COMMONWEALTH OF MASSACHUSETTS
THE GENERAL COURT
STATE HOUSE. BOSTON 02133-1053
David Mohler, Chair
MPO Transportation Planning and Programming Committee
10 Park Plaza Suite 2150
Boston, MA 02116
September 12, 2011
Dear Mr. Mohler:
We are writing to offer our comments on the Long Range Transportation Plan and specifically the
proposed delay in completion of the Green Line Extension to Somerville and Medford. The Green Line
Extension is an extremely high priority for all of us as well as for the state for environmental, legal and
economic reasons. Delaying this project will delay all ofthese benefits and add an additional $200
million to the cost ofthe project. Therefore, we have serious concerns about this delay and we would
ask that the MPO reject the proposed time frame of 2018-2020.
The proposed delay is inconsistent with everything that we have been told by DOT for the past several
years. Additionally, the proposed delay violates the commonwealth's legal requirement to give highest
priority in all transportation planning documents to those projects the state has promised to complete
in order to become compliant with the federal Clean Air Act. The Green Line Extension not only is one of
those projects, but it is the one the state says will provide by far the greatest air quality benefits.
The current proposal is to begin land acquisition once DOT has received a Finding of No Significant
Impact and then to wait until all land acquisitions have been completed before beginning any
construction. This is scheduled to take two years. This is an unnecessary delay. There are very few
major parcels to be acquired throughout the entire corridor and most should be acquired fairly quickly.
Given a proposed 55 month construction schedule, there is no reason that work cannot be done building
the Green Line Extension while the details are worked out on a land taking that is only needed for the
maintenance facility. Construction of the maintenance facility could easily be scheduled for the final
stages of the project allowing ample time for land acquisition. Adopting this scheduling change could
reduce the project time frame by as much as 2 years.
DOT should revisit this schedule and to offer solutions that will speed up completion including beginning
construction before land acquisitions are complete and by offering new phased construction schedules
that will allow portions of the line to be opened prior to the completion of the entire line. DOT should be
required to set multiple schedule deadlines so that progress toward those goals can be monitored. It
would not be unreasonable to expect that DOT could complete preliminary design (the current HDR
contract) by the end of 2012, advertise Design-Build contract in the first quarter of 2013 and have Green
Line service operational from the new Lechmere station to Washington Street by end of 2015 with full
service operational to Medford by 2016.
Pursuant to the SIP, this latest delay, even if the time frame is shortened to 2016, will require DOT to
take on additional Clean Air Act commitments. These additional commitments must directly benefit
those who have already been waiting on the Green Line for years. In particular, DOT's mitigation efforts
should focus on full build of the original project to Route 16 and completion of the Community Path.
We understand that building the Green Line Extension is an expensive proposition; however, it is a legal
commitment of the commonwealth as a result of the Big Dig. It is no less of a commitment than the
state's commitment to pay the contractors and the bond holders for the construction of the Big Dig
itself. DOT and the state must find a way to pay for this commitment and for the financing of the state's
transportation infrastructure generally including the necessary capital and operating expenses of the
Green Line Extension and an assessment of all feasible financial actions to bring the TIP into compliance
and conformity with Federal Requirements by the end of 2011.
Sal N. DiDomenico
State Senator
Denise Provost
State Repres ntative
State Representative
Sean Garballey
State Representative
got
Friends of the Community Path
112 Belmont Street
Somerville, MA 02143
617.776.7769
friendspath@yahoo.com
www.pathfriends.org/scp/
PACDH?
September 13,2011
To:
Mr. Jerome Grafe, Mass Department of Environmental Protection
Ms. Christine Kirby, Mass Department of Environmental Protection
Mr. David Mohler, Chair, Boston MPO Planning & Programming Committee
The Boston MPO Staff
Re: Community Path, Green Line Extension Delay - Please fully enforce the SIP Air Quality
requirements and Transportation Conformity Measures in the Boston MPO 2012 - 2015 TIP and
LRTP
To Mr. Jerome Grafe, Ms. Christine_Kirby, Mr. David Mohler, and the Boston MPO Staff:
We are writing on behalf of the Friends of the Community Path, a community group of almost a
1000 members that was formed ten years ago. We are writing here for a number of reasons, fIrst
to express our thanks and support for the 2012 Transportation Improvement Program (TIP)
funding of the Cedar-to-Lowell Community Path section.
We are also writing to emphatically protest the State's attempt to further delay the Green Line
Extension (GLX), and we urge that the project be put back on schedule as legally required. As
such, we urge Federal and State government entities to enforce the legal and environmental
obligations (Federal Transportation Conformity Measures and SIP air quality) of the GLX
project to their full extent. The Green Line extension is a legal obligation under the Clean Air
Act, and the project should not be allowed to be delayed further. Full funding of the project and
any interim replacements must be identified in the Boston MPO 2012-2015 TIP and in the Long
Range Transportation Plan (LRTP).
Community Path: Lowell to Cedar Street
We wish to thank the MPO for the draft programmed 2012 TIP funds to be used for the
construc~ion of the next quarter-mile section ofthe Community Path frorp Cedar Street to Lowell
Street at the location of the Lowell Street GLX station. We request that the fInal 2012-2015 TIP
be approved with this funding intact. There were (at least) 138 letters written to the MPO in
March to support funding this section of the Community Path.
Page 10f7
Community Path and the Green Line extensions
There is ubiquitous regional support to extend the Community Path all the way to Lechmere and
North Point along with the Green Line extension project. We are attaching here over 200 letters
supporting the simultaneous construction of these projects. These letters were written just two
weeks prior to the State's August 151 announcement of its intention for further GLX delay.
However, it is clear from these letters that there is vast public support not only for the
Community Path extension, but also for the timely construction of the Green Line extension.
Delaying GLX project also delays the Community Path, since the two projects need to be
designed and built together. This proposed Community Path connector from Lowell Street
(Somerville) to LechmerelNorthPoint (East Cambridge) cannot be designed and built without
sharing infrastructure, right-of-way, and heavy construction with the Green Line extension.
Full funding of the Community Path should also be programmed in the 2012-2015 TIP and
LRTP along with the GLX. The GLX and Community Path are wonderful sustainable
transportation projects that will help more people get around with fewer car trips, curb
greenhouse gases, and provide needed regional economic development opportunities.
