, there are no immediate plans to remove responsibility for this debt from the MBTA. The gap in transportation funding should be filled by a new assessment on the Massachusetts Port Authority. The Massachusetts Port Authority is responsible for Logan International Airport, Worcester Regional Airport, and the civilian aviation component of Hanscom Field. It is also responsible for the Port of Boston and other ancillary facilities. Massport is one of the agencies of MassDOT, and collaborates with other branches of MassDOT on a variety of transportation and economic development initiatives, including the MBTA Silver Line service to Logan Airport. The activities of Massport are primarily funded through fees collected from airline passengers – which are often forbidden to be used for non-aviation purposes – as well as from revenue generated by the leasing of Massport-owned land and the use of Massport-owned parking garages. The leadership of MassDOT and Massport work together to figure out how Massport can best contribute to the overall transportation goals of the Commonwealth, within existing constraints and given Massport’s primary responsibility to the management of safe and efficient airports. Massachusetts Department of Transportation January 11, 2012 Page 4 See the response to a similar question on Page 20 of this document. Investment in the SIP projects comes at the expense of the service quality and system-wide condition of existing MBTA infrastructure. As described above, 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. The MBTA should be sold or privatized. Globally, some public transit systems – and some components of some public transit systems – have been sold or leased to private companies, with decidedly mixed results. MassDOT believes that the provision of public transit services is a fundamental duty of the public sector, and that responsibility for running the MBTA should remain a public one in as much as possible. A private company motivated by profit and private interest may not always be an appropriate entity to provide public transit service, which by definition offers low-cost mobility to the general public. While no administrative arrangement may be the perfect one, on balance we believe that public management of the MBTA provides a higher level of accountability and control than would private management. However, that arrangement may be different for the provision of different types of services, as noted in the answer immediately below. The existing contract for the provision of MBTA Commuter Rail service should be re-bid, with terms that are more favorable to the MBTA. The MBTA Commuter Rail system is currently operated by a private firm, the Massachusetts Bay Commuter Railroad Company (MBCR). The current contract between MBCR and the MBTA expires in summer 2013. The procurement process for the Commuter Rail contract is extremely complex and takes several months to complete, so the MBTA and MassDOT have already begun to work on it. While it is too early in the process to predict what the exact terms of the contract will be or who the ultimate operator will be, the MBTA and MassDOT continue to examine methods of improving performance on the Commuter Rail system, and the means of integrating those methods into a new operating contract. Many lessons have been learned from current and past contracts, and those lessons will inform the development of future contracts. The Department of Environmental Protection should require a new, metro-area review of multi-modal transportation planning, similar to the 1971 Boston Transportation Planning Review. MassDOT will defer to DEP on this, but will comment that that the projects currently underway in fulfillment of the SIP were developed as a package that included cooperation by MassDOT, DEP, other government agencies, and the general public; that each of the SIP projects is regularly codified in the short- and long-range planning documents prepared by the Boston Region Metropolitan Planning Organization through an iterative process of analytical evaluation and public review and comment; and that each of the SIP projects themselves have their own civic engagement processes associated with them. MassDOT is also engaged in a number of statewide transportation planning efforts. Arguably, the transportation planning process in the Commonwealth is more transparent and has more public involvement now than ever before (and certainly more so than in the 1970s). MassDOT and the MBTA should be exploring the feasibility and costs/benefits of switching its fleets from those that use combustion engines to those that run on battery power. In addition, MassDOT and the Massachusetts Department of Transportation January 11, 2012 Page 5 MBTA should be exploring the feasibility and costs/benefits of providing public charging stations for electric vehicles. To date, the MBTA has invested heavily in vehicles that burn clean fuel rather than in electric vehicles. With years of experience in the field of vehicle-fueling technologies, the MBTA has generally found that electric vehicles are unable to provide the reliability or range of travel that is required for MBTA vehicles. That could change in the future, however, and the MBTA recently announced a three-year partnership with Chrysler to pilot ten Dodge Ram plug-in electric trucks for agency use. Depending on the success of the pilot, MassDOT and the MBTA will determine if wider use of electric vehicles is feasible and sensible. MassDOT is also currently working on an implementation plan for the MassDOT GreenDOT policy, which will consider a variety of green infrastructure concepts and technologies and their appropriate application across the Commonwealth. Vehicle Miles Traveled (VMT) is not the best measure of air quality conformity. Consider using Vehicle Hours Traveled (VHT) instead. 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 U.S. 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 able to ‘look up’ the congestion levels and other pertinent characteristics of roadway segments and incorporate that information into its emissions calculations. Emissions are then 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. 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 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 U.S. EPA in their new emissions model called ‘MOVES.’ Barring any new guidance from U.S. 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. In order to garner greater levels of public support and funding, the MBTA simply must improve its reliability, frequency, and customer service. The MBTA operates one of the most expansive and heavily patronized public transportation networks in the United States. Service is provided by the most diverse fleet of transit vehicles (commuter rail, heavy rail, light rail, trackless trolley, dual-mode articulated buses, traditional buses, historic PCC trolley cars, and boats) and, in places, on the oldest infrastructure, in the Massachusetts Department of Transportation January 11, 2012 Page 6 nation. It is a challenge for the MBTA to meet the needs of its 1.2 million daily passengers while also working to maintain a state of good repair on its complex system. MassDOT appreciates that improved service is an important prerequisite that the MBTA must meet in order to garner greater public support or a willingness to devote public resources to the system. However, the current financial state of the MBTA contributes in part to the Authority’s inability to make major advances in the performance areas cited in some letters. System reliability is impacted by many factors outside of MBTA control (for example, traffic congestion on city streets can have significant impacts on the reliability of buses and some light rail service). Other reliability issues are caused by deferred maintenance on signal systems, rolling stock, tracks, etc., that have followed from the MBTA’s well-documented lack of resources. The ability to increase service frequency—particularly during peak periods when they would have the greatest benefit—can only be achieved by shifting service off of other routes or through the availability of additional resources. Massachusetts Department of Transportation January 11, 2012 Page 7 II. FAIRMOUNT LINE IMPROVEMENT PROJECT In its Petition to Delay for the Fairmount project, MassDOT states that the proposed offset measures meet the required emissions reduction targets, but the Petition does not provide an adequate level of detail for DEP, or other stakeholders, to evaluate that assertion. MassDOT fails to identify its assumptions in the Petition. A memo describing the assumptions made in support of the Petition to Delay is appended to this document. [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. A reduction in the fares on the Fairmount Line could lead to pressure for reduced fares at other stations for other idiosyncratic reasons, leading to a return to a system of arbitrary fares at certain stations. MassDOT and the MBTA should immediately institute the use of diesel-multiple units on the Fairmount Line. MassDOT and the MBTA have in the past and are again researching the potential use of selfpowered diesel-multiple units (DMUs) on the Fairmount Line and throughout the MBTA system. DMUs potentially offer the benefit of being relatively flexible compared to a full-length Commuter Rail train, and MassDOT and the MBTA are potentially interested in making use of them in the future. However, certain obstacles stand in the way of their immediate introduction on the Fairmount Line: (1) the MBTA currently does not own any DMU-like vehicles, nor are there any currently available for purchase that meet the safety standards of the MBTA and the Federal Railroad Administration, (2) the MBTA does not currently have a facility for maintaining DMU-like vehicles, nor is its staff trained to maintain them, and (3) the MBTA does not have the funds necessary to invest in a new fleet of vehicles. Given the delays in the construction of the Blue Hill Avenue station, it is important that the MBTA begin running passenger service to the other new Fairmount Line stations as soon as possible. The MBTA should not wait for the completion of the Blue Hill Avenue station to begin running new service. The MBTA plans to open the new Fairmount Line stations incrementally, as soon as each one is ready. The MBTA will not wait for the Blue Hill Avenue station to be opened before it introduces passenger service to the other new stations on the Fairmount Line. Massachusetts Department of Transportation January 11, 2012 Page 8 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 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. It is troubling that MassDOT questions the air quality benefits of the parking facility it has chosen to meet over sixty percent of the requirement to construct one thousand new park and ride parking spaces [a parking facility at Wonderland Station]. At a minimum, MassDOT should be required to provide mitigation for any delay in the opening of the parking at Wonderland. MassDOT appreciates this concern, and wants to emphasize that it believes that the long-term potential of a garage at Wonderland Station makes it a worthwhile investment and a worthwhile project to meet the SIP commitment. Over time, the area around Wonderland Station is slated to grow with new housing, hotels, and employment. Furthermore, the Wonderland area has the potential to serve as a new gateway into the downtown Boston area, making it a suitable location for parking facilities intended to facilitate a transfer from private automobile to the public transit network. With guidance from DEP, MassDOT has reconsidered its position on mitigation for delays in the implementation of the park and ride parking spaces at Wonderland Station and is planning to provide the following interim offset mitigation: increased Saturday bus service on Route 111, the highest ridership route serving the communities to the northeast of Boston. This interim mitigation service will begin in January 2012. Public parking is available at the Savin Hill MBTA station, but is not listed on the MBTA website. Parking information for the Savin Hill station is available at: http://www.mbta.com/riding_the_t/parking/?transittype=Subway&rn=Red&submitsubway=Find+Parking Massachusetts Department of Transportation January 11, 2012 Page 9 IV. RED LINE/BLUE LINE CONNECTOR MassDOT and the MBTA should build the Red Line/Blue Line Connector project. 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, which would experience a reduction in 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 ‘shovel-ready.’ The term ‘shovel-readiness’ entered standard parlance during the implementation of the American Recovery & Reinvestment Act. Conceptually, shovel-ready means that an infrastructure project is fully ready for construction – all designs done, all right-of-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 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 appropriately cautious about preparing a project like the Red Line/Blue Line Connector to a ‘shovel-ready’ level. The concept of shovel-readiness exists in part because the federal government is inexorably reducing its commitment to funding state-level transportation needs through guaranteed funding formulas. Instead, projects must compete for shrinking pots of discretionary funds, giving those projects that are supposedly ‘shovel-ready’ a leg up on those that require longer and more complex development. A project like the Red Line/Blue Line Connector simply requires too Massachusetts Department of Transportation January 11, 2012 Page 10 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. MassDOT should complete just the beginning of a final design phase for the Red Line/Blue Line Connector project, in order to prepare the project for a design-build contract. Although the described approach could avoid some of the costs associated with performing full final design and would leave open the option to construct the project using a method other than traditional design-bid-build (and perhaps take advantage of schedule and cost efficiencies by doing so), it doesn’t address the fundamental resource constraints faced by MassDOT for the construction of public transit projects. MassDOT simply doesn’t have the money, nor does it anticipate having the money in the foreseeable future, to dedicate to constructing the Red Line/Blue Line Connector. MassDOT and the MBTA should complete conceptual design and state-level environmental review for the Red Line/Blue Line Connector project. At present, a Draft Environmental Impact Report, along with conceptual design, has been completed and is available at: http://www.eot.state.ma.us/redblue/documents.htm. Given the uncertainty surrounding the ultimate construction schedule for the Red Line/Blue Line Connector project, MassDOT has been ambivalent about the value of completing state-level environmental review for the project, given the resources required to do so. The lack of a clear funding plan and construction schedule makes it difficult to fully and accurately assess the environmental impacts associated with the project, hence the difficulty of completing environmental review and permitting given the current status of the project. This position is reflected in the Massachusetts Environmental Policy Act Office certificate on the Red Line/Blue Line Draft Environmental Impact Report: However, at present this project is not listed on the latest Regional Transportation Plan (RTP) for the Commonwealth that identifies transit projects slated for funding and completion in the next 20 years, and no funding sources have currently been identified. Given these circumstances it appears possible that this project will be not [sic] constructed within the timeframe typically associated with MEPA review. Under the MEPA regulations, if a project does not commence construction within three years of the availability of the FEIR a Notice of Project Change (NPC) is required, and a new Environmental Notification Form is required after five years. These provisions of the regulations are intended to ensure meaningful review of environmental impacts by requiring review of project-related impacts in light of currently-existing conditions. Therefore, if the Red Line/Blue Line Connector project does not commence construction within these regulatory time periods, supplemental MEPA review may ultimately be required. MassDOT should perform ‘value engineering’ for the Red Line/Blue Line Connector project. Should the project advance beyond the stage of conceptual design, the methodologies of value engineering could be useful to develop the most efficient and cost-effective design. Massachusetts Department of Transportation January 11, 2012 Page 11 MassDOT should reconvene the Red Line/Blue Line Connector Working Group. The Working Group supported MassDOT during the development of conceptual design and the Draft Environmental Impact Report. Should MassDOT continue the environmental review process, it would reconvene the Working Group. MassDOT and the MBTA focus too much on the transportation needs of suburban commuters and not enough on the needs of urban residents and workers. This is inequitable, and will be exacerbated by MassDOT’s request to cease work on the design of the Red Line/Blue Line Connector, a project which would benefit urban users of the MBTA system. MassDOT is a statewide agency, and thus obliged to consider the needs of the transportation users of the entire Massachusetts transportation system. Over the life of the legal commitments associated with the Central Artery/Tunnel project and the SIP, transportation projects have been implemented that have benefited both urban and suburban users (keeping in mind that the MBTA system is just that – an interconnected system – and improvements to one element of the system can provide residual benefits throughout). The current package of SIP commitments – the Fairmount Line Improvement project, 1,000 park and ride spaces, Red Line/Blue Line Connector design, and extension of the Green Line to Somerville and Medford – is heavily weighted towards projects in urban areas. MassDOT takes seriously its commitment to urban users of the transportation network, and particularly users of the MBTA system. Nevertheless, MassDOT is simply unable at this point to continue to design the Red Line/Blue Line Connector – a commitment which in and of itself has no air quality benefits – without any expectation that the funds necessary to construct the project will become available in the foreseeable future. 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 Red Line/Blue Line Connector requirement. As the existing Red Line/Blue Line Connector requirement is solely to perform final design of the Connector, the Red Line/Blue Line Connector provides no measurable air quality benefits by itself. A re-modeling of the SIP projects, both with and without the Connector requirement, would show the identical air quality benefits. 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. 