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
[email protected]
(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 [email protected] 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
[email protected]
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
[email protected]
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
[email protected]
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 • [email protected]
FIGURE 1
Map of the Study Area
Scott Hamwey, MassDOT
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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
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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
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November 29, 2011
Scott Hamwey, MassDOT
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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
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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
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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
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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 [email protected]
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
[email protected]
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
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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 [email protected]
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
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