The Community Path will connect the walking and biking neighborhoods of Somerville and
Cambridge to four of the new Green Line Extension stations, bringing riders to the MBTA
system in the most cost-effective manner. Harnessing the synergy of these transportation modes
with mass transit will vastly increase Green Line extension ridership at a low cost per rider and
make the GLX a truly multi-modal project.
This Path will create a regional network of path connectivity of almost 50 miles of continuous
path to 11 Boston MPO cities and towns. The 2.3-mile Community Path connector project is the
missing link (as shown in the attached regional map) will link the Minuteman Bikeway network
and Charles River path network, producing a zero-emissions active transportation network.
The City of Somerville is not planning to apply for a TIGER III grant for the Community Path as
they did last year (i.e., TIGER II). The TIGER application requires a match, which was to be the
shared infrastructure construction (bridges, retaining walls, etc.) for the GLX from MassDOT.
With the pending GLX delay, MassDOT cannot make this shared infrastructure construction
commitment (estimated value of -$10 Million) in good faith now. Thus, this multi-million grant
opportunity for the Community Path is sadly lost at this time due to the pending GLX delay.
Getting the Green Line Back on Track
The original legal agreement in 1990 to extend the Green Line was revised in 2000 for planned
completion in 2011. Then it was delayed to 2014 in revisions to the State Implementation Plan
(SIP), legal obligations under the Clean Air Act. Then, last year MassDOT announced that the
Green Line Extension (GLX) would not open until 2015. Now, they have announced even more
delays, to 2018 to 2020. While the reasons given are claimed to be out ofMassDOT's control,
the delays can be alleviated by State funding of the GLX, a plan always envisioned if federal
funding is not forthcoming - which MassDOT admits is the case.
.. Legal
The Green Line extension has been the State's single largest Transportation Control Measure
(TCM) obligation under the State Implementation Plan (SIP) for air quality for twenty years.
Thus, it is a binding legal obligation under the Clean Air Act. Federal Transportation
Conformity Regulations require that SIP TCMs like the Green Line Extension must be given
funding and completion priority by the region and state. The Green Line Extension has never
been given top priority, even though the State is legally mandated to do so.
This newest proposed delay violates the Commonwealth's legal requirement to give highest
priority in all transportation planning documents to those projects the State has promised will
complete in order to become compliant with the federal Clean Air Act (SIP projects). The Green
Line Extension not only is one ofthose projects, but it is the one the State says this project will
provide by far the greatest air quality benefits. Therefore, money should be reallocated from
other optional and lower priority transportation projects to the GLX.
Meeting this legal obligation requires the Boston MPO to show realistic funding sources and
timely completion of the Green Line Extension in both the 2012- 2015 TIP and the
LRTP. Currently the TIP shows less than 50% of the money and less than 50% of the Green Line
Extension being completed by the legal deadline of2014. The state must pursue full bond
funding ofGLX to satisfy Federal Transportation Conformity.
The Draft 2012-2015 TIP and the Draft LRTP "Paths to a Sustainable Region" fail to meet both
the "fiscal constraint" requirement for full funding and the "environmental" requirement for
timely completion ofthe SIP Transportation Conformity Measures (TCMs). And, beyond the
binding legal obligations, MassDOT and the Commonwealth have failed over and over again to
meet promised deadlines given to the Green Line Extension communities
The state is legally obligated to extend the Green Line to Medford Hillside; a terminus station at
ColJege Avenue is not in Medford Hillside. Failure to allocate funding for the extension to Route
16 by current legal deadline (Dec. 31, 2014) also violates the existing legal requirement.
Health Impacts
The purpose of the Green Line Extension is to mitigate the health effects of vehicle pollution
from 1-93 and regional highway traffic, as well as regional ozone levels. Delaying completion of
the project without mitigation of the pollution will continue to negatively affect the health of
Somerville and regional residents. Somerville has the greatest daily exposure to commuter traffic
and diesel rail pollution in the state from 250,000 vehicles on 1-93, Mystic Avenue (Route 38)
and McGrath Highway (Route 28). Somerville also breathes fumes from 200 daily diesel
commuter and freight trains that cut through the City but (fortunately) do not stop.
The Green Line is desperately needed, especially in environmental justice neighborhood of East
Somerville and the economic justice neighborhood of East Cambridge.
People who live in the most transportation-polluted 10% of a large urban region may have:
•
•
•
•
20% higher overall mortality rates
50% higher lung cancer mortalities
50% higher heart attack mortalities
50% higher childhood asthma rates
Page 3 of7
Sustain ability
The Green Line Extension is an excellent, sustainable transportation project. With the GLX,
85% of Somerville residents will have access to rail and many of our neighbors in East
Cambridge, Medford and Arlington will have access to new light rail.
It is no wonder the Green Line is overwhelmingly supported in Somerville and surrounding
communities. The GLX light rail system will provides clean transit to the city most health­
burdened by highway and diesel commuter rail pollution.
The state points to the Green Line Extension as the hallmark of its "GreenDOT" environmental
campaign, and a key to achieving the Massachusetts Global Warming Solutions Act's
requirement to reduce statewide greenhouse gas emissions by 25% of their 1990 levels by 2020.
If this is the case, the project should be accelerated, not delayed. The Green Line Extension fully
embodies the principles espoused by MassDOT's GreenDOT initiative:
"GreenDOT, a comprehensive environmental responsibility and sustainability initiative
that will make MassDOT a national leader in ''greening'' the state transportation system.
GreenDOT will be driven by three primary goals: reduce greenhouse gas (GHG)
emissions; promote the healthy transportation options ofwalking, bicycling, and public
transit; and supportfor smart growth development"
hl1Q:iItranspo [tarion. b [OQ. state.ma. Lls/blog/20 1O/06/massdot -Iau nches-2.[ccndo t. html
Impact Of Delay On Transportation Funding and Regional/Statewide Economics
The GLX delay could jeopardize the State's federal transportation funding - a loss of$650
million per year. The delay would also:
• Significantly increase the cost of the GLX project and needlessly cost taxpayers statewide
$200 million or more, plus the costs of required air quality mitigation to offset the delay.
• Deny a key regional transit link for employers, universities, research centers and residents. • Result in significant loss of sales and income tax revenues to the Commonwealth because
it misses the opportunity to create construction and other jobs when we really need them.
• Cause us to miss the benefits seen by other regions in the country - such as Salt Lake
City, Utah and Dallas, Texas - that have recently built light rail on time and sometimes
under budget.