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. Massachusetts Department of Transportation January 11, 2012 Page 12 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 does not explain why it used less favorable assumptions to estimate the cost of construction of Red Line/Blue Line Connector than any other public transit project it is currently planning. While MassDOT recognizes that it included a much more conservative contingency amount for the most recent cost estimate, it fails to disclose that it also included a higher inflation rate. The inflation rate used in the Red Line/Blue Line Connector Draft Environmental Impact Report was developed by MassDOT and its consultant team. Project costs were escalated to an anticipated midpoint of construction, based on the planning assumptions within the Draft Environmental Impact Report. The 4.2% inflation rate was based on Federal Transit Administration recommendations to make use of historic averages, as measured by the increase in the Consumer Price Index and real gross domestic product since 1947. The average annual rate of inflation over this period was 4.2% with some years as high as 14.4 % and others as low as –1.2 %. The 40% contingency level was deemed necessary to account for scope growth, evolution of design, and schedule risk for an enormously complex tunnel project in the middle of an historic urban environment. The contingency was developed as part of a risk analysis process and represents a weighted average of separate contingencies applied to tunnels, track, schedule, structures, utilities, surface work, and other elements of the project. As a project evolves beyond the 10% level of design, monies budgeted to contingency would shift to defined estimate items and the overall contingency would be reduced. The Red Line/Blue Line project team developed the contingency percentage considering past experience with project construction projects. MassDOT, which currently oversees hundreds of projects in various stages of planning and development, does not have a policy requiring that the same assumptions be made for every planned project’s cost estimate. These estimates, which are developed at different points in time for different projects, are always evolving to reflect the stage of project development and the risks associated with particular projects. Furthermore, the unique nature of every project – its built environment, whether it is above or below grade, whether or not in includes rolling stock – also result in variation in the estimates and measures used to forecast costs. MassDOT is inflating the costs of completing design for the Red Line/Blue Line Connector intentionally. 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 come in over their original cost estimates, not under. MassDOT did not manipulate the process of estimating the costs. Massachusetts Department of Transportation January 11, 2012 Page 13 MassDOT has not made the full back-up materials that contributed to the development of the cost projections available to the public. These materials can be found online at http://www.eot.state.ma.us/redblue/. 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. Leaving aside the enormous 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. Furthermore, the fundamental problem of financing the construction of the Red Line/Blue Line Connector remains. Even if MassDOT is unable to design and construct the Red Line/Blue Line Connector right now, it should work to preserve the right-of-way that would be necessary to eventually construct it. In principle, MassDOT agrees with this approach. It can be challenging, however, in cases where the public sector requests that private development interests delay or modify building proposals – sometimes at substantial expense or with substantial impacts to a proposed project – for transportation projects that are not designed, permitted, or funded. If handled poorly, this can have negative repercussions for the built environment as a whole. Nevertheless, MassDOT will consider this strategy where and as appropriate. Massachusetts Department of Transportation January 11, 2012 Page 14 V. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD The recently-reported delay in the implementation of the Green Line Extension [a new estimated completion date of 2018-2020] is unacceptable, unlawful, unfair, and must be rejected by DEP. MassDOT and the MBTA should build the Green Line Extension now. MassDOT recognizes the anger, frustration, and disappointment evoked by the recent announcement of a delayed opening of the Green Line Extension, and deeply regrets that we will be unable to meet the SIP deadline (and public expectation) of passenger service on December 31, 2014. MassDOT has tried, in good faith and given the resources available to it, to advance the Green Line Extension project as quickly as possible and as far as possible, but the realities of the tasks needed to implement the project and the time required to do so have made it impossible to open the Green Line Extension to passengers on December 31, 2014. This is not a choice – MassDOT is in no way choosing to delay the Green Line Extension, nor is it shelving work on the project for any period of time – but a reflection of the most reasonable and realistic project schedule that we have been able to develop to date. At the same time, MassDOT and the MBTA are working to develop a new project implementation strategy, a strategy that could allow certain segments of the Green Line Extension to open while others are still under construction. This strategy may make possible a somewhat accelerated implementation timeline. Regardless of the exact date on which the project opens, MassDOT will lawfully fulfill the requirements of 310 CMR 7.36 to provide appropriate interim offset mitigation measures for any period of delay. MassDOT has broken its promise to the Green Line Extension corridor communities, and does not make decisions in a transparent way. MassDOT is painfully aware that the recent announcement about delays in implementing the Green Line Extension project has contributed to a sense of disillusionment among advocates for the Green Line Extension. More than many other infrastructure projects, the Green Line Extension benefits from enormous public support and passion, and MassDOT is sensitive to its responsibility to protect and nurture that support. The SIP projects are, in a sense, commitments between government and the public. But they are also negotiated agreements, developed privately between a small number of parties under the threat of lawsuit. The December 31, 2014 deadline for the Green Line Extension was a product of just such a negotiation, and it was from the beginning a very aggressive and optimistic goal for the implementation of a complex project that – while on the conceptual drawing board for several decades – was un-planned, unpermitted, un-designed, un-funded, and largely un-developed. MassDOT and the MBTA have advanced the Green Line Extension as quickly and transparently as has been possible, working through a huge number of issues related to implementing the first new urban extension of the MBTA system in 20 years. The Green Line Extension project is and will continue to be a priority of MassDOT and the MBTA, and we will continue to advance the project as quickly as we can, at the pace allowed by the resources we have at our disposal and the complexity and scope of the project. The revised Green Line Extension schedule came as a shock and disappointment, particularly because it diverges so greatly from previously published project schedules. Has MassDOT been intentionally deceiving the public with the information provided in the monthly status reports to the Boston Region Metropolitan Planning Organization on the SIP projects? No. 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 Massachusetts Department of Transportation January 11, 2012 Page 15 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.eot.state.ma.us/default.asp?pgid=content/transitCommitment&sid=about. MassDOT and the MBTA have an ‘incestuous relationship’ with the special interest groups involved with the planning for the Green Line Extension project. As a result, individuals who are not savvy about how best to make their voices heard and how best to influence the planning process get shut out. 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 the 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 the 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 is not focused on the needs of ‘regular people,’ but is instead focused on upper-income, highly educated people, and on the expansion needs of Tufts University. As discussed above, 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. MassDOT should make available a full project schedule, one that reflects the recently-announced delays. See www.greenlineextension.org/documents.html. MassDOT and the MBTA should make available the Risk Analysis, sponsored by the Federal Transit Administration, on which the revised Green Line Extension project schedule is based. See http://www.greenlineextension.org/documents/Risk_Report_081211.pdf. At this point, what government agency bears primary responsibility for the implementation schedule and approach for the Green Line Extension project? With the project now in engineering and moving towards construction, the MBTA has primary responsibility for the implementation of the Green Line Extension project. MassDOT supports the MBTA on issues of public policy and funding. The new Green Line Extension schedule means that all of the community input already provided on station designs will be lost in the years of delay. Massachusetts Department of Transportation January 11, 2012 Page 16 The new schedule for the implementation of the Green Line Extension project reflects not a stoppage of design work in the present but a longer than expected construction timeframe in the future. All of the design work that has been done over the past year, with close cooperation from many stakeholders and members of the general public, is continuing apace without delay or loss of momentum. MassDOT should consider phasing the implementation of the Green Line Extension project, with clear goals and milestones. MassDOT and the MBTA are currently considering a number of options for the incremental implementation of the Green Line Extension project. If successful, this could allow certain segments of the project to open for passenger service while other segments are still under construction. A phased approach presents certain risks and challenges, but offers the possibility of meaningfully accelerating construction. A decision to follow a path of phased implementation would require a complete redevelopment of the detailed project schedule, which would be released to the public. MassDOT should not phase the implementation of the Green Line Extension project. As noted above, MassDOT and the MBTA are pursuing a strategy of implementing the Green Line Extension project incrementally, in order to provide passenger service on some parts of the Extension while the others are still under construction. MassDOT and the MBTA do not have a clear strategy for completing the Green Line Extension project. As laid out in the project schedule available at www.greenlineextension.org/documents.html, MassDOT and the MBTA already have a complex and detailed approach to the completion of the Green Line Extension project. As mentioned above, the agencies are also currently considering using a phased approach to the implementation of the project, which could make possible limited passenger service while the remainder of the Extension is still under construction. Regardless of which approach is ultimately selected, a clear strategy for the design, construction, and start-up of the project has been and will continue to be developed by MassDOT and the MBTA. The Green Line Extension project is taking longer to implement than are other light rail projects elsewhere across the United States. It is difficult to draw accurate comparisons between and among transportation projects, even projects that may appear similar on their face. Some other light rail projects currently under development in the U.S. are in suburban areas, without the challenges of nearby historic structures, dense underground utilities, closely abutting private properties, or adjacent heavy rail lines. Some are stand-alone projects, without the challenge of needing to be seamlessly interoperable with an old and complicated trolley system. Some do not require the structures – the bridges, multi-level stations, and retaining walls – that the Green Line Extension requires. It is important to also note that the Green Line Extension project is, in essence, two construction projects wrapped into one: (1) the relocation of the existing Commuter Rail infrastructure and (2) the construction of the Green Line Extension. For all of these reasons, the Green Line Extension project may not be easily comparable to other light rail projects elsewhere in the U.S. The true cause of the recently-announced implementation delays is not the technical challenges facing the project, but the financial challenges. MassDOT should be honest with the public, stop unnecessarily prolonging the design process, and release a clear finance plan for the project. Massachusetts Department of Transportation January 11, 2012 Page 17 As has been frequently discussed, the financial situation facing the construction of public transit projects in the Commonwealth is enormously challenging. However, at the moment, funding is not an obstacle to the continued progress of the project: MassDOT and the MBTA have sufficient funds to continue to advance the project through the completion of environmental review and the continuation of engineering. The planning and design process for the Green Line Extension project to date has indeed been long, for which MassDOT takes responsibility, but it has also allowed the design team to benefit from intense public involvement and an intimate knowledge of the Green Line Extension corridor. MassDOT and the MBTA have never intentionally extended the design process to slow the project down – quite the contrary, in fact. The new Five-Year Capital Investment Plan for the Commonwealth provides more information on the currently-available state funding for the Green Line Extension project. See: http://www.mass.gov/bb/cap/fy2009/dnld/fy12capplan.pdf. MassDOT is prolonging the completion of the Green Line Extension project in order to defer or avoid having to fund the costs of the Extension. While there is no doubt that the costs of the Extension are substantial and will be a challenge for the Commonwealth to handle (both with and without federal funding), the projected schedule for the implementation of the Green Line Extension was in no way designed to reduce or put off the need to pay for the Green Line Extension project. Simply stated, even if MassDOT and the MBTA had unlimited funding for the Green Line Extension project immediately available, all of the tasks associated with the construction of the project could still not be complete before December 31, 2014. MassDOT should cease its effort to seek federal funding for the Green Line Extension project and instead fund the project entirely with Commonwealth funds. Avoiding the steps required by the New Starts process would allow the project to move faster. The New Starts process is, without question, a long and challenging process, and MassDOT and the MBTA dedicate substantial resources to completing the application requirements that are part of the process. However, the costs of the Green Line Extension project – currently estimated at approximately $1.2 billion – necessitate MassDOT and the MBTA to pursue any options for possible project funding other than simply relying on Commonwealth funds. The simple truth is that the costs of the Green Line Extension project are a substantial challenge for the capital program of the Commonwealth, which is responsible for funding the needs of not only transportation but all manner of public infrastructure. Until such time as that situation changes, MassDOT and the MBTA will continue to try to secure federal funding to help support the costs of the Green Line Extension project. The Commonwealth should convince the Obama Administration and the Federal Transit Administration to bypass the New Starts application requirements in order to allow construction to begin on the Green Line Extension project immediately. MassDOT has a positive partnership with the Federal Transit Administration, which is enormously helpful as we move through the New Starts application process. The process is rigorous, based on laws and regulations, and cannot be bypassed. MassDOT is committed to working through the process as it exists. The Commonwealth shouldn’t use bond funds – and pay their accompanying long-term debt service – to pay for the costs of the Green Line Extension project, which benefits only a small number of communities. Massachusetts Department of Transportation January 11, 2012 Page 18 The Green Line Extension is a SIP commitment, and the Commonwealth has taken on the obligation to implement the project and fully absorb the costs thereof, if need be. As discussed above, however, the costs of the project and relative scarcity of state bond funds has caused MassDOT and the MBTA to elect to pursue federal funding for the project. Should MassDOT and the MBTA fail to secure New Starts funding, the Commonwealth will then be responsible for the entirety of the costs of the Green Line Extension project. Bond funds are an appropriate source of funding for capital projects like the Green Line Extension, and are frequently used for projects in a single municipality or small number of municipalities. The Executive Office for Administration & Finance should be more involved and more visible as part of the development of the Green Line Extension project. The Executive Office for Administration & Finance (ANF) has many responsibilities for the smooth running of the Commonwealth. One of its responsibilities is the management of the Commonwealth’s capital plan, including the transportation agencies. The non-federal share of the Green Line Extension project – whatever it ultimately turns out to be – will be carried as part of the capital plan developed and managed by ANF. MassDOT and the MBTA work with ANF on a host of issues related to the Commonwealth’s transportation budget, including all of the SIP projects. That will continue to be the case as the projects move forward, but MassDOT and the MBTA will continue to be the lead agencies and those with the public responsibilities for the projects. MassDOT and the MBTA should reallocate funding from other projects to support the costs of the Green Line Extension project. As the Green Line Extension is a SIP commitment, MassDOT is obligated to advance the project as quickly and efficiently as is practicable. As the statewide transportation agency, MassDOT is also obligated to meet the divergent transportation needs of the entire Commonwealth, which includes continuing to fund projects other than the Green Line Extension. MassDOT spends money on highway projects that should be dedicated to the Green Line Extension project. As described above, the Green Line Extension is a legal commitment of the Commonwealth, and MassDOT is required to prioritize funding the implementation of the project. However, MassDOT has many other significant obligations as well, including safety and mobility improvements on modes other than public transit. Residents of many municipalities across the Commonwealth rely upon safe and efficient roads for their daily lives, and MassDOT tries hard to balance many competing demands in ways that are fair and that reflect our policy commitment to supporting sustainable communities. Furthermore, funding allocated to one mode of transportation – in this case, highways – is often restricted, and not applicable to other modes, meaning that funding cannot always be easily shifted among modal categories. The Massachusetts Port Authority should fund the costs of the Green Line Extension project. The Massachusetts Port Authority is responsible for Logan International Airport, Worcester Regional Airport, and the civilian aviation component of Hanscom Field. It is also responsible for the Port of Boston and other ancillary facilities. Massport is one of the agencies of MassDOT, and collaborates with other branches of MassDOT on a variety of transportation and economic development initiatives, including the MBTA Silver Line service to Logan Airport. The activities of Massport are primarily funded through fees collected from airline passengers – which are often prohibited from being used for non-aviation purposes – as well as from revenue generated by the leasing of Massport-owned land and the use of Massport-owned parking garages. The Massachusetts Department of Transportation January 11, 2012 Page 19 leadership of MassDOT and Massport work together to figure out how Massport can best contribute to the overall transportation goals of the Commonwealth, within existing constraints and given Massport’s primary responsibility to the management of safe and efficient airports. Funding the Green Line Extension project does not seem like a viable or prudent responsibility for Massport to assume at this point. See the response to a similar question on Pages 4-5 of this document. The new delays will add unnecessary costs to the Green Line Extension project. Construction costs are currently low; MassDOT and the MBTA should take advantage of that by accelerating the construction of the Green Line Extension. Each additional year required to complete the project will most likely add to the Green Line Extension bottom line through the escalation of the cost of labor, materials, private property, and other items. In addition, costs will be incurred by MassDOT for the implementation of interim offset mitigation measures for the ultimate period of delay. Added costs are one of the many reasons why MassDOT is attempting to reduce the project schedule as much as possible. Delays in the implementation of the Green Line Extension project are counter to the ‘GreenDOT’ goals of MassDOT. As articulated by the GreenDOT initiative, MassDOT is increasingly aware of and sensitive to the environmental and public health impacts of its projects and programs. The Green Line Extension project – the first major expansion of the Massachusetts urban public transit system in decades and a project which will substantially increase regional mobility options and decrease regional vehicle miles driven – is in many ways an embodiment of the GreenDOT philosophy. And while the delays in the implementation of the Green Line are regrettable, they in no way reflect a diminishment of commitment to the GreenDOT ideal or the weakening of the association between the GreenDOT concepts and the Green Line Extension project. Delays in the implementation of the Green Line Extension made it difficult for individuals, families, and small businesses to plan their lives and futures. MassDOT shares the public’s appreciation of the Green Line Extension’s potential to enhance the livability and attractiveness of residential and commercial neighborhoods along the project corridor. MassDOT is also well aware that public infrastructure investment decisions often guide private investment and inform decisions on where households and businesses choose to locate, expand, and become part of the local community. MassDOT is sympathetic to the uncertainty the current delay may cause at the individual, household, or business level—for example, strategizing over the best time to sell property in the corridor in order to maximize returns, or the decision on when to relocate to the corridor to take advantage of new commuting options and patterns. Nevertheless, no major, complex infrastructure project, particularly one located in such a dense urban environment as the Green Line Extension, can ever be “guaranteed” by a certain date. The deadlines in the SIP regulation represent ambitious goals towards which MassDOT and the MBTA have worked, but the SIP regulation also includes mechanisms for handling unforeseen delays. There are simply too many variables that are out of the control of the MBTA and MassDOT to pick a date many years in the future and be sure that it can be met. As work progresses on the Extension, MassDOT will continue to signal its intentions and understanding of project schedule and cost so that all stakeholders are kept abreast of project status—as was the case with the most recent Status Massachusetts Department of Transportation January 11, 2012 Page 20 Report. MassDOT invites and encourages all interested individuals, households, and businesses to continue to monitor this process The costs of building the vehicle maintenance facility, relocating Lechmere Station, and mitigating project impacts in the Brickbottom area should not be borne by the Green Line Extension project. The full scope of the Green Line Extension project is not simply the construction of the tracks and stations that will connect the Extension to the existing MBTA Green Line. It also includes the need to design and construct a new maintenance facility to store and care for the trolley cars that will run on the Extension; the need to relocate Lechmere Station to the far side of O’Brien Highway in order to facilitate the Extension to Somerville and Medford (costs once but no longer borne by a private developer); and the need to mitigate undue impacts from the Extension to the Brickbottom area. While there may be some opportunities to share some of these responsibilities with other entities, the majority of them will remain with MassDOT and will remain part of the totality that is the Green Line Extension project. These components are required for the project to be functional, and MassDOT can’t simply jettison them in hopes that someone else will pick them up. Without these components, a modern, efficient, and equitable Green Line Extension would not be possible. 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. MassDOT is committed to fully designing the extension of the Community Path, in collaboration with the City of Somerville and advocates for the Path, so that it is effectively integrated with the Green Line Extension. At the same time, MassDOT has repeatedly maintained that it is unable to take on the additional costs and responsibility associated with constructing the Community Path extension. This remains our policy. MassDOT has missed out on the opportunity to apply for American Recovery & Reinvestment Act (ARRA) and Transportation Investment Generating Economic Recovery (TIGER) funds for the extension of the Somerville Community Path, due to the slow pace of the project design. Given the interconnectedness of the proposed designs for the extension of the Somerville Community Path and the Green Line Extension, it is imperative that the two design efforts move in concert. As a result, the design of the extension of the Somerville Community Path must wait while the many complex design issues related to the Green Line Extension are resolved. Nevertheless, MassDOT collaborated with the City of Somerville on its application – ultimately unsuccessful – for TIGER funds and would be happy to collaborate on a similar effort in the future. The Green Line Extension project should be made ‘shovel-ready.’ For all of the reasons and in all of the ways described elsewhere in this document, MassDOT and the MBTA are working to implement the Green Line Extension project as quickly as possible. ‘Shovel-ready’ is not a particularly relevant concept for a project of the magnitude and complexity of the Green Line Extension, nor is it likely that the types of funding for which ‘shovel-readiness’ is a factor will be available to support the Green Line Extension. As an example, a recent $90 million funding application from the Commonwealth to the Transportation Investment Generating Economic Recovery program of the U.S. Department of Transportation – a funding program for which ‘shovel-readiness’ is an important evaluation criteria – netted a mere $10 million, reflecting the relative scarcity of federal ‘shovel-ready’ transportation funds. For more on the shovel-ready idea, see the response to a similar question on Page 10-11. Massachusetts Department of Transportation January 11, 2012 Page 21 Why was MassDOT able to complete the ‘Fast 14’ bridge replacement project so quickly and so smoothly? During the summer of 2011, MassDOT reconstructed 14 bridges on I-93 in the City of Medford as part of the Accelerated Bridge Program (St. 2008, c. 233). The complex project was enormously successful, and has received much well-deserved commendation. The Green Line Extension project, however, differs from the Fast 14 effort in many crucial ways: the type of construction work to be done, the type of structures to be installed, the interaction with abutting residents, the construction and procurement techniques available to be used, and the resources available to be dedicated. Of greatest importance: the construction of the Green Line Extension project differs from the Fast 14 project in that a number of bridges need to be widened – with their abutments relocated – to make space for the Green Line Extension. This was not a requirement for the Fast 14 construction, which needed only to replace the decks and girders of the bridges. In addition, the bridges of the Fast 14 project contained comparatively few utilities, whereas the Green Line Extension bridges carry major complex utilities. Fundamentally, building new projects like the Green Line Extension is different from repairing existing structures like the I-93 bridges. Why aren’t MassDOT and the MBTA more innovative and better able to embrace new ideas and approaches that could allow the Green Line Extension to progress more quickly? The project development process, as currently practiced by MassDOT and the MBTA, has evolved over time to reflect state and federal law, available resources and expertise, and lessons learned on past projects. Many of the steps in the process may appear slow or overly conservative, but they exist to protect the Commonwealth from unnecessary problems or costs. Innovation entails risk, and the public sector generally seeks to avoid risk in order to protect public monies and the public interest. The consolidation of various transportation agencies into MassDOT, however, has led to a new emphasis on innovation and creativity, and new techniques have been piloted in efforts like the Massachusetts ARRA program and the Accelerated Bridge Program Fast 14 project. The Green Line Extension project team is looking for opportunities to integrate any relevant concepts – as well as from other projects around the United States – from those efforts into the execution of the Green Line Extension project. MassDOT and the MBTA cite the Greenbush Commuter Rail Restoration project as an example from which lessons can be drawn for the Green Line Extension project. The Greenbush project – a suburban Commuter Rail project for which substantial land acquisitions was required – is significantly different from the Green Line Extension project, and makes a poor template from which to learn. For a number of reasons detailed below, MassDOT and the MBTA feel that Greenbush offers some useful insight from which the Green Line Extension team can learn, particularly that permits and private land should be obtained prior to the issuance of a Notice to Proceed for large Design/Build projects (of which Greenbush was one). Proceeding without full ownership of the relevant private parcels caused significant impacts to the cost and schedule of the Greenbush project. Without a doubt, the particulars of the Green Line Extension and the Greenbush Restoration project are different. However, they have a number of important similarities which provide useful comparisons and information for the Green Line Extension project team. In particular, both are major construction projects, both are rail projects, both require close coordination with multiple abutting municipalities, and both require land acquisitions for stations and rights-of-way. In addition, Greenbush – the last major public transit expansion project undertaken by the MBTA prior to the Green Line Extension project – was constructed Massachusetts Department of Transportation January 11, 2012 Page 22 using an alternative construction methodology, as the Green Line Extension project is also expected to be. The need to acquire land shouldn’t cause the construction of the Green Line Extension project to be delayed. MassDOT/MBTA should acquire any necessary land now – using its powers of eminent domain, if necessary - and move ahead with the project. For any government entity to acquire private land for a public purpose is a delicate and highly regulated undertaking. Private property owners have rights that must be respected, just as the public sector must protect the interests of the taxpayers by securing the best price for a piece of property. Furthermore, the vision of a public entity making unbridled and premature use of its powers of eminent domain is one which MassDOT and the MBTA do not embrace and work hard to avoid. Private property acquisitions must be done in a way that is procedurally and ethically correct. In the particular case of the Green Line Extension project, the fact that MassDOT is applying for federal funding means that we must follow the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, which requires that federal environmental review be complete prior to the acquisition of private property. This requirement exists to prevent public entities and project sponsors from purchasing property before the framework of a project is fully established and permitted. Because the Green Line Extension project has not yet received federal environmental approval, MassDOT/MBTA are unable to purchase any private property associated with the project. The vehicle support facility is not required by the SIP regulation. MassDOT should separate it from the Green Line Extension project, not allow it to impact the Green Line Extension implementation schedule, and pursue it as an independent project. While a vehicle support facility is not specifically identified in the SIP regulation, it is as crucial a part of the Green Line Extension project as are the many other project elements that are not listed by name in the regulation, including among others, stations, tracks, bridges, utilities, and catenary structures. Without a vehicle support facility proximate to the Green Line Extension, the MBTA will be unable to operate passenger service on the Extension that is efficient enough and cost-effective enough to be worthy of the more than $1 billion being invested by the Commonwealth in the Green Line Extension project. The proposed vehicle support facility will be used to house more Green Line vehicles than those to be solely dedicated to the Green Line Extension. Given that, the costs of constructing the new facility should be allocated across the entirety of the MBTA and not borne solely by the Green Line Extension project. MassDOT and the MBTA have discussed with the Federal Transit Administration the possibility of a cost-allocation of the type described here. However, given the intensity of the financial problems facing the MBTA, it seems more likely that the vehicle support facility will be able to be funded and built in total as part of the Green Line Extension project. MassDOT and the MBTA should scrap their plan to acquire private property to build a vehicle maintenance facility as part of the Green Line Extension project, and should instead use the existing Boston Engine Terminal/Commuter Rail Maintenance Facility for any Green Line Extension maintenance needs. This issue has been covered extensively in a number of reports and studies, and rejected as infeasible. For more information, please visit: http://www.greenlineextension.org/docs_vehSupp.html. Massachusetts Department of Transportation January 11, 2012 Page 23 The MBTA should shutter the Boston Engine Terminal/Commuter Rail Maintenance Facility, which offers no benefits to Somerville. The current Commuter Rail Maintenance Facility, located on the municipal boundary of Somerville and Cambridge, serves the entirety of the MBTA Commuter Rail system. Railroad facilities have been located at the site for more than a century, and provide crucial support for the regional transportation network. The MBTA is in no position at this time to close the Commuter Rail Maintenance Facility. MassDOT and the MBTA should begin the process of relocating the existing Commuter Rail tracks – needed to make room for the next Green Line Extension tracks – right now. The need to relocate the existing Commuter Rail tracks within the right-of-way that will eventually be shared by the Commuter Rail system and the Green Line Extension is a prerequisite to the full construction of the Green Line Extension. A number of important things still need to happen prior to relocating the Commuter Rail tracks: a number of bridges must be rebuilt (including the relocation of their abutments) in order to widen the corridor on the northeast side, utility (drainage/power/signal) work along the northeast side of the corridor needs to advance, and construction of retaining/noise walls along the northeast side of the corridor also needs to advance. These activities will allow for the relocation of the Commuter Rail infrastructure and the creation of a fully separate corridor for which the construction of the Green Line Extension can occur. Therefore, it is impossible for the relocation of the Commuter Rail tracks to begin immediately. MassDOT and the MBTA should construct minimal stations now – either temporary or permanent – in order to get passenger service running more quickly. The proposed design of the Green Line Extension stations is driven by a number of factors, including public input, the natural topography of the corridor, the need to provide full ADA accessibility, and MBTA operational and maintenance requirements, among other things. The stations will be more like subway stations than they will be like the aboveground Green Line stations currently found on the B and C Lines, primarily due to the need to provide fully accessible paths of travel in an area of substantial changes in grade between street level and the railbed. For all of these reasons, the engineering and construction of the stations is complex and still underway, and needs to be done apiece with the remainder of the Green Line Extension project. Current station concepts can be found at: http://www.greenlineextension.org/documents/ev_Assess/Volume_2_Figures.pdf. The design of Lechmere Station, particularly the adjacent pedestrian crossing of O’Brien