Funding, Timing and Transparency
Governor Patrick committed to build the Green Line Extension during his term in office.
Governor Patrick and Lieutenant Governor Murray must honor this commitment.
The Green Line Extension communities have repeatedly welcomed project staff from MassDOT,
the MBT A and their consultants. Cooperation, good rapport, and enthusiasm have generally
been high on both sides whenever people have rolled up their sleeves to tackle project details.
However, MassDOT has not been transparent at major steps with regard to securing real funding
for the project and making reasonable time commitments.
MA DOT states that securing federal "New Starts" funding for the Green Line is risky because
of the MBTA financial condition, but MassDOT has not demonstrated it has a funding plan and
.. design and construction schedule to meet the SIP requirements using only state funding - which
has been agreed to by the Commonwealth in the SIP agreement. Monthly SIP reports as recent as
May 2011, committed to completing the Green Line Extension at the end of2015, provide no
hint of further possible delays. This reflects a lack oftransparency and seriousness in meeting
the legal SIP requirements.
MassDOT's assertion that land acquisition is a primary factor in the latest delay is not
acceptable. Commuter rail track could be moved and track could be laid while waiting to acquire
land for the Ball Square and Union Square Stations. The Greenbush Line land acquisition delays
are not a valid comparison to the GLX because the land required for Greenbush was for right-of­
way. GLX land acquisition is not for right-of-way, but for station locations and the maintenance
facility. The maintenance facility not even included in the SIP agreement - and could be done
much later, after the rest of the GLX is built
The suggested phasing scenario proposed for constructing the GLX should only be permitted if
the State is legally bound to complete of the full GLX to Route 16 by 2018. By contrast: This
year, through the groundbreaking 1-93 Fastl4 Bridge Replacement Project, the state
demonstrated a new commitment to completing transportation projects on time and on budget.
The Green Line Extension project deserves an infusion of the same commitment and innovation,
not yet another delay.
In summary, we hope our public comments have presented the compelling and even
overwhelming case not to allow MassDOT to delay the Green Line Extension (and Community
Path Extension) any longer.
Thank you very much.
Sincerely,
l
,
.
.
J
(~.>.~;/)~.-;../ ,~~:!.~/~·.~~:;,t;:'·:~.~.i~~t.i~f_
I
,
\.../
Lynn Weissman and Alan Moore
Co-Presidents, Friends of the Community Path
"To Lechmere - and beyond!"
Attachments:
• Map of proposed Community Path along the GLX Route
• Over 200 letters supporting the Community Path and GLX Projects (to MPO, DEP,
Governor Deval Patrick, Lieutenant Governor Timothy Murray, Congressman Michael Capuano,
MassDOT Board)
cc:
Governor Deval Patrick
Lt. Governor Timothy Murray
Page 5 of7
Ms. Anne Arnold, Manager, EPA Region I Air Quality Planning Unit,
Mr. Donald Cooke, Conformity and mobile monitoring, EPA Region 1 Air Quality, Ms.
Rosemary Monahan, EPA Region 1 Smart Growth Coordinator
Ms. Pamela Stephenson, MA Division Administrator, Federal Highway
Mr. Michael Chong, Federal Highway Planning and Environ. Program Manager
Ms. Mary Beth Melio, Regional Director, Federal Transit Region 1
Congressman Michael Capuano
MassDOT Board of Directors
Transportation Secretary Rich Davey
Ms. Katherine Fichter, MassDOT Office of Transportation Planning,
Mayor Joseph Curtatone, City of Somerville
Hayes Morrison, City of Somerville
Sara Spicer, City of Somerville
Somerville Board of Aldermen
Senator Patricia Jehlen
Representative Denise Provost
Representative Carl Sciortino
Representative Timothy Toomey
Ellin Reisner, STEP
Complete the Community Path!
The missing link in the regional network
Community Path
(partial funding)
Page 7 of7
Community Path
(no funding)
clf
.•-------­
For a thriving New England
elF Massachusetts 62 Summer Street
Boston, MA02110
P: 617.350.0990
F: 617.350.4030
www.clf.org
conservation law foundation September 13,2011
Katherine S. Fichter Massachusetts Department of Transportation Office of Transportation Planning 10 Park Plaza, Room 4150 Boston, Massachusetts 02116 RE: 2011 State Implementation Plan Transit Commitments Status Report
Dear Ms. Fichter:
The Conservation Law Foundation ("CLF") has reviewed the State Implementation Plan
("SIP") Transit Commitments Status Report filed on July 27,2011 ("2011 SIP Status Report").
CLF is alarmed about the escalation of estimated project delays and the lack of sufficient
expenditure of funds to ensure that all of the remaining SIP projects are completed and on
schedule. The Commonwealth's legal obligation to complete these projects is binding under the
federal Clean Air Act and pursuant to the settlement agreement in CLFv. Romney et aI., United
States District Court for the District of Massachusetts, Civil Action No. 05-1048 (hereinafter,
CLF v. Romney); the projects are crucial to achieving attainment of ambient air quality standards,
and are vital to the health and mobility of the area's residents.
The SIP requires that status reports be filed annually to ensure that projects do not fall
behind schedule and the necessary steps are taken so that compliance with the Clean Air Act is
not delayed in the event that challenges arise. 1 We urge the Massachusetts Department of
Transportation ("MassDOT" or "Department"), the Massachusetts Department of Environmental
Protection ("DEP"), and the U.S. Environmental Protection Agency ("EPA") to take all
necessary actions to respond to the delays, reduce them, and avoid the need for additional future
delays. This should include the provision and implementation of detailed and expedited project
schedules, and, where necessary and permissible, identification of interim emission reduction
offset projects or measures ("Interim Offset Projects"). See 310 CMR 7.36(4). Such Interim
Offset Projects should be identified through a transparent and thorough community public
participation process. In addition, CLF requests that DEP require a mid-year status report to be
filed by MassDOT by December 31, 2011, on the Fairmount Line Improvements, the Green Line
Extension, the construction of one thousand additional parking spaces, the design of the Red
Annual SIP Status Reports are due on July I 51 of every year. See 310 C.M.R. 7.36(7). This year's report was
submitted late again on July 27,2011; as a result, MassDOT failed to comply with the state and federal reporting
obligation.
I
ClF MAINE
ClF MASSACHUSETTS
ClF NEW HAMPSHIRE
ClF RHODE ISLAND
.