Highway, is inadequate and uncreative. The design of all of the Green Line Extension stations, including the relocated Lechmere Station, is still a work in progress. Given the limited land available for the relocated Lechmere Station and the complexity of integrating a busy busway and an elevated structure on which the Green Line will run, the design of a relocated Lechmere Station has proven to be especially tricky. The Green Line Extension team is continuing to work on the design, however. Likewise, the redesign of O’Brien Highway in the area of a relocated Lechmere Station continues to be refined by the NorthPoint development team (HYM Investment Group), which is the primary responsible party for the design and construction of the improvements to O’Brien Highway in the vicinity of the relocated Lechmere Station. HYM, MassDOT, the MBTA, and the City of Cambridge are all Massachusetts Department of Transportation January 11, 2012 Page 24 working closely to create a pedestrian environment that is acceptable to the abutting neighborhoods and can best serve both the Green Line Extension and the NorthPoint site. The Green Line Extension should include a Green Line station at the Twin City Plaza. Although it would provide benefits for those using the Plaza, MassDOT and the MBTA feel, on balance, that a station at Twin City Plaza is not warranted or fundable at this point. Given the very close proximity to a relocated Lechmere Station, a Twin City Plaza station would have limited ridership and would not be able to justify the cost of siting, designing, and constructing the station. Furthermore, the complexity of the track design in that particular area – within site of the rail junction at Brickbottom – would be substantial and challenging. All of this being said, a station could, conceivably, be constructed at Twin City Plaza or at the neighboring shopping center at some point in the future. The Green Line Extension should be built to connect with the MBTA Commuter Rail at West Medford. The boundaries of the current Green Line Extension project – Lechmere Station to College Avenue in Medford and Union Square in Somerville – were established through a long planning process that examined a number of different alternatives for both mode and routing. An early stage of the planning process examined the possibility of extending the Green Line to West Medford, but opposition from local officials combined with the technical and regulatory challenges of crossing the Mystic River persuaded MassDOT to terminate the Extension on the east side of the Mystic River. MassDOT and the MBTA should insist that no Transit-Oriented Development be allowed at the location of the Green Line Extension station at College Avenue. Land use, zoning, and real estate development decisions are the purview of local municipalities, and neither MassDOT nor the MBTA have jurisdiction over them. Concerns about land use decisions in the area of the future College Avenue station should be directed to the City of Medford. MassDOT and the MBTA should eliminate the Drill Track. The the Drill Track is an essential piece of transportation infrastructure and cannot be eliminated. The Drill Track is used to move trains within the Boston Engine Terminal area, to stage trains before they are allowed into the Boston Engine Terminal, and as a safety track for runaway trains. Most often, the Drill Track is used to pull locomotives and/or strings of coaches from the BET storage yard and push them into the various shops within the BET building and then back into the yard after the work is complete. The Drill Track allows these operations to occur independent of the Fitchburg Commuter Rail Main Line and the Lowell Commuter Rail Main Line operations, allowing these key commuter lines to operate without interruption. Having this ability is vital to safe and effective MBTA operations. The current design of the Drill Track is integrated with the Green Line Extension in such a way that the Drill Track has as minimal an impact as possible on the surrounding structures and area. The MBTA has worked with the immediate abutters to finalize designs for the Drill Track and all of the viaducts and track structures in the Red Bridge/Brickbottom area. Geotechnical and structural design work based on the current design is currently proceeding. MassDOT and the MBTA should cease any road-related work associated with the Green Line Extension project, and focus solely on the rail-related elements of the projects. In particular, MassDOT and the Massachusetts Department of Transportation January 11, 2012 Page 25 MBTA should stop planning and engineering streets, bridges, sidewalks, and the so-called Urban Ring Bridge. Infrastructure that benefits cars has no place in a public transit project. The Green Line Extension project is primarily a public transit project, dedicated to expanding the existing MBTA network and providing greater opportunities for non-auto mobility throughout both the Green Line Extension corridor and the Boston Region as a whole. Nevertheless, any transportation investment of the size and scope of the Green Line Extension requires interventions throughout the transportation network, and the improvements to roads and bridges in the Green Line Extension corridor are required to allow the Green Line Extension to function (this is particularly true for the bridges, some of which must be reconstructed to allow for the widening of the corridor and the ultimate construction of the Extension). Other roadoriented improvements are designed to make the stations fully accessible by pedestrians, particularly given the topography of the corridor. The Urban Ring/NorthPoint Bridge is a proposed bridge connection between the NorthPoint area of Cambridge and the Inner Belt area of Somerville. The bridge, which has not been designed, has been conceived as a multimodal connection between Cambridge and Somerville, important for improving access to and connectivity of the Inner Belt area. MassDOT and the MBTA are committed to not engineer the Green Line Extension in such a way that it will make impossible a future NorthPoint Bridge, but the design and construction of the bridge is not part of the Green Line Extension project. MassDOT and the MBTA should plan for the Urban Ring/NorthPoint Bridge. As noted above, MassDOT and the MBTA are not including the design of the Urban Ring/NorthPoint Bridge as part of the Green Line Extension project. The ridership projections prepared by MassDOT and the MBTA for the Green Line Extension project are inaccurate. Many more people will use the Green Line Extension than are being predicted by your models. Every person who rides the Green Line Extension will leave behind a car in order to do so. The Green Line Extension will be a very strong part of the MBTA system. This is not correct. Future ridership on the Green Line Extension project was projected using the most professional and current planning assumptions, which have been reviewed and accepted by the Federal Transit Administration and are used elsewhere around the United States. The ridership projections suggest that the Green Line Extension will be well-used, and the analysis projected that several thousand auto drivers will switch to the Green Line as a result of the construction of the Extension. However, it also indicates that some Green Line Extension riders will leave other modes of public transit – particularly the MBTA bus system – in favor of the Extension. This does not diminish the value or importance of the Green Line Extension, however. The ridership projections prepared by MassDOT and the MBTA for the Green Line Extension project are inaccurate. Many fewer people will use the Green Line Extension than are being predicted by your models. See above. Massachusetts Department of Transportation January 11, 2012 Page 26 CTPS CENTRAL TRANSPORTATION PLANNING STAFF Staff to the Boston Region Metropolitan Planning Organization DRAFT MEMORANDUM To: Scott Hamwey Massachusetts Department of Transportation From: Scott Peterson Re: Fairmount Line: SIP Mitigation Targets and Strategies November 29, 2011 BACKGROUND The Central Transportation Planning Staff (CTPS) was asked by the Massachusetts Department of Transportation (MassDOT) to support a transportation demand and air quality analysis of the Fairmount Line as part of a work program that was created in December of 2010 and approved on March 17, 2011. This analysis was used to determine the emissions target for having a delay in opening four new rail stations on the Fairmount Line and analyzing mitigation strategies to offset the delays. This analysis is important because the Fairmount Line project is a legal commitment under the State Implementation Plan (SIP), and therefore any delays in completing the rail stations would have legal ramifications. The SIP requirements related to the Fairmount Line are as follows: Before December 31, 2011, construction of the following facilities shall be completed and opened to full public use: Fairmount Line improvements consisting of enhancements of existing stations including, without limitation: platform extensions; improved lighting and improved access; a new station in the general location of Four Corners, and a new station in each of the neighborhoods of Dorchester, Mattapan and Roxbury; and bridge upgrades and other measures to improve service and increase ridership. In the May 2010 SIP Status Update to the Federal Transit Administration, MassDOT acknowledged that there would be a delay in completing the four new rail stations by the December 2011 deadline, requiring the analysis described below. The four new rail stations are Four Corners, Talbot Avenue, Newmarket, and Blue Hill Avenue, and their locations on the Fairmount Line are shown in Figure 1. The SIP identifies emissions from three pollutants: carbon monoxide (CO), volatile organic compounds (VOC), and nitrogen oxides (NOx). APPROACH MassDOT will need to mitigate the delay of the opening of the four new rail stations, starting in January 1, 2012, with a set of projects and/or programs (offsets) that will result in emissions reductions for the three key pollutants (reduction targets) equal to or greater than the reductions that would result after opening the four new stations. The approach used in this analysis, State Transportation Building • Ten Park Plaza, Suite 2150 • Boston, MA 02116-3968 • (617) 973-7100 • Fax (617) 973-8855 • TTY (617) 973-7089 • ctps@ctps.org FIGURE 1 Map of the Study Area Scott Hamwey, MassDOT 3 November 29, 2011 which is similar to that used in previous CTPS studies, consists of two steps. The first step was to quantify the reduction targets for the three key pollutants. The targets were developed by creating two representations of an average spring weekday transportation system and travel flows in eastern Massachusetts for 2012 using the Metropolitan Planning Organization’s (MPO) regional travel demand model set. These two representations of the transportation system and travel flow were identical except that one included the four new stations and a service plan that served them and the other representation excluded them. The regional model set was used to determine the emissions reductions associated with auto diversions from building four new stations. The second step involved testing the potential emissions reductions of several mitigation strategies developed in discussions with MassDOT using the regional model set. The scenarios that were tested in order to develop the targets and identify strategies that could be implemented by January 1, 2012, are listed below: Scenario A: Four new Fairmount Line stations Scenario B: No new stations, with existing conditions Scenario C: Provide a new weekday service between Andrew Square and Boston Medical Center Scenario D: Reduce Fairmount and Readville commuter rail station fares to $1.70 Scenario E: Increase weekday peak-period headways on Fairmount Line Scenario F: Implement new weekday Roxbury-Dorchester-Mattapan express bus service Scenario G: Improve off-peak and weekend headways on the Fairmount Line Scenario H: Initiate Youth Pass program Scenario I: Improve weekday bus Route 31 headways Scenario J: Extend bus Route 29 from Jackson Square to Ruggles on weekdays Scenario K: Improve weekend bus Route 29 and Route 31 headways Scenario L: Improve weekday Red Line headways Scenario M: Improve weekend Red Line headways MODEL METHOD The regional travel demand model set used in this study is based on procedures and data that have evolved over many years. The model set is used to simulate existing travel conditions and to forecast future-year travel on the entire transportation system spanning eastern Massachusetts, for the transit, auto, and walk/bike modes. The model set simulates the modes and routes of trips between areas in the modeled region. Population, employment, number of households, auto ownership, highway and transit levels of service, downtown parking costs, auto operating costs, and transit fares are some of the most important inputs that are used in applying the model to a real-world situation. These inputs are constantly updated so that the model set simulates current travel patterns with as much accuracy as possible. The MPO regional travel model set has been used in a number of recent modeling activities, such as the Green Line Extension New Starts Study, the South Coast Rail Study, the Casey Overpass Study, and I-93 Tri-Town Interchange Study. Scott Hamwey, MassDOT 4 November 29, 2011 The model set is calibrated to a base year, in this case 2009. Once the model set satisfactorily replicates existing conditions, it is used for forecasting. The future year in this study was 2012. The reduction targets and offsets were tested using that year of analysis and the corresponding land use and transportation system. Some important features of the model set are listed below. • The modeled area normally encompasses 164 cities and towns in Eastern Massachusetts. The modeled area is divided into 2,727 internal transportation analysis zones (TAZs). There are 146 external load points around the periphery of the modeled area that allow for travel between the modeled area and adjacent areas of Massachusetts, New Hampshire, and Rhode Island. • The model set was estimated using data from a Household Travel Survey, External Cordon Survey, Transit Passenger Surveys, the 2000 U.S. Census data, an employment database for the region, and a vast database of manual counts of transit ridership and traffic volume data collected over the last decade. CTPS obtained the most current transit ridership data and highway volumes available to help calibrate the model for use in this study. • The transportation system is divided into three primary modes. The transit mode contains all the MBTA rail and bus lines, commuter boat services, regional transit agencies, and private express bus carriers. The auto mode includes all of the express highways, principle arterials, many minor arterials and local roadways. Walk/bike trips are also examined and are represented in the nonmotorized mode. The nonmotorized mode is represented as a network of roadways with sidewalks, bike trails, and major walking paths. • The model is set up to examine travel on an average weekday in the spring for four time periods. The time periods are AM (AM peak period), 3 hours; MD (midday), 6 hours; PM (PM peak period), 3 hours; and NT (nighttime), 12 hours. The model set is based on the traditional four-step urban transportation planning process of trip generation, trip distribution, mode choice, and trip assignment. This process is used to estimate the daily transit ridership and highway traffic volumes, based on changes to the transportation system. The model set as it relates to transit takes into consideration data on service frequency (how often trains and buses arrive at any given transit stop), routing, travel time, transit parking availability, and fares for all of the transit services. The model set for the roadway system is sensitive to roadway locations, connectivity, length, speeds, capacity, lanes, truck exclusions, turn prohibitions, and tolls. Results from the computer model provide us with detailed information relating to transit ridership demand and roadway travel. A schematic representation of the modeling process is shown in Figure 2. Scott Hamwey, MassDOT 5 November 29, 2011 Scott Hamwey, MassDOT 6 November 29, 2011 The Four-Step Model 1. Trip Generation: In the first step, the total number of trips produced by the residents in the modeled area is calculated using demographic and socio-economic data. Similarly, the numbers of trips attracted by different types of land uses such as employment centers, schools, hospitals, and shopping centers, are estimated using land use data and trip generation rates obtained from travel surveys. All of these calculations are performed at the TAZ level. 2. Trip Distribution: In the second step, the model determines how the trips produced and attracted would be matched throughout the region. Trips are distributed based on transit and highway travel times between TAZs and the relative attractiveness of each TAZ. The attractiveness of a TAZ is influenced by factors such as the number and type of jobs available, the size of schools, hospitals, and shopping centers. 3. Mode choice: Once the total number of trips between all combinations of TAZs is determined, the mode choice step of the model splits the total trips among the available modes of travel. The modes of travel are walk, auto and transit. To determine what proportions of trips each mode receives, the model takes into account the travel times, number of transfers required, and costs associated with these options. Some of the other variables used in the mode choice are auto ownership rates, household size, and income. 4. Assignment: After estimating the number of trips by mode for all possible TAZ combinations, the model assigns them to their respective transportation networks. Reports showing the transit and highway usage can be produced as well as the impact of these modes on regional air quality. The mobile-source emissions of alternative transportation scenarios can be forecasted and analyzed using the MPO’s regional travel demand model set in conjunction with U.S. Environmental Protection Agency (EPA) emissions rates that are developed by the EPA’s MOBILE6.2 software. The model estimates traffic volumes, average highway speeds, vehicle miles traveled, and vehicle hours traveled. The EPA’s MOBILE6.2 software develops emission factors by pollutant and speed for different years based on, among other things, assumptions about fleet fuel efficiency. Using these tools, reasonable estimates of emissions from mobile sources can be developed for various years and network conditions. The procedure described above is used to estimate emissions from cars and trucks for carbon monoxide (CO), nitrogen oxides (NOx), and volatile organic compounds (VOC). TRANSIT SERVICE PLANS The background transportation projects and plans included in this analysis were based on the best information available at the time of the study. The transit service plans for all of the transit modes and services except the Fairmount Line were based on 2011 schedules. The Fairmount Line was undergoing tie replacement in 2011, which impacted headways and runtimes, so the schedules used in the study for all scenarios except A were from 2010. Scenario A used the same headways, but added additional run-time to account for the additional stations. Scenarios A and Scott Hamwey, MassDOT 7 November 29, 2011 B were used to develop the targets, while scenarios C through M represented various mitigation strategies that MassDOT requested CTPS examine. A. Fairmount commuter rail scenario with four new stations B. Fairmount commuter rail scenario without four new stations C. Provide a new service between Andrew Square and Boston Medical Center: The travel time for the new line was assumed to be the same as the run time of the CT3 bus route between Andrew Station and Boston Medical Center. There were no intermediate stops. The total travel time between the two ends was assumed to be 8 minutes. The headways used were: AM – 20 minutes; PM – 20 minutes; MD and NT – no service. D. Reduce Fairmount and Readville commuter rail station fares: Fairmount Station is currently in fare zone 1 and Readville is currently in fare zone 2, which results in an adult cash fare of $4.25 and $4.75, respectively. This strategy would put both stations in fare zone 1A, an adult cash fare of $1.70. E. Increase peak-period headways on the Fairmount Line: In the AM and PM peak periods, headways would be improved, from every 30 minutes to every 20 minutes. F. Implement new Roxbury-Dorchester-Mattapan express bus service (Route 29 and Route 31): Travel times and routing for both bus routes would stay the same as in the current condition. The headways used for Route 29 are: (AM – 10 minutes, MD – 20 minutes, PM – 10 minutes, and NT: – 20 minutes, while bus Route 31 headways would be: AM – 5 minutes, MD – 10 minutes, PM – 5 minutes, and NT – 10 minutes. G. Increase off-peak-period and increase weekend headways on the Fairmount Line: Operate service that is consistent with the MBTA’s service delivery policy. H. Initiate Youth Pass program: A $29.50 monthly Youth Pass program was assumed; it would be available to teenagers age 18 and under. Since the MPOs regional model set does not divide users in the necessary age groups for this strategy, a spreadsheet analysis was conducted using fare data provided by the MBTA. I. Expand service on bus Route 31 between Mattapan and Forest Hills. The headways on Route 31 are improved from 7 minutes to 5 minutes in the AM, from 15 minutes to 10 minutes in the MD, from 8 minutes to 5 minutes in the PM, and from 20 minutes to 10 minutes at NT. No changes to the run time or fares are proposed with this option. J. Extend the bus Route 29 from Mattapan and its current terminus at Jackson Square to Ruggles Station, on the Orange Line. The additional run time would be consistent with bus Route 22, which traverses this same route K. The previous analysis of bus Routes 29 and 31 focused on an average weekday, but since this is when there is the heaviest utilization of buses and operations limit expansion, it was decided that weekend service improvements should be analyzed for this study. For Scott Hamwey, MassDOT 8 November 29, 2011 bus Route 29, this consisted of improving the MD and PM headways on Saturday, with 30-minute headways. On bus Route 31, the MD and PM headways would be improved from 13 minutes to 10 minutes. L. Both Red Line branches currently operate on headways of 14 minutes all day long on Saturday and 15.5 minutes on Sunday. Saturday and Sunday would improve by 2.5 minutes, with 11.5-minute headways on Saturday and 13-minute headways on Sunday. M. Red Line weekday MD and NT headways would improve in this scenario. The headway would go from 13 to 11.5 minutes in the MD, and from 12 to 11.5 minutes at NT. RESULTS After the base year was calibrated, the next step was to identify the reduction targets associated with the Fairmount stations for 2012 (shown in Table 1). Subtracting the air quality benefits from the scenario having the four new stations (Scenario A) from the one without (Scenario B) resulted in the reduction targets for an average weekday in 2012, the figures shown in the table in bold after Scenario B: 0.34 kg of VOC, 0.67 kg of NOx, and 10.26 kg of CO. The air quality benefits shown are purely a result of auto diversions—approximately 80 round-trips or 160 oneway trips, which result in a reduction of 1,000 vehicle-miles of travel (VMT) in the region. Based on feedback from stakeholders and an examination of 11 offset strategies (shown in Table 1), two were identified as collectively meeting the emission targets, being operationally feasible, not changing a fare policy, and being implementable by January 1, 2012: • • Scenario C: A new bus service between Andrew Square and Boston Medical Center Scenario I: Improving headways on bus Route 31 Therefore, Scenarios C and I are proposed for implementation. The reasons for eliminating the other scenarios from consideration are described below: • • • • • • • • • Scenario D was eliminated due to a conflict with fare policies. Scenario E was eliminated due to operational constraints. Scenario F was eliminated due to not meeting the proposed schedule for implementation. Scenario G was eliminated due to operational constraints. Scenario H was eliminated due to a conflict with fare policies. Scenario J was eliminated due to the small emissions benefits it produced. Scenario K was eliminated due to the small emissions benefits it produced. Scenario L was eliminated due to not meeting the proposed schedule for implementation. Scenario M was eliminated due to not meeting the proposed schedule for implementation. Scott Hamwey, MassDOT 9 November 29, 2011 TABLE 1 Results of Emission Targets and Mitigation Strategies Scenario A B C Description VOC (kg) NOx (kg) CO (kg) Four New Fairmount Line Stations 42,071.40 90,851.30 1,256,789.40 No New Stations, with Existing Conditions 42,071.74 90,851.97 1,256,799.66 Target (A minus B ) -0.34 -0.67 -10.26 Provide a Shuttle Bus Service from Andrew Square to Boston Medical Center -0.25 -0.55 -9.21 D Reduce Fairmount and Readville Commuter Rail Fares to $1.70 (a) (a) (a) E Increase Peak-Period Headways on Fairmount Line (b) (b) (b) F Implement Proposed Roxbury-Dorchester-Roxbury Express Bus Service (d) (d) (d) G Improve Off-Peak and Weekend Headways on Fairmount Line (b) (b) (b) H Youth Pass Program (a) (a) (a) I Improve Bus Route 31 Headways -0.17 -0.37 -6.84 J Extend Bus Route 29 from Jackson Square to Ruggles Station (c) (c) (c) K Improve Weekend Headways on Bus Route 29 and Route 31 (c) (c) (c) L Improve Weekday Red Line Headways (d) (d) (d) M Improve Weekend Red Line Headways (d) (d) (d) Notes: Mobile-source emissions are for passenger vehicles on an average weekday in 2012, estimated using MOBILE 6.2 The scenarios with no emission values shown: the letters in the table indicate that the scenario either: (a) was inconsistent with an existing or proposed MBTA fare policy; (b) could not be implemented due to operational constraints; (c) produced minimal emissions benefits, which would require it to be packaged with numerous other scenarios; or (d) could not be implemented by January 1, 2012. SAP/sap July 27, 2011 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 attached the annual Status Report on transit projects required under the revised State Implementation Plan. We appreciate your allowing us an extension on our submittal of this Report. The Status Report will be made publicly available on the MassDOT website at www.massdot.state.ma.us. If you have any questions or concerns or if we can be of assistance during the public review period for this document, please do not hesitate to contact Katherine Fichter of my staff at (617) 973-7342 and katherine.fichter@state.ma.us. Sincerely, David J. Mohler Executive Director Office of Transportation Planning Leading the Nation in Transportation Excellence Ten Park Plaza, Suite 3170, Boston, MA 02116 Tel: 617-973-7000, TDD: 617-973-7306 www.mass.gov/massdot Massachusetts Department of Transportation Massachusetts Bay Transportation Authority State Implementation Plan – Transit Commitments 2011 Status Report Submitted to the Massachusetts Department of Environmental Protection July 27, 2011 For questions on this document, please contact: Katherine S. Fichter Massachusetts Department of Transportation Office of Transportation Planning 10 Park Plaza, Room 4150 Boston, Massachusetts 02116 katherine.fichter@state.ma.us INTRODUCTION This report is submitted by the Massachusetts Department of Transportation (MassDOT), in conjunction with the Massachusetts Bay Transportation Authority (MBTA), to the Massachusetts Department of Environmental Protection (DEP) in order to fulfill the requirements of 310 CMR 7.36(7), Transit System Improvements. Below is a project description and status information for each of the public transit projects required under the amended State Implementation Plan (SIP). As in previous Status Reports, MassDOT is no longer reporting on Blue Line Platform Lengthening and Station Modernization and the Greenbush Commuter Rail Restoration. Both of those projects have been completed and MassDOT believes that the relevant commitments have been met. As always, MassDOT hopes to make the annual Status Report process one of iterative improvement, and looks to DEP and to the public for comments and other suggestions to refine its efforts. MassDOT Office of Transportation Planning July 27, 2011 Page 1 I. FAIRMOUNT LINE IMPROVEMENT PROJECT SIP Requirement Before December 31, 2011, construction of the following facilities shall be completed and opened to full public use: Fairmount Line improvements consisting of enhancements of existing stations including without limitation: platform extensions; improved lighting and improved access; a new station in the general location of Four Corners, and a new station in each of the neighborhoods of Dorchester, Mattapan and Roxbury; and bridge upgrades and other measures to improve service and increase ridership (the Fairmount Line project). EOT 1 shall meet the following interim deadlines for the Fairmount Line Project: A. One year from the effective date of this regulation (December 1, 2006), develop a Request for Proposals for a design consultant, complete the competitive procurement process, and issue a notice to proceed for a design consultant. Done B. Within two years following the issuance of a notice to proceed, complete final design, apply for all necessary permits and grants, file any required legislation, and initiate all public and private land acquisition. Done (for all elements of the project except for Blue Hill Avenue Station) Project Description The 9.2-mile Fairmount commuter rail line runs from South Station, currently serves four stations (Uphams Corner, Morton Street, Fairmount, and Readville) in the communities of Dorchester, Mattapan, and Hyde Park, and terminates in the Readville section of Boston. The line, which uses right-of-way entirely owned by the MBTA, also includes 41 bridges. It is the only commuter rail line that exclusively serves neighborhoods within the City of Boston, but ridership has historically been low and passenger facilities along the line do not meet modern standards. The Fairmount Line Improvement Project includes the rehabilitation of the existing Uphams Corner and Morton Street Stations, construction of four new stations – Newmarket, Four Corners, Talbot Avenue, and Blue Hill Avenue – reconstruction of six existing railroad bridges (located over Columbia Road, Quincy Street, Massachusetts Avenue, Talbot Avenue, Woodrow Avenue, and the Neponset River), and construction of a new interlocking and upgraded signal system (required to advance the bridge reconstruction work). These upgrades will enhance future service, allowing for increased frequency on the line. Planning Conformity Throughout the life of the project, improvements to the Fairmount Line have been included in all relevant transportation planning documents, including the MBTA Program for Mass Transportation and the Regional Transportation Plans of the Boston Region MPO. 1 EOT is the predecessor to the legislatively-created Massachusetts Department of Transportation (MassDOT). For the purposes of referencing 310 CMR 7.36(7) Transit System Improvements of the SIP, this report will continue to use the EOT designation. However, the MassDOT designation will be used for all other language or text contained in this report. MassDOT Office of Transportation Planning July 27, 2011 Page 2 Project Status The sections below describe the current status of the different elements of the Fairmount Line Improvement Project. Systems Necessary upgrades to interlocking and signal systems have been completed and are currently in use, allowing for the reconstruction of structurally deficient bridges along the Fairmount Line. Bridges A construction contract to replace the Columbia Road, Quincy Street, and Massachusetts Avenue bridges was awarded in October of 2007, with the construction work completed in 2010. The design of the Talbot Avenue, Woodrow Avenue, and Neponset River bridges is completed and construction is beginning (see below). The Talbot Avenue and Woodrow Avenue bridges will be constructed under the same construction contract as Talbot Avenue Station, while three Neponset River bridges are being advertised separately (see below). The project includes replacing three bridges over the Neponset River. Bids for replacement of the northernmost Neponset River Bridge (just north of Fairmount Station) were opened on November 3, 2010. The low bidder was Barletta Construction. Contract authorization was given at the January 2011 MBTA Board of Directors meeting, and the MBTA issued a notice to proceed on February 11, 2011. The project duration is approximately 30 months and is currently 17% complete, with project completion to occur in August 2013. The two southern Neponset River Bridges (one just south of Fairmount Station, and one just north of Readville Yard) were packaged with environmental remediation of the Yard 5 area. Bids for this group of projects were opened on October 13, 2010. The low bidder was S&R Construction Enterprises, with contract award authorization given at the January 2011 MBTA Board of Directors meeting. The notice to proceed for this contract was issued March 1, 2011. The project duration is approximately 30 months and is currently 17% complete, with project completion to occur in September 2013. Existing Stations The MBTA held a station-opening at Uphams Corner on January 23, 2007. The reconstruction of Morton Street was celebrated at a station-opening on July 17, 2007. New elements at both stations include extended high-level passenger platforms, accessible walkways, canopies, benches, windscreens, signage, bicycle racks, variable messages signs, lighting, and landscaping. Work at both stations is now complete. New Stations Four Corners Station is under construction and is now 67% complete. A notice to proceed was issued to S&R Construction Enterprises, Inc. on January 28, 2010. Four Corners Station has experienced delays due to unforeseen geotechnical conditions encountered during the excavation work undertaken for the construction of the outbound platform at Washington Street. The revised MassDOT Office of Transportation Planning July 27, 2011 Page 3 substantial completion date for Four Corners Stations is September 2012 with final completion to occur in November 2012. The construction of Talbot Avenue Station and the Talbot and Woodrow Avenue Bridges Rehabilitation projects were advertised and opened for bids in May 2010. The MBTA Board of Directors authorized a construction contract to Barletta Construction on September 10, 2010 and the notice to proceed was issued on November 22, 2010. The construction period is expected to last approximately twenty-six months, with substantial completion of the station and the bridges in October 2012 and anticipated final completion of work by January 2013. Construction is currently 38% complete. A groundbreaking was held on June 7, 2011. Construction of Newmarket Station was awarded to S&R Construction Enterprises at the MBTA Board of Directors meeting on October 6, 2010. The MBTA issued a notice to proceed on December 13, 2010. Construction is currently 18% complete. The MBTA anticipates substantial completion in December 2012 with final completion of work to occur in February 2013. The proposed Blue Hill Avenue Station has been the subject of significant community controversy over the past two years. In early 2009, after design work for the station was well underway (60% design), concerns about negative impacts to surrounding residences were raised by a small number of abutters to the proposed station, which at the time was proposed to have two side platforms. In an effort to address these concerns, the MBTA conducted a new analysis of alternative station locations. This additional analysis determined that at least one alternative location (River Street) was infeasible due to track curvature, and that the two other alternative locations (north of Blue Hill Avenue and south of Cummins Highway) would have greater impacts to abutting residential properties than would the original design, while serving fewer riders at increased cost. The MBTA then developed an additional alternative that made use of a centerisland platform at the original station site, therefore mitigating some abutter concerns by locating the platform further from homes and backyards; the MBTA also developed a conceptual design for this proposal. The MBTA continued to encounter opposition from some abutters, however, who question the need for and appropriateness of any commuter rail station in this location. The MBTA responded to the immediate neighborhood concerns by completing an additional analysis of noise impact and mitigation measures. After this further review, the MBTA and MassDOT made a final determination on the Blue Hill Avenue station in May 2011. Station design will proceed at the original site with the center-island platform concept. The necessary redesign of the station is underway, and 100% design completion is anticipated by the end of 2011. The project is tentatively scheduled for construction advertisement in February 2012, with anticipated construction to start in May 2012. This anticipated schedule will be revisited as the design of the station evolves. Project Funding In August 2007, MassDOT and the MBTA executed a contract to transfer approximately $39 million in bond funds from MassDOT to the MBTA to support project costs of (1) signal work, (2) reconstructing the Columbia Road, Quincy Street, and Massachusetts Avenue Bridges, (3) MassDOT Office of Transportation Planning July 27, 2011 Page 4 designing the Talbot Avenue, Woodrow Avenue, and Neponset River Bridges, and (4) designing the Newmarket, Talbot, and Blue Hill Avenue Stations. A supplemental funding agreement providing $23,756,574 in Commonwealth bond funding was executed in June 2009 in order to advance construction of the station at Four Corners. An additional funding agreement, approved in June 2011 by the MBTA Board of Directors in the amount of $61,616,500, has allowed the remaining stations and bridges, including Blue Hill Avenue, to advance. SIP Requirement Status Community concerns (described above) regarding the construction of a station at Blue Hill Avenue, as well as construction