ClF VERMONT
Line/Blue Line Connector, and the Blue Line Platform Lengthening and Modernization, since all
of these projects are significantly behind schedule. More detailed comments on each of the
projects discussed in the SIP Status Report and the need for Interim Offset Projects are provided
below.
Green Line Extension
In its 2010 SIP Status Report, MassDOT indicated that the Green Line Extension Project
would be delayed approximately ten months past the SIP deadline of December 31, 2014, until
October of2015. Only one year later, in the 2011 SIP Status Report, MassDOT is now
estimating a further delay of at least three years, and more likely four or five years. See 2011
SIP Status Report at 18. This additional delay is based not on any adverse developments during
the past year, or on any new information, but rather simply on further analysis of the same facts.
See id. at 17. It therefore appears that this additional delay is either not necessary or, if it is,
should have been revealed to the public much earlier consistent with the SIP requirement to
provide "detailed information about any actual or known potential need and reasons for project
delays or substitution." See 310 CMR 7.36 (7)(a)4. Regardless, this new timeline is clearly
inconsistent with the SIP and the 2006 eLF v. Romney settlement agreement.
To date, MassDOT has failed to disclose detailed information about reasons for the
project delay, to petition to delay the project, and to identify any Interim Offset Projects that
might be implemented, as required by the SIP. See 310 C.M.R. 7.36(4) and (7). Plainly,
MassDOT is aware of facts that led to its decision to delay the project; the rule is in place to
ensure that the public, regulators, and other agencies understand the basis for MassDOT's
decision at the time it is announced, not months or years after the fact. MassDOT should
promptly provide an updated and detailed project schedule that provides information about how
and when each phase of the Green Line Extension will be completed and states specific reasons
for the delay.
In its 2011 SIP Status Report, MassDOT states that the new estimates for the delays of
the Green Line Extension project stem from a "cost/schedule/risk analysis" that was performed
based on the results of a Federal Transit Authority Project Management Oversight Consultant
Risk Assessment Workshop. See 2011 SIP Status Report at 17. Despite numerous requests by
CLF and others, MassDOT has still not provided copies of the documents associated with this
analysis nor released the information obtained through this process. MassDOT's refusal to make
that information publicly available violates the Transit System Improvement regulations. See
310 C.M.R. 7.36(4). Likewise, MassDOT should involve the public in the identification and
selection of any Interim Offset Projects. CLF together with other stakeholder last year, in a letter
dated September 22, 2010, provided a list of suggested interim offset proj ects and measures to
MassDOT, but has not received a substantive response. CLF hopes that MassDOT will consider
and analyze all of these proposed Interim Offset Projects closely as it develops a plan to address
the SIP project delays. Last year's SIP Status Report stated that MassDOT did not intend to
2
clf
For a thriving New EngLand
elF Massachusetts •
62 Summer Street
Boston, MA 02110
P: 617.350.0990
F: 617.350.4030
www.clf.org
conservation law foundation
make any information about Interim Offset Projects available until January of2011. See 2010
SIP Status Report at 18. MassDOT never made such information available. This year's report
does not even mention a date by which MassDOT intends to propose Interim Offset Projects.
See 2011 Status Report at 19.
As CLF stated last year, seeking public input that late in the Interim Offset Project
selection process is almost like closing the barn door after the horse has already left. It is
crucially important for MassDOT to seek public input at the time it is investigating ideas for
interim offset projects and measures. Considering that the Green Line Extension project enjoys a
high level of involvement by knowledgeable members of the public, MassDOT should offer an
early public participation opportunity that seeks and collects ideas for potential Interim Offset
Projects. MassDOT could then choose the best options for each of the SIP projects, taking the
communities' ideas, concerns, and interests into consideration. MassDOT could then propose
these options to DEP as part of its petition. A public comment period following its selection
would allow for additional input after MassDOT has made its choices.
As our September 22, 2010, letter reflects, all suggested Interim Offset Projects should be
located in the neighborhoods that are intended to benefit from emissions reductions attributable
to the Green Line Extension project. While CLF recognizes that keeping the Interim Offset
Projects in the same neighborhoods as the delayed transit commitment is not a legal requirement
of the SIP, we strongly believe that failing to adhere to this approach would be patently unfair.
CLF therefore strongly recommends that all Interim Offset Projects considered be located in the
respective neighborhoods of the delayed projects. Specifically, for the Green Line Extension
Project, the Interim Offset Projects should be located in and serve the Somerville, Medford and
Cambridge neighborhoods that are adj acent to the extension of the Green Line. All Interim
Offset Projects shall achieve emission reductions equal to or greater than the emission reductions
that would have been achieved had the project not been delayed. See id.
Repeating last year's and the previous year's SIP Status Report omission, the 2011 SIP
Status Report also does not provide adequate information about the Commonwealth's funding
plan for the Green Line Extension. CLF hereby renews, once again, its request that MassDOT
complete and make publicly available a detailed funding plan for the Green Line Extension
Project. The funding plan should cover the fifty percent state match required if the project
receives federal funds through New Starts as well as the complete projected cost ofthe project in
case no federal funding is obtained.
CLF continues to be troubled by the proposed segmentation of the Green Line Extension
Project into two phases, which makes even less sense if one considers MassDOT's proposed
delays of the project until at least 2018. To comply with the SIP, MassDOT must construct an
extension of the Green Line "from Lechmere Station to Medford Hillside" by December 31,
2014. See 310 C.M.R. 7.36(2)0)1. The Green Line Extension Project, as proposed, does not
3
CLF MAINE
CLF MASSACHUSETTS
CLF NEW HAMPSHIRE
CLF RHODE ISLAND
•
CLF VERMONT
comply with the SIP, since Medford Hillside's well-documented historical boundaries do not
include the location of the proposed terminus at the intersection of College Avenue and Boston
Avenue. 2 Any petition to delay the project should therefore include the full extension to Route
16.
MassDOT continues to declare that it is committed to the Green Line Extension Project.
This year's SIP Status Report, unfortunately, belies those assertions. Without going into any
details, MassDOT cites primarily two reasons for the additional delay-the need to take full
ownership of all private property of any substantial size required for the construction of the
project and the challenges involved in obtaining federal funding. See 2011 SIP Status Report at
16 and 18.
It is difficult to accept MassDOT's assertion that land acquisition is a significant factor in
the latest delay estimate considering that no changes in the need for the purchase of private
property have occurred over the last year, the complete right of way for the project is already
owned by the Commonwealth, and most of the private property required for the project is either
small or within geographic areas outside the SIP requirement, e.g., the maintenance facility. In
the past, MassDOT has stated that it is "guided by a commitment to minimize any impacts on
private property from this project" and that "the potential need to acquire additional property is
limited to those areas where stations will be constructed or where the right-of way is too narrow
to accommodate the service." MassDOT Green Line Extension Project, Property Impacts Fact
Sheet. 3 Even if private acquisitions are necessary, commuter rail tracks could be moved, Green
Line tracks could be laid, and stations could be built while waiting to acquire land for the
maintenance facility and the few stations that require use of private land. MassDOT cites the
Greenbush Line land acquisition delays as a lesson learned for the Green Line Extension project
but this does not provide a valid comparison since the land acquisition required for the
Greenbush Line was for the right of way. See 2011 SIP Status Report at 18.
While it is permissible and sound financial policy for the Commonwealth to apply for
federal funding to comply with the SIP, the SIP transit system improvement commitments are a
state obligation regardless whether MassDOT secures any federal funding for the project. From
the 2011 SIP Status Report, it appears that MassDOT is delaying the project in order to wait for
federal funding to become available. Delay on that basis would be unlawful. Delaying the
construction of the extension will only make this important project more costly in the future.
Comedian Will Rogers once joked, "Even if you're on the right track, you'll get run over if you
For a more detailed explanation of this issue, please see eLF's comments on the Draft and Final Environmental
Impact reports for the project available at
http://www.greenlineextension.orgldocuments/FinaIEIRlVoI2and3/71 GLX FEIR V2 CommOrg30f5 20100615.
ru!f and at http://www.greenlineextension.orgldocuments/FinalE 1R/certificate/FE 1R CommentsPart4.pdf
respectively.
3 http://www.greenlineextension.orgldocuments/aboutiTopics/GLX Propertvlmpacts F web. pdf (last viewed
September 13,2011).
2
4
clf
For a thriving New England
elF Massachusetts &
62 Summer Street
Boston, MA 02110
P: 617.350.0990
F: 617.350.4030
conservation law foundation
www.clf.org
just sit there," The Commonwealth for now appears to have chosen to sit on the right track
rather than to build it.
Fairmount Line Improvement Project
Despite the fact that it has been known and acknowledged that the Fairmount Line
Improvement Project will be delayed since at least March of2010, it took MassDOT sixteen
months-until July 27 of this year-to comply with its SIP obligation timely to submit to DEP a
petition to delay the project ("Petition"). See 310 CMR 7.36(4)(c). The SIP requires a petition
to delay to be filed following disclosure of a delay, not at some undetermined point in the future.
MassDOT does not cite any reason for its noncompliance.
For the Fairmount Line Improvement Project, MassDOT is proposing two interim offset
measures: shuttle bus service from Andrew Square to Boston Medical Center and increased bus
service in Roxbury-Dorchester-Mattapan through Routes 29 and 31. We are pleased to see that
the proposed offset measures incorporate one of the ideas that the Fairmount/Indigo Line
Coalition put forward (shuttle bus service from Andrew Square to Boston Medical Center) and
that both measures are targeted to benefit the neighborhoods most impacted by the delay in the
Fairmount Line.
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 the assumptions (such as the
level of increased frequency, scheduling, and size of busses of the additional proposed service)
upon which its analysis is based. In addition, the Petition did not include the Central
Transportation Planning Staff (CTPS) studies upon which the estimates were based and without
which it is impossible to assess whether the projects meet the SIP requirement to offset the lost
air quality benefits during the period of delay. Through subsequent communication with
MassDOT, CLF has received information about some of the assumptions used in the analysis
(the modeling for the Route 31 bus was done with five minute headways during peak and ten
minute headways during off-peak hours, the Route 29 bus with ten minute headways during peak
and twenty minute headways during off-peak hours, and the Andrew/BMC shuttle was done with
twenty four minute peak headways), as well as the estimated mobile source emissions on an
average weekday in 2012 for all the interim offset projects and measures considered, attached
hereto as Exhibit A. These data have not been shared by CTPS or MassDOT with the public,
and we provide them to DEP in the event that DEP has also not had the opportunity to review
them. CLF has not seen the CTPS studies and we understand that they have not been provided to
the public, or to DEP.
At the same time, we are disappointed that the MBTA is not including a fare reduction on
the Fairmount Line during the period of delay as one of the interim emission offset measures, as
was proposed by the Fairmount Line/Indigo Coalition (the "Coalition") last year. By fare
5
CLF MAINE
CLF MASSACHUSETTS
CLF NEW HAMPSHIRE
CLF RHODE ISLAND
.
CLF VERMONT
reduction, we refer to making the $1.70 transit fare applicable to the whole line, including the
two stations in Hyde Park (Fairmount and Readville) which now have fares of$4.25 and $4.75
respectively. The Coalition proposed this offset measure because it would most directly help the
people impacted by the delay in the construction of the stations. Moreover, it offers a great
opportunity to help market the Fairmount Line as the stations are being built and work towards
increasing ridership, whereas the increased bus service proposed distracts from the opportunity
to promote usage of the Fairmount Line. Measures to improve service and increase ridership on
the Fairmount Line are required by the SIP. See 310 CMR 7.36(2)(h)1. CTPS analyzed the
potential emission reduction benefits of reducing the fare and should make its analysis available
to DEP and the public. The summary of mobile source emissions on an average weekday in
2012, which summarizes CTPS' s findings, shows that combined with providing shuttle service
from Andrew Square to Boston Medical Center the fare reduction would provide the required air
quality benefits during the period of the delay. See Exhibit A. CLF therefore respectfully
requests that DEP require the inclusion of the fare reduction as one of the interim emission offset
measures to counter the negative impacts of the delays of the Fairmount Line Improvement
Project.
Construction of 1,000 New Parking Spaces
Since MassDOT has not been able sufficiently to advance the parking garage projects at
the Salem and Beverly commuter rail stations originally slated for fulfilling this transit
commitment, it decided last year, on its own accord, to shift its focus for meeting the December
31, 2011, deadline to the proposed South Garage at Wonderland Station in Revere. MBTA is
building this garage in coordination with the larger Waterfront Square development at Revere
Beach. Last year, MassDOT touted this project as an effective way to meet its obligation under
the SIP, despite CLF's concern that due to the multi-use nature of the Waterfront Square
development the number of spaces actually available for users of the MBT A's public transit
system will be smaller than predicted and therefore too small to contribute sufficiently to SIP
compliance. See CLF's comments on the 2010 SIP Status Report attached hereto as Exhibit B.