challenges throughout the Fairmount Line, have resulted in a delay of the overall Fairmount Line Improvement Project beyond the December 31, 2011 SIP deadline. MassDOT anticipates that the Four Corners, Talbot Avenue, and Newmarket Stations and their attendant bridges and other infrastructure will be completed incrementally in 2012-2013, beyond the SIP deadline. A reliable completion date for Blue Hill Avenue station continues to be unknown at this time, although the MBTA is working to advance the project as quickly as possible. MassDOT recognizes that this delay triggers the Project Delay component of the SIP regulation and that MassDOT therefore needs to prepare a Petition to Delay and an Interim Emission Offset Plan, to be implemented for the duration of the delay. Both are appended to this Report. MassDOT Office of Transportation Planning July 27, 2011 Page 5 II. CONSTRUCTION OF 1,000 NEW PARKING SPACES SIP Requirement Before December 31, 2011, construction of the following facilities shall be completed and opened to full public use: 1,000 new park and ride parking spaces serving commuter transit facilities within the 101 cities and towns constituting the Boston Metropolitan Planning Organization. EOT is also bound by the following interim deadlines: On or before 18 months following the effective date of the regulation (December 1, 2006), MassDOT must develop a request for proposals for a design consultant, complete the competitive procurement process, and issue a notice to proceed. Done Within 15 months of the completion of the above requirements, EOT must complete conceptual design and file an Environmental Notification Form. Done (as appropriate for the different projects) On or before two years after MEPA’s issuance of a scope for a Draft Environmental Impact Report or a Single Environmental Impact Report, EOT must complete preliminary design and file a DEIR or SEIR. Not appropriate for the projects On or before one year after MEPA’s issuance of a scope for a Final Environmental Impact Report, EOT must file an FEIR. Not appropriate for the projects On or before 18 months after MEPA’s issuance of a certificate on an FEIR or an SEIR, EOT must complete final design, apply for all necessary permits, funds and grants, file any required legislation, and initiate all public and private land acquisition. Done (as appropriate for the different projects) Upon completion of all of the above milestones, DEP and EOT shall establish a schedule for project construction and deadlines for project completion. Underway Project Description To encourage commuters and other travelers to make use of the public transit network for trips into downtown Boston and to other locations, the MBTA will construct 1,000 new parking spaces at MBTA stations within the 101 communities of the Boston Region Metropolitan Planning Organization (MPO). Planning Conformity The construction of 1,000 new parking spaces is included in the Regional Transportation Plan of the Boston Region MPO, adopted in November 2009. MassDOT Office of Transportation Planning July 27, 2011 Page 6 Project Status In prior reports submitted to DEP, MassDOT identified two major garage projects (at the Beverly and Salem Commuter Rail Stations) that it planned to implement in order to provide the 1,000 park and ride spaces required under the SIP regulation. While MassDOT was focused on developing these two projects for the SIP commitment, the MBTA was also advancing a series of other projects that would result in additional parking spaces in other locations. Following these two paths simultaneously, MassDOT and the MBTA would have constructed significantly more than the required 1,000 spaces. However, unanticipated delays to the projects in both Beverly and Salem have extended the anticipated timelines for design and construction of those two facilities beyond the deadlines required by the SIP. Therefore, MassDOT, along with the MBTA, has established a different set of parking projects which are intended to fulfill the necessary SIP commitments and requirements. Wonderland/Blue Line (Revere) MassDOT, the City of Revere, and the MBTA are working together to advance a transit-oriented development (TOD) project at Wonderland Station. The master plan for the TOD project calls for residential, retail, office, and hotel space to be built on a portion of the existing surface parking lots at the site currently used by transit riders. In exchange, the developer will build for the MBTA a new 1,465-car parking garage to not only replace the parking lost due to the development but also to increase overall transit parking supply. This project will result in 612 net new transit spaces. In November 2009, with the garage substantially designed, the City of Revere and MassDOT secured funding under ARRA for construction of the garage. This unanticipated funding source substantially expedited the development of the project. The MBTA entered into a Memorandum of Understanding with the City of Revere to award a construction contract using a municipal earmark. On September 9th, 2010, the MBTA authorized the City of Revere to award a Design/Build contract to Suffolk Construction. Notice to proceed was issued September 9th, 2010 to Suffolk Construction, and a project groundbreaking occurred on September 13th, 2010. Construction is currently 49% complete. The construction schedule anticipates substantial completion by the end March 2012, with final completion in June of 2012. Beverly Depot/Commuter Rail As part of the proposed parking garage project in downtown Beverly, the MBTA purchased a parcel of land for use for a portion of the project. In the fall of 2009, the MBTA added 102 surface level spaces on the purchased parcel, which are currently open for use by commuters. Future development on this site will include a parking garage, replacing and supplementing the current surface parking. Savin Hill/Red Line (Dorchester) During construction of Savin Hill Station (MBTA Red Line), the MBTA purchased a parcel of land adjacent to the station for construction-related uses. Upon completion of the project, the parcel was converted to a surface parking lot, which is currently open for use by commuters. The MassDOT Office of Transportation Planning July 27, 2011 Page 7 Savin Hill lot has 28 total spaces, with 22 available for use by daily commuters (the remaining spaces are reserved for MBTA employees and Zipcar users). Woodland/Green Line (Newton) 100 spaces, built as part of a joint development project, were opened to the public in 2007. Quincy Shipyard/Ferry The MBTA purchased a site previously occupied by a series of abandoned buildings associated with the Quincy Shipyard. The buildings were deemed a safety hazard and subsequently razed. Construction of a 168-space commuter parking lot is complete and open to the public. Tally Location Wonderland/Blue Line (Revere) Beverly Depot/Commuter Rail Savin Hill/Red Line (Dorchester) Woodland/Green Line (Newton) Quincy Shipyard/Ferry Total Spaces 612 102 22 100 168 1,004 Status Expected Completion March 2012 Complete Complete Complete Complete Project Funding Of the 1,004 spaces listed, 392 are complete and the 612 at Wonderland/Blue Line (Revere) have identified funding sources. The following table provides detail on the funding sources for the reported locations: Location Wonderland/Blue Line (Revere) Beverly Depot/Commuter Rail Savin Hill/Red Line (Dorchester) Woodland/Green Line (Newton) Quincy Shipyard/Ferry Funding Source (Percentage) ARRA (46) Federal Earmark (6) MBTA (23) State MORE 2 Grant (20) State TOD Grant (5) Federal Earmark (80) MBTA (20) MBTA (100) MBTA (100) Federal Earmark (80) MBTA (20) SIP Requirement Status With 392 spaces of the identified 1,004 parking spaces complete, and the Wonderland/Blue Line (Revere) garage currently under construction, it is anticipated that MassDOT will complete this SIP commitment. However, with the construction of the Wonderland garage taking longer than anticipated, MassDOT will not Massachusetts Opportunity Relocation and Expansion Jobs Capital Program 2 MassDOT Office of Transportation Planning July 27, 2011 Page 8 meet the full 1,000-space commitment in time for the December 31, 2011 deadline. MassDOT recognizes that this delay triggers the Project Delay component of the SIP regulation and that MassDOT therefore needs to prepare a Petition to Delay and an Interim Emission Offset Plan, to be implemented for the duration of the delay. However, MassDOT believes that the delay in the Wonderland parking garage causes no measurable loss of air quality improvement, as described in the attached Petition to Delay. MassDOT Office of Transportation Planning July 27, 2011 Page 9 III. RED LINE/BLUE LINE CONNECTOR - DESIGN SIP Requirement Before December 31, 2011, complete final design of the Red Line/Blue Line Connector, from the Blue Line at Government Center to the Red Line at Charles Station. Project Description The proposed Red Line/Blue Line Connector consists of an extension of the MBTA Blue Line under Cambridge Street to the Red Line station at Charles/MGH. As currently envisioned, the project would consist of two major components: (1) a new tunnel extending the Blue Line under Cambridge Street from Joy Street to Charles Circle and (2) a new underground Blue Line station connected to the existing Charles/MGH station. The project would also consider whether and how to make use of the existing Bowdoin Station – which will require significant rehabilitation – possibly including the relocation of underground trackage and platforms. The SIP requires only that MassDOT complete final design for the project. Construction of the Red Line/Blue Line Connector is not required. Planning Conformity The design of he Red Line/Blue Line connector project has been included in all relevant transportation planning documents, including the 2009 amendment to the Regional Transportation Plan of the Boston Region MPO. Project Status On September 14, 2007, MassDOT filed an Expanded Environmental Notification Form with the Massachusetts Environmental Policy Act Office. A public scoping session was held on October 17, 2007, and the Secretary of Energy & Environmental Affairs issued a certificate on the project on November 15, 2007. Based on the project scope as defined in the MEPA Certificate, MassDOT issued a Request for Proposals on March 27, 2008 for a consultant to complete the necessary environmental reviews and engineering for the project. MassDOT awarded a consultant contract during the summer of 2008. MassDOT has completed the following environmental reviews and conceptual engineering for the project: Draft Environmental Impact Report The Draft Environmental Impact Report (DEIR) was filed on March 31, 2010 A MEPA Certificate for the DEIR was issued on May 28, 2010 Public Outreach Six Working Group meetings were held A public hearing on the DEIR was held on May 3, 2010 A project website has been launched and is maintained at www.mass.gov/redblue MassDOT Office of Transportation Planning July 27, 2011 Page 10 Refinement of Alternatives/Conceptual Engineering Refinement of potential alternatives was performed for three options: (1) a no-build option, (2) a tunnel option with Bowdoin Station remaining open, and (3) a tunnel option with Bowdoin Station closed. The refinement of alternatives also included an evaluation of potential construction options (a mined tunnel vs. a cut-and-cover tunnel) and construction phasing schemes. A Definition of Alternatives/Conceptual Engineering Report was completed in November 2009. Design Criteria A draft Design Criteria Report was prepared and was included with the Definition of Alternatives Report. Alternatives Analysis An Alternatives Analysis Technical Report was completed on March 31, 2010. Design The conceptual design of the project is complete. Cost Estimates Conceptual cost estimates were included in the Definition of Alternatives Report. Construction Staging and Sequencing Plans Construction staging and sequencing plans were included in the Draft Environmental Impact Report. Real Estate Requirements Potential real estate impacts were identified as part of the DEIR. Project Funding The ‘immediate needs’ Transportation Bond Bill of 2007 provides state bond funding for the design of the Red Line/Blue Line Connector project. The estimated funding needed to complete design has increased from the previous $29 million estimate to $52 million, according to the new cost estimates completed during the development of the DEIR. SIP Requirement Status MassDOT has made a good faith effort to meet the commitment to complete final design of the Red Line/Blue Line Connector. However, as part of the environmental review and conceptual design process, MassDOT determined that the ultimate construction costs for the project will far outstrip the cost projections in place at the time that the SIP regulation was promulgated: $290 million at the time of the SIP regulation versus the current best estimate of $748 million (escalated to year of expenditure). MassDOT has already spent $3 million to advance the project through environmental review and conceptual design, but the current $52 million estimate to complete final design substantially exceeds the $29 million last identified for the effort in the 2009 Regional Transportation Plan for the Boston Region. Furthermore, MassDOT has been unable to identify funding with which to construct the Red Line/Blue Line Connector at any point in the next 20 MassDOT Office of Transportation Planning July 27, 2011 Page 11 years. As a matter of policy, MassDOT believes that it is irresponsible to spend precious public funds to design and permit transportation projects for which there are no identified construction funds, particularly given the need to continually refresh planning and permitting materials for major projects. To pursue final design of the Red Line/Blue Line Connector project at this point would be to squander resources that could otherwise be spent on projects for which construction funds are already committed. Therefore, MassDOT is initiating a process to amend the SIP to permanently and completely remove the obligation to perform final design of the Red Line/Blue Line Connector. To this end, MassDOT will work with DEP and with the general public on the amendment process. MassDOT is not proposing to substitute any new projects in place of the Red Line/Blue Line Connector commitment, given the absence of any air quality benefits associated with the current Red Line/Blue Line commitment (final design only). Correspondence from MassDOT to DEP formally initiating the amendment process is appended to this Report. MassDOT Office of Transportation Planning July 27, 2011 Page 12 IV. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD SIP Requirement Before December 31, 2014, construction of the following facilities shall be completed and opened to full public use: 1. The Green Line Extension from Lechmere Station to Medford Hillside; 2. The Green Line Union Square spur of the Green Line Extension to Medford Hillside; and On or before 18 months following the effective date of the regulation (December 1, 2006), MassDOT must develop a request for proposals for a design consultant, complete the competitive procurement process, and issue a notice to proceed. Done Within 15 months of the completion of the above requirements, MassDOT must complete conceptual design and file an Environmental Notification Form. Done On or before two years after MEPA’s issuance of a scope for a Draft Environmental Impact Report or a Single Environmental Impact Report, MassDOT must complete preliminary design and file a DEIR or SEIR. Done On or before one year after MEPA’s issuance of a scope for a Final Environmental Impact Report, MassDOT must file an FEIR. Done On or before 18 months after MEPA’s issuance of a certificate on an FEIR or an SEIR, MassDOT must complete final design, apply for all necessary permits funds and grants, file any required legislation, and initiate all public and private land acquisition. Underway Upon completion of all of the above milestones, DEP and MassDOT shall establish a schedule for project construction and deadlines for project completion. To be completed Extensive information about the Green Line Extension project can be found at www.mass.gov/greenlineextension. Project Description This project – the purpose of which is to improve corridor mobility, boost transit ridership, improve regional air quality, ensure equitable distribution of transit services, and support opportunities for sustainable development – will extend the MBTA Green Line from a relocated Lechmere Station in East Cambridge to College Avenue in Medford, with a branch to Union Square in Somerville. MassDOT Office of Transportation Planning July 27, 2011 Page 13 Proposed Stations New Green Line stations are currently proposed for: College Avenue, Medford – Located at the intersection of College Avenue and Boston Avenue in Medford, adjacent to Tufts University. The station platform will be located on the north side of the College Avenue Bridge, which crosses over the MBTA Lowell Line. Access to the station will be provided from both Boston Avenue and College Avenue, as well as from the Burget Avenue neighborhood, which lies northeast of the station site. Broadway/Ball Square, Medford/Somerville – Located at the intersection of Broadway and Boston Avenue on the north side of Ball Square. The station platform will be located on the north side of the Broadway Bridge, which crosses over the MBTA Lowell Line. Access to the station will be provided from both Boston Avenue and Broadway. An electrical substation, needed to support the Green Line Extension, will likely be installed at this location. Lowell Street, Somerville – Located at the Lowell Street Bridge, which crosses over the MBTA Lowell Line adjacent to the proposed extension of the Somerville Community Path. The station platform will be located on the north side of the Lowell Street Bridge. Access to the station will be provided from Lowell Street. Gilman Square, Somerville – Located in the vicinity of the Medford Street crossing of the MBTA Lowell Line, behind Somerville City Hall, Public Library, and High School. The station platform will be located on the north side of the Medford Street Bridge, which crosses over the MBTA Lowell Line. Access to the station will be provided from Medford Street. The proposed extension of the Somerville Community Path will be located in close proximity to the station. Washington Street, Somerville – Located within the footprint of the Washington Street Bridge, proximate to Somerville’s Brickbottom, Inner Belt, and Cobble Hill areas. The station platform will be located south of the Washington Street undergrade crossing of the MBTA Lowell Line. Access to the station will be provided via entrances located under or adjacent to the south abutment of the bridge, in conjunction with improved sidewalk and street-crossings in the area. The proposed extension of the Somerville Community Path will be located in close proximity to the station. Union Square, Somerville – Located east of Prospect Street in the vicinity of Union Square in Somerville. The station platform will be located within the MBTA Fitchburg Line right-of-way east of Prospect Street. Access to this station will be provided from both the street and bridge