CLF also warned last year that since South Garage was then estimated to be completed by
November of2011, even a small delay would cause MassDOT to miss this SIP commitment
deadline. Now, MassDOT estimates that the Wonderland Project will be delayed until sometime
during the spring of2012, and as a result announced that it will not be able to meet its obligation
to construct 1,000 new park and ride parking spaces by December 31, 2011, although it had five
years to build them.
Despite the delay, the length of which is so uncertain that MassDOT can only state a
season, not even a month of completion for the project, MassDOT proposes to put in place not a
single interim emission project or measure, in clear violation of the SIP. See 310 CMR
7.36(4)(b). In an attempt to justify this request, MassDOT engages in a tortured analysis that is
based on its assumption that the South Garage facility at Wonderland would be underutilized due
to the availability of private parking lots in the area, which cost between $2 and $3 less than
6
cf -­
For a thriving New England
elF Massachusetts 62 Summer Street
Boston, MA 02110
P: 617.350.0990
•conservation
law foundation F: 617.350.4030
www.clf.org
what MassDOT was planning to charge its transit commuters at the parking garage, As result of
this underutilization, MassDOT concludes there would have been no short-term air quality
benefits from the project it freely selected to fulfill one of the Commonwealth's requirements
under the Clean Air Act. While it is troubling that MassDOT questions the air quality benefits of
the parking facility it chose to meet over sixty percent of the requirement to construct one
thousand new park and ride parking spaces, there is no doubt that the creation of over six
hundred parking spaces near transit facilities in any appropriate location, would have a
considerable positive impact on air quality, as it makes it easier for commuters to leave their cars
behind. This reasoning also exposes MassDOT's failed strategy to count parking spaces that are
already being constructed towards the SIP requirement, although these spaces are at a location
where there is an existing oversupply of parking and MassDOT is planning to charge more than
everyone else.
In addition to South Garage, MassDOT is also counting almost four hundred existing
parking spaces in Beverly, Dorchester, Newton and Quincy towards this transit commitment. To
comply with the SIP requirement, however, one thousand additional parking spaces have to be
constructed rather than merely provided. See 310 CMR 7.36(2)(h)2 ("Before December 31,
2011 , construction of the following facilities shall be completed and opened to full public
use: ... 1000 new park and ride parking spaces serving commuter transit facilities ... ) (emphasis
added). The parking spaces near the Beverly commuter rail station, at least, appear only to have
been opened to the public but have not been constructed. For the Savin Hill Station, the MBT A
does not list any availability of parking spaces on its website, even though some exist. See
http://www.mbta.com/schedules and maps/subway/lines/stations/?stopld= 14289&lat=42.31109
9&lng=-71.053175 (last visited September 1,2011).
DEP should therefore deny MassDOT's Petition pursuant to 310 CMR 7.36(4)(c) and
require MassDOT to propose Interim Offset Projects for the time period of the delay. In
addition, considering MassDOT's own negative analysis of the lack air quality benefits from the
proposed South Garage at Wonderland, at least in the short-term, MassDOT should be required
to choose another location to meet this SIP requirement.
Blue Line Platform Lengthening and Station Modernization
MassDOT failed to include the Blue Line Platform Lengthening and Station
Modernization project in its 2011 Status Report. CLF disagrees with MassDOT's continued
claim that its obligations under this SIP commitment are complete by virtue of implementing six­
car train service despite the failure to modernize all Blue Line stations. The SIP requires both
Blue Line platform lengthening and station modernization. See 310 CMR 7.3 6(2)(g) ("Before
December 31 , 2008, construction of the following facility shall be completed and opened to full
public use: Blue Line Platform Lengthening and Modernization." (emphasis added)).
MassDOT's failure to report on this commitment therefore violates the law. Furthermore, both
components of this project are necessary to achieve the increased ridership and attendant
7
ClF MAINE
ClF MASSACHUSETTS
ClF NEW HAMPSHIRE
ClF RHODE ISLAND
.
ClF VERMONT
improved air quality required under the Clean Air Act through the SIP. Increased ridership is a
function of available capacity, access, and attractiveness of service. Modernization of old,
inaccessible, uncomfortable, and otherwise non-user friendly stations and facilities leads to
increased ridership and thus to improved air quality.4
The failure to modernize all Blue Line stations is a continuing violation of the SIP, which
required that Blue Line station modernization be completed by December 31, 2008. As of
September of 20 11, the following stations have been modernized: Aquarium, Beachmont,
Revere Beach, Suffolk Downs, Wood Island, Wonderland, Maverick, and State. The difference
in appearance of the stations that have been completed speaks volumes for the importance of this
requirement. The 2009 SIP Status Report indicated that Orient Heights Station modernization
will commence in the Spring of2010, however, no such work has begun yet. The delays of the
modernization of the remaining Blue Line stations to be modernized (Orient Heights,
Government Center, and Bowdoin) are significant and the reasons for them largely unspecified.
DEP should therefore require continued status update reports and Interim Offset Projects for the
delay in completion of this commitment. MassDOT, in tum, should make every effort to hasten
the completion of this overdue commitment.
CLF remains pleased that all work has been completed to accommodate six-car trains and
that eighty-two new Blue Line vehicles have been in service since September 15,2008. This is a
major achievement. The increased capacity on the Blue Line is already relieving overcrowding
and improving quality of service for riders. When coupled with full modernization of the Blue
Line, CLF is confident that even more riders will be attracted to the service and this increased
capacity will be well-utilized.
Red Line-Blue Line Connector
Under the Clean Air Act, states are assigned the primary responsibility to achieve and
maintain compliance with the national ambient air quality standards ("NAAQS"). To this end,
Massachusetts has adopted the SIP, which contains the projects and measures relied on to satisfy
the state's obligations to achieve and maintain the NAAQS. In 2008, the Commonwealth sought
and received approval for its revised SIP, which is the subject of the 2011 SIP Status Report.