levels of Prospect Street. Details of the design of the stations, including the relationship of the stations to the pedestrian, bicycle, and bus networks around them, are now being more fully developed. The MBTA has just MassDOT Office of Transportation Planning July 27, 2011 Page 14 completed a series of public Design Workshops, held to engage the public in developing the ‘look and feel’ of the stations and the areas around the stations. The MBTA will use the information collected at the Workshops and from work with the Green Line Extension Design Working Group to inform the ongoing station design and engineering work. Vehicle Storage and Maintenance Facility The Green Line Extension will also require the construction of a new light rail vehicle storage and maintenance facility in the vicinity of the Green Line Extension. MassDOT has identified a location known as ‘Option L’ in the Inner Belt area of Somerville as its preferred alternative for the location of the vehicle support facility. The MBTA is currently working on the program and design of the maintenance facility and its associated vehicle storage areas. The MBTA must acquire certain parcels of private property in order to construct the vehicle facility at the Option L location. Somerville Community Path Extension In addition, the Green Line Extension project includes the design of the proposed extension of the Somerville Community Path (not part of the SIP commitment). Planning Conformity The Green Line Extension project has been included in all relevant transportation planning documents, including Transportation Improvement Programs for the Boston Region MPO, the MBTA Program for Mass Transportation, and the Regional Transportation Plans of the Boston Region MPO. Project Status State-level environmental review (MEPA) was completed in July 2010. Federal-level environmental review (NEPA) documents were submitted to the Federal Transit Administration (FTA) in December 2010, and will be released upon FTA approval. MassDOT hopes to receive a Finding of No Significant Impact from the FTA for the Green Line Extension project in autumn of 2011. The MBTA procured a new Program Management/Construction Management/Preliminary Engineering (PM/CM/PE) technical team in the autumn-winter of 2010-2011. This team is currently working under an initial contract to perform Advanced Conceptual Engineering for the Green Line Extension project, which will lead to Preliminary Engineering and then to the initiation of procurement of a Design-Build team to complete design of and construct the Green Line Extension. The MBTA has also recently selected an Owner’s Representative to support the MBTA throughout the implementation of the project. MassDOT and the MBTA continue to work with the FTA to seek funding for the Green Line Extension project under the FTA New Starts capital funding program. Procurement of 24 new Green Line vehicles needed to support the operation of the Green Lin Extension is now underway. The MBTA advertised for the new vehicles in January 2011 and held MassDOT Office of Transportation Planning July 27, 2011 Page 15 a pre-bid meeting for prospective bidders in February 2011. Proposals were submitted to the MBTA on June 13, 2011. Potential real estate impacts have also been identified and are continuing to be refined. MassDOT and the MBTA are collaborating on necessary background and support work, including geotechnical and hazardous materials testing, in order to be ready for the process of property acquisition upon receipt of federal environmental approval. In addition, recent completion of an agreement with Pan Am Railways allowed the Commonwealth to acquire land and track vital to the construction of the project. Many other project milestones have also been reached on the Green Line Extension project, including: refinement and analysis of alternatives, development of design criteria, station programming and siting, initial cost and schedule estimating, conceptual engineering, and the development of construction staging and sequencing plans. Public outreach on the project has included hundreds of meetings and other events over multiple years. MassDOT and MBTA staff have met with numerous public groups, elected officials, and other interested parties. There have been two different project advisory committees, including the former Project Advisory Group and the present Design Working Group. Meeting types have included meetings of those groups and their subcommittees, station workshops, interagency meetings, neighborhood briefings, briefings with elected officials, institutional and business group meetings, public meetings and hearings, land use workshops, and ‘meet and greet’ sessions, as well as many others. Project Funding As mentioned above, MassDOT is pursuing federal funding – through the competitive New Starts program managed by FTA – to support the design and construction of the Green Line Extension project. In January of 2010, MassDOT and the FTA initiated formal collaboration on the development of a complete New Starts application for the Green Line Extension project, including oversight and assistance from a Project Management Oversight Consultant (PMOC). This effort is and will be ongoing. The MBTA, MassDOT, FTA, and the PMOC held a week-long ‘Cost and Schedule Risk Assessment’ Workshop in March 2011, which was crucial to moving ahead with the New Starts application process (see below for more information on the results of the Workshop). The final New Starts application materials are in progress, and need to be finalized for FTA review. The challenges related to the New Starts process – a complex, demanding, and time-consuming process – have added substantial time to the schedule for initiating design of the Green Line Extension project. MassDOT and the MBTA nevertheless believe that the Green Line Extension project is a strong and viable contender for New Starts funding. Despite support for the project and its benefits from officials at FTA, however, we are realistic about the national-level demand for New Starts funding. While the Commonwealth (not the MBTA itself) is committed to pay the capital costs of the Green Line Extension, there will be additional and ongoing operating expenses associated with running the expanded Green Line that must be borne by the MBTA. We are therefore concerned about the effect that the enormously constrained financial condition of the MBTA system will have on our chances of success within the New Starts program. It must also be MassDOT Office of Transportation Planning July 27, 2011 Page 16 noted that the availability of transportation funding at the federal level, including for the New Starts program, is uncertain and most likely shrinking. All of these factors will play a role in the potential federal funding of the Green Line Extension project. In addition to the use of any federal funding, MassDOT and the MBTA will use Commonwealth funds to support the design and construction of the Green Line Extension project. These funds will be raised with the backing of authorizations made to support the SIP projects in Transportation Bond Bills of the past several years. At present, MassDOT has $800 million (less funds already spent on planning, design, and construction) in active Transportation Bond Bill authorizations for the SIP projects. As needed, MassDOT will seek additional Transportation Bond Bill authorization to cover the costs of the Green Line Extension project, as well as other SIP projects. SIP Requirement Status By filing an Expanded Environmental Notification Form, procuring multiple design consultants, and publishing both Draft and Final Environmental Impact Reports, MassDOT has met the first four interim milestones associated with the Green Line Extension project. MassDOT – which has committed substantial resources to the Green Line Extension project, a top transportation priority of the Commonwealth and the largest expansion of the MBTA rapid transit system in decades – is now transitioning the project from the planning and environmental review phases to design, engineering, and eventual construction, coupled with the tasks associated with applying for New Starts funding. As part of this transition, the MBTA has assumed lead project management responsibility for the ongoing development of the Green Line Extension project, with MassDOT continuing to support the MBTA on an as-needed basis. This transition to design, engineering, and construction represents the achievement of a crucial and exciting milestone for the Green Line Extension project, which has now progressed farther and closer to implementation – with the support and advocacy of elected leaders, municipal officials, organized advocates, and hundreds of individual members of the public – than at any time in the past. Together, MassDOT and the MBTA have also managed an extensive community and public participation effort for the Green Line Extension project, which enjoys widespread support from local officials and the public in general. This community participation effort, while time-consuming, has made the project better and more responsive to public concerns, and is appropriate for a project of this magnitude and importance to the surrounding community and to the region as a whole. The Green Line Extension is an enormously complex capital project, with many tasks and sub-tasks that must be completed, some in sequence and some in parallel, in order for the first rider to travel from a relocated Lechmere Station toward Union Square and College Avenue. In the 2010 SIP Status Report, MassDOT indicated that the Green Line Extension project was tracking for completion at the end of October 2015, ten months past the legal deadline of December 31, 2014. Over the past four months, the Green Line Extension project team has performed a cost/schedule/risk analysis, which used as a foundation the results of the abovementioned FTA PMOC Risk Assessment Workshop. As a result, the 2010 schedule projections for the Green Line Extension project have been further refined. MassDOT and the MBTA now have a much deeper and more nuanced understanding of the constraints and limitations that must be managed in order to implement the Green Line Extension project. MassDOT Office of Transportation Planning July 27, 2011 Page 17 Based upon those continuing analyses, we are now projecting a timeframe – rather than a specific month or day – for the introduction of revenue service on the Green Line Extension. The points within the timeframe are associated with different probabilities, as shown below: 10% Probability of Not Exceeding – September 2018 50% Probability of Not Exceeding – June 2019 90% Probability of Not Exceeding – July 2020 It is important to note that this schedule scenario assumes the issuance of a notice to proceed to a Design/Build contractor only after the MBTA has taken full ownership of all private property of any substantial size required for the construction of the Green Line Extension. This allows the Green Line Extension project to benefit from lessons learned on the Greenbush Commuter Rail project, in which the MBTA did not take ownership of needed properties until after the issuance of a notice to proceed to the Design/Build contractor, costing the MBTA both time and money and slowing the overall completion of the project. It also assumes that the federal National Environmental Policy Act (NEPA) process for the Green Line Extension will be complete in November of 2011 and that necessary property acquisition can begin at that time. The work that has gone into developing the detailed risk analyses and to quantifying the statistically-based schedule ranges is significant and the most detailed done to date for the Green Line Extension project. However, MassDOT and the MBTA are not satisfied with the schedule ranges shown here, and are actively considering strategies that could mitigate schedule risks and improve upon the probable delivery dates for passenger service on the Green Line Extension. Some of the strategies under consideration are identified below: The development of a ‘phasing’ scenario that could have segments of the Green Line Extension in revenue service earlier than projected, thereby mitigating at least some of the delay described above. In this scenario, opening of the Green Line Extension project would be phased, allowing some stations to open for public use while others are still being constructed. The possibility of awarding a Design/Build contract prior to completion of all major property acquisitions. While this would run counter to the lessons of the Greenbush project, it could potentially expedite completion of the project. The possibility of using a project delivery method other than Design/Build, specifically Construction Manager - General Contractor. Although this method is relatively new, it could potentially expedite final design and construction. In order to better and more frequently share with project stakeholders and the general public the status and progress of the Green Line Extension project, the MBTA proposes to convene a GLX Steering Group. The Group, which will be chaired by the MBTA, will include representatives of MassDOT Planning; MassDOT Highway Division; the Cities of Cambridge, Somerville, and Medford; and the Federal Transit Administration. The first task for the Group will be to review the anticipated Green MassDOT Office of Transportation Planning July 27, 2011 Page 18 Line Extension project schedule, including phasing options, to try to lessen the projected delay. The Group will, therefore, meet on at least a bi-weekly basis, at least in the short term. The MBTA and its technical team will report to the Group on the schedule and status of the Green Line Extension project, and will bring any other pertinent issues to the Group. The Group will follow all Open Meeting guidelines. In addition, the MBTA plans to request a ‘Letter of No Prejudice’ from the FTA, which could allow the Green Line Extension project to move forward more quickly while still preserving the future potential to seek federal reimbursement for state monies expended. The timeline listed above represents a substantial delay beyond the current SIP deadline of December 31, 2014, triggering the need to provide interim emission reduction offset projects and measures for the period of the delay (beginning January 1, 2015). Working with the Central Transportation Planning Staff, MassDOT and the MBTA are currently initiating the process of calculating the reductions of NMHC, CO, and NOx – reductions equal to or greater than the reductions projected for the Green Line Extension itself, as specified in the SIP regulation – that will be required for the period of the delay. Once that process is complete, MassDOT and the MBTA will develop a portfolio of interim projects and/or measures that can meet the requirement, and will seek input from both DEP and the general public on the portfolio. MassDOT and the MBTA are aware of the strong public interest in potential interim emission reduction offsets, having already received many suggestions and recommendations; we will strive to make use of ideas presented to us by the public whenever possible. However, MassDOT and the MBTA are acutely aware of the need for any selected interim emission reduction offsets to quantitatively and demonstrably meet the emission reduction threshold established in the SIP regulation, and will be subjecting potential interim emission reduction offsets to necessary rigorous analysis by the Central Transportation Planning Staff. MassDOT and the MBTA are also sensitive to the constrained fiscal environment in which all of the Massachusetts transportation agencies currently operate, and will weigh fiscal concerns when selecting appropriate interim emission reduction offsets. MassDOT will keep DEP apprised of the progress made by the Central Transportation Planning Staff as it develops the emission reduction targets for the portfolio of interim emission reduction offset projects and measures. MassDOT Office of Transportation Planning July 27, 2011 Page 19 PETITION TO DELAY Fairmount Line Improvement Project 1,000 New Park and Ride Parking Spaces Background This Petition to Delay is submitted by the Massachusetts Department of Transportation (MassDOT), in conjunction with the Massachusetts Bay Transportation Authority (MBTA), to the Massachusetts Department of Environmental Protection (DEP) in order to fulfill the requirements of 310 CMR 7.36(7), Transit System Improvements, as amended. Below is a Petition to Delay the Fairmount Line Improvement project and the 1,000 New Park and Ride Parking Spaces project. Fairmount Line Improvement Project The Fairmount Line Improvement project includes the rehabilitation of the existing MBTA Uphams Corner and Morton Street Stations, construction of four new stations – Newmarket, Four Corners, Talbot Avenue, and Blue Hill Avenue – reconstruction of six existing railroad bridges (located over Columbia Road, Quincy Street, Massachusetts Avenue, Talbot Avenue, Woodrow Avenue, and the Neponset River), and construction of a new interlocking and upgraded signal system (required for the bridge reconstruction work). These upgrades will allow for increased frequency and better overall service on the Fairmount Line. The entirety of the Fairmount Line Improvement project is required to be completed by December 31, 2011. At present, multiple elements of the Fairmount Line Improvement project are delayed, including construction of three of the Neponset River Bridges, construction of Four Corners Station, construction of Talbot Avenue Station, construction of Newmarket Station, and construction of the Talbot and Woodrow Avenue Bridges. These project elements are all currently anticipated to be completed autumn 2012–winter 2013. In addition, the construction of Blue Hill Avenue Station is substantially behind schedule, due to sustained neighborhood controversy about the siting of the station. The MBTA has announced its decision to pursue the construction of the station at the intersection of Blue Hill Avenue and Cummins Highway and has re-started station design for that location. The necessary redesign of the station is underway, and 100% design completion is anticipated by the end of 2011. The project is tentatively scheduled for construction advertisement in February 2012, with anticipated construction to start in May 2012. This anticipated schedule will be revisited as the design of the station evolves. The Fairmount Line Improvement project is delayed for multiple reasons, including a longer-than-anticipated public outreach process; the need to re-design certain station elements and infrastructure such as platforms, canopies, and track curvature in order to accommodate public requests; and unexpected geological conditions encountered during construction. However, the majority of the project elements are now under construction; Blue Hill Avenue Station – the exception – is well into design and construction is anticipated next year. The MBTA is advancing the Fairmount Line Improvement project steadily and expects to meet the timeline laid out here. MassDOT Office of Transportation Planning July 27, 2011 Page 1 As the delay of the complete implementation of the Fairmount Line Improvement project cannot now be avoided, however, MassDOT is petitioning DEP to formally delay the project. In order to compensate for the delay, MassDOT requested the Central Transportation Planning Staff to estimate the reduced emissions expected to be generated by the implementation of the new Fairmont Line stations (the emissions reduction projections are shown below). MassDOT and the MBTA have further identified two interim emission reduction offset measures that will together meet the required emissions reduction targets and which will provide valuable transportation benefits in the period prior to the full implementation of the Fairmount Line Improvement project. These proposed measures were developed with the input and assistance of Fairmount Line stakeholders, for which MassDOT and the MBTA are grateful. MassDOT believe that the potential offset measures shown below meet the standard of being within the ‘transit ridership area’ as required by the State Implementation Plan regulation. Fairmount Line Improvement Project Mobile Source Emissions (Average Weekday) – Projection for 2012 Condition Existing Conditions Fairmount Line Improvement Project – Implemented Target VOC (kg) 1 42,071.7 42,071.4 NOx (kg) 90,851.9 90,851.3 CO (kg) 1,256,799.6 1,256,789.4 -0.34 0.67 -10.26 Fairmount Line Improvement Project Proposed Interim Emission Reduction Offset Measures VOC (kg) Proposed Offset Measures Shuttle bus service from Andrew -0.25 Square to Boston Medical Center Implement proposed Roxbury-0.42 Dorchester-Mattapan increased bus service (Routes 29 and 31) NOx (kg) CO (kg) -0.546 -9.214 -0.52 -3.65 MassDOT and the MBTA would like to solicit feedback from DEP and the general public on these proposed interim emission reduction offset measures for the Fairmount Line Improvement project. 