The Commonwealth included the design of the RedIBlue Line Connector ("Connector") in its
revised SIP, recognizing and relying on the associated air quality benefits. Now, only three years
after the revised SIP was approved, MassDOT is denying that the same project has any merit and
is seeking to remove it from the SIP claiming that it does not help the state meet national ambient
air quality standards. In its request to DEP ("Request"), MassDOT reasons that there are no air
4 See,.!<..&, Stacey Falzarano, Richard Hazlett, and Thomas Adler, Quantifying the Value ofTransit Station and
Access Improvements for Chicago's Rapid Transit System (Transportation Research Board Paper No. 01-2987, Jan.
2001).
8
clf
•
For a thriving New England
elF Massachusetts 62 Summer Street
Boston, MA 02110
­
P: 617.350.0990
F: 617.350.4030
conservation law foundation www.clf.org
quality benefits associated with the design of a transit project, calling it a "purely procedural
requirement," which raises the question why the Commonwealth would have included the
Connector in the revised SIP in the first place. Based on its inclusion in the revised SIP, the
Commonwealth should be precluded from arguing now that the design of a transit project has no
calculable air quality benefits.
Moreover, there are clearly air quality benefits associated with designing a transit project.
For a transit project to be constructed, it has to be designed first. Frequently funding becomes
available for a transit project only after it has been designed. Despite MassDOT's grim
prognosis ofthe availability of federal funding, increasingly only projects that are shovel-ready
are eligible to apply when federal funding opportunities arise. Thus designing a transit project,
more than anything else, raises its chances of ever being built. As a result, air quality benefits
can be calculated by applying a discounted percentage of those the constructed project would
produce. This percentage can take the estimated likelihood of construction, at the time of the
inclusion in the SIP, into consideration. In 2006, the Commonwealth estimated that the
Connector would reduce emissions of carbon monoxide by 156 kilograms, nitrogen oxides by 4
kilograms, and volatile organic compounds by 9 kilograms per day. See DEIR, Appendix E, at
3-16 and Central Transportation Planning Staff ("CTPS"), "Description of Modeling
Assumptions and Analysis Methodology for the State Implementation Plan Transit Commitment
Projects Current and Proposed Substitutions," December 28,2006, revised March 15,2007
("2006 SIP Analysis"). Even if discounted by ninety percent, the design of the Connector would
still provide emission reductions of 15.6 kilograms for carbon monoxide, 0.4 kilograms for
nitrogen oxides, and 0.9 kilograms for volatile organic compounds per day.
The fact that these air quality benefits from the Connector were previously not included
in the air quality model for the revised SIP does not make the project any less of an obligation.
The EPA approved the revised SIP expecting that the estimate for the revised SIP is leaving the
Commonwealth some room for error-the Connector helped to create that necessary buffer.
Thus, it is not permissible for the Commonwealth to simply remove that project now.
Ultimately, the SIP has to allow the Commonwealth to attain compliance with the NAAQS,
currently Eastern Massachusetts continues to be in non-attainment for ozone. To be able to
properly evaluate this request to amend the Transit System Improvement Regulations, DEP
should require MassDOT to remodel the air quality benefits expected from the projects in·the
revised SIP and then compare them to those of the remaining transit system improvement
projects without the Connector.
It is also worthy to note that in an attempt to justify its request to simply be relieved from
an important SIP requirement, although only a few years have passed, MassDOT claims that the
cost of designing the Connector has gone up significantly. See Request at 3. MassDOT explains
that the design costs, which are typically ten percent of the total construction costs, have
increased because the ultimate construction costs of the project are estimated to "far outstrip" the
cost projections in place at the time that the SIP regulation was promulgated. Id. MassDOT lists
9
ClF MAINE
ClF MASSACHUSETTS
ClF NEW HAMPSHIRE
ClF RHODE ISLAND
.
ClF VERMONT
a number of factors that may have contributed to an increase in the estimated cost of the
Connector. See id. at 3-4. Among those, MassDOT admits to budgeting a much more
conservative contingency for the most recent cost estimate, but fails to disclose that it also
included a higher inflation rate. Likewise, the Department does not explain that it used less
favorable assumptions to estimate the cost of the Connector than any other transit project it
currently is planning. But without markups, the raw-cost estimate for construction of the Red
Line/Blue Line Connector is about $336 million rather than the $748 million figure MassDOT
relies upon to support its request. See Red LinelBlue Line Connector Project 10% Design Cost
Estimate, Basis of Estimate, at 1. At the time of the SIP revision, in July of2008, the
Commonwealth's estimate was $290 million for construction of the project, which is not as
significant of a difference.
Specifically, the total cost estimated for the Connector included a forty percent
contingency (up from a twenty percent contingency applied in earlier planning stages of this
project) and an inflation rate of 4.2% (although construction cost changes are currently under
two percent as is general inflation, and inflation is not expected to increase significantly any time
soon). To make matters worse, these add-ons are not applied equally to every project MassDOT
is planning. As a comparison, for the ongoing South Coast Rail Project, MassDOT is applying a
lower contingency (31.70% instead of 40%), a lower inflation rate (3.25% instead of 4.20%), and
a lower design cost estimate (13.44% of present construction cost not including the contingency
instead of 14% of present construction cost plus the contingency which translates into 19.6%
without the contingency). See South Coast Rail, Alternative Description Technical Report at 4­
53 (September 2009). Thus, a careful review of MassDOT's numbers reveal that the "dramatic
increase" in project costs the Department describes in its letter is also a result of the application
of a particularly and deliberately conservative budgeting approach for the Red Line/Blue Line
Connector.
Conclusion
MassDOT's disregard for the SIP disclosure requirements, the projected delays for the
Green Line Extension, the Fairmount Line Improvements, the one thousand additional park and
ride parking spaces serving commuter transit facilities, the failure to acknowledge that the Green
Line Extension as planned does not comply with the SIP, the request to eliminate the
requirement to design the Red Line/Blue Line Connector, and the continued delay of the Blue
Line Platform Lengthening and Modernization raise serious concerns regarding the lawfulness of
MassDOT's activities and its compliance with the public process and reporting requirements of
the SIP. See 310 CMR 7.36(7). It took almost one year from last year's annual SIP status report
public meeting for DEP to issue its certification that MassDOT has met its public process
requirements, that complete information was provided on actual or known project delays, project
substitutions, and interim offsets. It took almost another month for that information to be
released to the public by MassDOT. DEP must provide greater oversight and order MassDOT to
comply with all the requirements of the SIP, including its public process and reporting
10
clf
For a thriving New England
elF Massachusetts 62 Summer Street
Boston. MA 02110
P: 617.350.0990
•
F: 617.350.4030
www.clf.org
conservation Law foundation
requirements, prior to certifying the 2011 SIP Status Report and MassDOT must allocate all
needed funding and take all necessary steps to complete the SIP commitments as quickly as
possible.