1,000 New Park and Ride Spaces 1 The SIP Regulation requires the estimation of NOx, CO, and NMHC (non-methane hydrocarbons). For the purposes of this analysis, CTPS opted to use VOCs (volatile organic compounds) as the comparable measured pollutant. Volatile organic compounds (VOC) represent a larger category of substances than do NMHC and have been used interchangeably in the examination of mobile source emissions. Non-methane hydrocarbons refers to the total air borne hydrocarbons (organic compounds consisting only of hydrogen and carbon) and other organic compounds excluding methane (CH4). VOC is a generic term for a large variety of chemically different non-methane compounds, such as benzene, ethanol, formaldehyde, 1,1,1trichloroethane, or acetone, as well as methane compounds. MassDOT Office of Transportation Planning July 27, 2011 Page 2 To encourage commuters and other travelers to make use of the public transit network for trips into downtown Boston, MassDOT and the MBTA are constructing 1,000 new parking spaces at MBTA stations within the 101 communities of the Boston Region Metropolitan Planning Organization (MPO). To meet this commitment, MassDOT has identified the construction of a new parking facility at the Wonderland Station on the MBTA Blue Line (see below for more information on the Wonderland project), as well as a series of other smaller projects 2 , that will together result in the required 1,000 spaces. The entirety of the 1,000 parking space commitment is required to be implemented by December 31, 2011. Upon completion of the construction of the new seven-story parking facility (known as the ‘South Garage’) at Wonderland, over 714 new spaces will be added to the spaces the MBTA already owns in the area. 102 of the new spaces will be leased to the City of Revere, leaving a net increase of 612 new MBTA-owned spaces that can be counted towards the 1,000 parking spaces required by the SIP. Parking at the South Garage is expected to cost $7 per day, between $2 and $3 more per day than is charged by the private lots that are located nearby. The Wonderland project is now delayed and is currently anticipated to be completed in the spring of 2012, meaning that the full parking space commitment will not be met by the established deadline. As the delay of the complete implementation of the parking space commitment cannot be avoided, MassDOT is now petitioning DEP to delay the project. The air quality benefits projected as part the SIP regulation process were anticipated for a model year 2025, and also include different anticipated land uses than are present today. In the case of Wonderland, current land uses include inexpensive private parking lots at the site of the former Wonderland Greyhound Park and adjacent to the future South Garage, the presence of which depress the projected demand for parking at the South Garage. In the short term, the availability of the private parking lots will likely result in South Garage being under-used, and, as a result, there will be no measurable air quality benefits in the short term. Given that, MassDOT is requesting that DEP not require the implementation of interim emission reduction offset measures for the 1,000 parking space commitment. 2 Including projects at Savin Hill Station, Woodland Station, and the Quincy Shipyard. MassDOT Office of Transportation Planning July 27, 2011 Page 3 July 1, 2011 Kenneth L. Kimmell, Commissioner Department of Environmental Protection 1 Winter Street Boston, MA 02108 Re: Red Line/Blue Line Connector, 310 CMR 7.36 2(i) Dear Commissioner Kimmell: I am writing to request an amendment to MassDEP’s Transit System Improvement regulations, 310 CMR 7.36, and the State Implementation Plan (SIP), specifically as they relate to the final design of the Red Line/Blue Line Connector (310 CMR 7.36 2(i)). As set forth in greater detail below, the requirement to complete final design of an extension of the Blue Line from Government Center Station to Charles/MGH Station is a significant and expensive commitment that provides no actual air quality or transit benefits in and of itself. Funding for transit projects in the Commonwealth is exceedingly scarce and there are many competing demands for those funds that do exist. Given the lack of transit or air quality benefits associated with this purely procedural requirement, MassDOT does not believe that spending up to $50 million to complete the project design is a wise use of public funds. MassDOT therefore respectfully requests that the Department of Environmental Protection (MassDEP) undertake the steps necessary to amend the Transit System Improvement Regulations and the SIP to remove the requirement to complete final design of the Red Line/Blue Line Connector. Background on Transit Commitments Under the SIP As you know, MassDOT, in partnership with the MBTA, has worked diligently over the past several years to implement the various SIP transit commitments. These efforts, which are described in greater detail in our monthly SIP Status Report updates (available at: http://www.mass.gov/massdot/SIP) are summarized below: Fairmount Line Improvements: The MBTA has already made significant upgrades to existing stations and bridges and has constructed a new interlocking on the Fairmount Commuter Rail Line. With the exception of Blue Hill Avenue station which is still in design, all remaining Fairmount project elements are currently under construction. 1,000 New Parking Spaces: Multiple projects are contributing to the fulfillment of this commitment, and the anticipated completion of the new Wonderland Station garage will allow us to meet the 1,000-space target. Green Line Extension: MassDOT is continuing to advance this enormously important and complex capital project, which will extend light rail service into previously Leading the Nation in Transportation Excellence Ten Park Plaza, Suite 3170, Boston, MA 02116 Tel: 617-973-7000, TDD: 617-973-7306 www.mass.gov/massdot underserved areas of Somerville and Medford. The Commonwealth has recently committed significant funds to advance the design of the project and purchase new Green Line vehicles to support the eventual operation of the Extension. In addition, the project’s Final Environmental Impact Report received a Certificate from the Secretary of Energy and Environmental Affairs in 2010, and final federal environmental approval is expected later this year. An agreement for the purchase of right-of-way needed for the project was also recently completed with Pan Am Railways. As required by 310 CMR 7.36(8), Determination of Air Quality Emission Reductions, and EPA SIP requirements, MassDOT determined that the Fairmount Line Improvements, 1,000 New Parking Spaces, and the Green Line Extension projects would achieve daily reductions of 435 kilograms of carbon monoxide (CO), 11 kilograms of nitrogen oxides (NOx), and 17 kilograms of volatile organic compounds (VOC) in 2025. The reductions in emissions are a result of a decrease in vehicle miles traveled because the projects encourage travel by public transit rather than by private automobile. Red Line/Blue Line Connector As noted above, the regulation and SIP require MassDOT to complete final design of an extension of the Blue Line from Government Center Station to Charles/MGH Station. Unlike the other transit project requirements in the regulation and SIP, however, there is no specific requirement or obligation to construct the Red Line/Blue Line Connector. As a result, the commitment to design this project, by itself, provides no air quality benefit to the Boston Metropolitan region. In fact, the air quality modeling for the regulation and SIP revision, as approved by EPA in 2008, did not include or assign any air quality benefits to the project 1 . MassDOT has, nonetheless, made a good faith effort to meet the commitment for the design of the Red Line/Blue Line Connector. MassDOT has spent close to $3 million over the past two years to advance conceptual design of the project and complete the Draft Environmental Impact Report (DEIR). This effort was supported by the input of a working group consisting of individuals representing institutions, neighborhood associations, business groups, advocates, City of Boston agencies, and state and local elected officials. This group met on a bi-monthly basis and their input was in addition to that received in two public meetings held on the project. In addition to the lack of tangible air quality benefits associated with the Red Line/Blue Line Connector requirement, final design of the project comes at a considerable financial cost (most recently estimated at more than $50 million). Given the many other competing needs for our limited transportation funding, the Commonwealth and the Boston Region Metropolitan Planning Organization have not included the project in the Regional Transportation Plan (RTP), which lists projects prioritized for construction in the next 25 years. Therefore, committing $50 1 EPA issued final approval of the State Implementation Plan for Transit System Improvements on July 31, 2008 including approval of air quality benefits assigned to the Green Line Extension to Union Square and Medford Hillside, Fairmount Line Improvements, and 1,000 park and ride parking spaces. Page 2 million in transportation funding to complete the design process – as well as dedicating additional resources to complete the environmental review and permitting processes – for a project that is extremely unlikely to be built simply cannot be justified. Since environmental review and conceptual design began for the Connector in 2009, MassDOT has determined that the ultimate construction costs for the project will far outstrip the cost projections in place at the time that the SIP regulation was promulgated: $290 million at the time of the SIP regulation versus the current best estimate of $748 million (escalated to year of expenditure). MassDOT has already spent $3 million to advance the project through environmental review and conceptual design, but the $50 million estimate to complete final design far exceeds the $29 million last identified in the Boston MPO 2009 Regional RTP. Design costs are typically estimated at 10% of total construction costs, so the $29 million estimate for final design at the time of the new SIP regulation was based on a $290 million estimated construction cost, which was escalated from the $237 million project cost carried in the 2004 Boston MPO RTP. The dramatic increase in projected costs from the 2004 RTP to the $748 million figure included in the 2010 DEIR is attributable to a number of factors: Prior estimates relied on decades-old analysis. The Red/Blue Connector project had been included in several iterations of the Boston MPO RTP and the MBTA’s Program for Mass Transportation (PMT). Although each of these planning efforts assigned an estimated construction cost to the project, these estimates were not based on new analyses of the project. Instead, the RTP and PMT estimates simply re-used the construction cost estimate from the last rigorous analysis of the project (the 1986 MBTA Bowdoin/Charles Connector Project report) and escalated those costs to the RTP or PMT year. The Red/Blue DEIR is, therefore, the first substantive analysis of costs for the Red/Blue Connector project in more than 20 years. New information gathered during conceptual design disproved old assumptions. The conceptual design work overseen by MassDOT starting in 2009 forced MassDOT and the consultant team to revisit previous assumptions. An example is the preferred tunneling method. Previous cost estimates had assumed ‘cut and cover’ construction, which is typically less expensive than is the use of a tunnel boring machine (TBM). However, due to the density and complexity of the utility networks beneath Cambridge Street, it was determined by MassDOT during this most recent planning process that cut and cover construction in this environment would actually be at least as expensive as a TBM approach. As a result, the savings resulting from a cut and cover approach envisioned by past analyses of the project would likely not be realized. Budgeting for contingency is now much more conservative. In the late 1980s, the MBTAdeveloped cost estimates for the project included a 20 percent contingency. The DEIR cost estimate, which is informed by two more decades of project management, the experience from the Central Artery/Tunnel project, and guidance from the Federal Transit Administration, includes a more conservative 40 percent contingency. MassDOT believes that a 40 percent Page 3 contingency is appropriate given the conceptual stage of design, and the uncertainties inherent in a project involving tunneling under a dense and historic urban environment. DEIR cost estimate reflects a new project scope. The 1980s analysis of the Bowdoin/Charles Connector did not include project components that were determined to be essential by MassDOT in 2010. For example, the 1986 analysis assumed that Bowdoin Station would be retained and that the extension would make use of that station’s existing tail tracks. However, the MBTA has since determined that it cannot allow revenue service – the operation of transit vehicles with passengers on board – on the Bowdoin loop. This is due to the challenges in safely evacuating passengers with disabilities from a train that might become disabled on this tight curve. As a result, whether or not Bowdoin Station is retained in the project, the tunnel construction will now extend several hundred more feet to the edge of Government Center Station. Design and permitting done now will need to be duplicated later. Finally, because the RTP does not include funding for construction of this project at any time in the next 25 years, it is fair to expect that the project will not actually be constructed during that time period even if the final design is completed. As a result, the final EIR and final design documents would need to be substantially, if not completely, revised and updated to reflect changed conditions and requirements at the time that the project was ultimately advanced for construction. There is no point in spending scarce public transit funds to develop documents that we know will need to be superseded later. Conclusion At some point, a project’s costs rise to the level where the pursuit of what was once a sound investment becomes simply unaffordable. I, therefore, respectfully submit this request for your consideration of removing the final design of this project, which by itself will generate no air quality benefits, from the Transit System Improvement Regulations and the SIP. Unless MassDEP removes this requirement, MassDOT will continue to be required to do the design or risk being in violation of the regulation and the SIP. I look forward to your response, and we will work with you and your staff to address any questions or issues that arise from our request. If you have any questions, please do not hesitate to contact me at 617-973-7844 or david.mohler@state.ma.us. Sincerely, David J. Mohler Executive Director Office of Transportation Planning cc: Red Line/Blue Line Connector Working Group Page 4 Green Line Extension Risk Analysis Schedule Range – Revenue Service Date for Full project Project At A Glance: • Track: o Green Line Medford Branch: 3.4-miles o Green Line Union Square Branch: 0.9-miles o Relocated Lowell and Fitchburg Commuter 100% Rail Tracks • Seven Stations (Cambridge, Somerville, and 90% Jul 2020 – 90% Medford): Probability 80% o Lechmere – Relocated o Washington Street 70% o Gilman Square 60% o Lowell Street 50% Jun - 2019– 50% o Ball Square Probability o College Avenue 40% o Union Square 30% • Reconstruction of 11 bridges Revenue Service – Range of forecasted 20% completion dates reflecting 10%, 50% • Vehicle Maintenance and Storage Facility and 90% completion probabilities 10% • Signal, Communication, and Power Systems Sep 2018 – 10% Probability • Multimodal Connections 0% Sep - 2017 Apr - 2018 Oct - 2018 May - 2019 Dec - 2019 Jun -2020 Jan -2021 Jul - 2021 • Retaining and Noise Walls Completion Date • Roadway and Intersection Design • 24 New Green Line Vehicles • Design of Community Path - Project Benefits • Improve Regional Air Quality • Improve Corridor Mobility and Regional Access • Boost Transit Ridership • Ensure Equitable Distribution of Transit Services • Support Opportunities for Smart Growth Key Schedule Requirements: • July/August 2011: Anticipated Final Environmental Assessment (EA) Filing • November 2011: Receive Finding of No Significant Impact (FONSI) from FTA allowing Project to Acquire Private Property (Acquisition/Relocation - 24 Month Process) • November 2013 – Notice to Proceed to Design-Build Contractor (Property Acquisitions Complete) Level of Project Design: Low Medium Risk Analysis Schedule Range • 10% Probability of Meeting Revenue Service Date - September 2018 • 50% Probability of Meeting Revenue Service Date - June 2019 • 90% Probability of Meeting Revenue Service Date - July 2020 Key Project Schedule Risks • Major Real Estate Acquisitions/Relocations (24 months) • Extend Bridge Construction Duration to Incorporate Local and Regional Utility Relocations • Maintaining Commuter Rail Operations During Construction: o Sequencing of Utility Relocation in Corridor o Sequencing of Bridge Construction and Utility Relocations o Sequencing of Retaining Walls Construction • Implementation of Third-Party Utility and Mitigation Agreements with Communities, Utilities, Rail Operator Corridor-Wide Stormwater Management and Permitting Issues • FTA Process and Procedures to Obtain New Starts Funding High July 2011