Thank you for the opportunity to comment.
Sincerely,
/ Y::.·/.4:/e /
Rafael Mares
Staff Attorney
cc Donald Cooke Air Technical Unit US Environmental Protection Agency - Region 1 5 Post Office Square, Suite 100 Mail Code OEP05-2 Boston, MA 02109 Christine Kirby Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 11
ClF MAINE
CLF MASSACHUSETTS
CLF NEW HAMPSHIRE
CLF RHODE ISLAND
•
CLF VERMONT
EXHIBIT A SIP Air Quality Analysis: Strategies for Fairmount Commuter Rail Station Delay Mobile Source Emissions on an Avera
Description
A
4 New Fairmount Stations
42,071.4
90,851.3
1,256,789.4
B
Existing Conditions
Target (A - B)
42,071 .7
90,851.9
1,256,799.6
C
sp, ctps
-0.34
-0.67
-10.26
D
Provide a bus shuttle service from Andrew Square to
Boston Medical Center
-0.25
-0.546
-9.214
E
Reduce Fairmount and Readville commuter rail fares
to $1.70.
-0.66
-0.22
-5.22
F
Increase peak-period service at the existing
Fairmount commut.er rail stations.
G
Implement the proposed Roxbury-Dudley-Mattapan
Express Bus Service - Rte 29 & Rte 31.
H
Weekend and off-peak service on the Fairmount
Line.
I
Youth Pass
unavailable
unavailable
unavailable
-0.42
-0.52
-3.65
unavailable
-1 .05
unavailable
-2.09
unavailable
-31 .81
C:\Documents and Settings\digi\My Documents\SIP-Legal(RB)\Fairmount\fairmount-sip_11 0621.xls, fairmount-sip_11 0621.xls
7/8/2011
EXHIBITB ,
CONSERVATION LAW FOUNDATION
September 30, 2010
Katherine S. Fichter
Massachusetts Department of Transportation
Office of Transportation Planning
10 Park Plaza, Room 4150
Boston, Massachusetts 02116
RE: 2010 State Implementation Plan Transit Commitments Status Report
Dear Ms. Fichter:
The Conservation Law Foundation ("CLF") has reviewed the State Implementation Plan
Transit Commitments Status Report flIed on July 9,2010 ("SIP Status Report"). We are pleased
that the Commonwealth continues to advance the transit commitments in the State
Implementation Plan ("SIP") and appreciate the progress that has occurred during the past year.
At the same time, however, CLF remains concerned about the proliferation of project delays and
the lack of sufficient expenditure of funds to ensure that all of the remaining SIP projects are
completed on schedule. The Commonwealth's legal obligation to complete these projects is
binding under the federal Clean Air Act; the projects are crucial to achieving attainment of
ambient air quality standards, and are vital to the health and mobility of the area's residents.
The SIP requires that status reports be filed annually to ensure that projects do not fall
behind schedule and the necessary steps are taken so that compliance with the Clean Air Act is
not delayed in the event that challenges arise. 1 We urge the Massachusetts Department of
Transportation ("MassDOT'), the Massachusetts Department of Environmental Protection
("DEP") and the U.S. Environmental Protection Agency ("EPA") to take all necessary actions to
respond to the delays, and avoid the need for additional future delays. This should include the
provision and implementation of detailed and expedited project schedules, and, where necessary
and permissible, identification of interim emission reduction offset projects or measures
("Interim Offset Projects"). See 310 C.M.R. 7.36(4). Such Interim Offset Projects should be
identified through an upfront and thorough community publiC participation process. In addition,
CLF requests that DEP require a mid-year status report to be filed by MassDOT by December 31,
2010 on the Fairmount Line Improvements, the Green Line Extension, the construction of one
thousand additional parking spaces, and the Blue Line Platform Lengthening and Modernization,
since all of these projects are significantly behind schedule. More detailed comments on each of
st
I Annual SIP Status Reports are due on July 1 of every year. See 310 C.M.R. 7.36(7). This year's report was
submitted late on July 9, 2010; as a result, MassDOT failed to comply with the state and federal reporting obligation.
62 Summer Street, Boston, Massachusetts 02110-1016· Phone: 617-350-0090· Fax: 617-350-4030· www.clf.org
MAINE: 47 Portland Street, Ste. 4, Portland, Maine 04101·9872·207·210-6439· Fax: 207·221·1240
NEW HAMPSHIRE: 27 North Main Street, Concord, New Hampshire 03301-4930 • 603·225·3060 • Fax: 603-225·3059
RHODE ISLAND: 55 Dorrance Street, Providence, Rhode Island 02903·2221 ·401·351·1102· Fax: 401-351·1130
VERMONT: 15 East State Street, Suite 4, Montpelier, Vennont 05602·3010 • 802·223·5992 • Fax: 802·223-0060
CONSERVATION LAW
FOUNDATION
the projects discussed in the SIP Status Report and the need for Interim Offset Projects are
provided below.
Green Line Extension
After missing a significant interim deadline for the Green Line Extension Project in
2008-the Draft Environmental hnpact Report was due on December 1, 2008 but was not filed
until more than ten months later-MassDOT has made significant progress over the last year in
the planning and environmental review phases of the project. Since October of 2009, MassDOT
has submitted both draft and final environmental impact reports and has reevaluated and
changed, with significant community input, the location of the vehicle storage and maintenance
facility. MassDOT, however, now estimates a delay of ten months for the completion of the
Green Line Extension, even though it has impermissibly limited the scope of the project by
proposing to end the main branch of the extension at College AvenuefTufts rather than in
Medford Hillside, as required by the SIP.2
To date, MassDOT has failed to disclose detailed information about reasons for the
project delay, to petition to delay the project, and to identify any Interim Offset Projects that
might be implemented, as required by the SIP. See 310 C.M.R. 7.36(4) and (7). The SIP Status
Report states that MassDOT does not intend to make that information available until January of
2011. SIP Status Report at 18. Plainly, MassDOT is aware of facts that led to its decision to
delay the project; the rule is in place to ensure that the public, regulators, and other agencies
understand the basis for MassDOT's decision at the time it is announced, not six months after the
fact. MassDOT should promptly provide an updated and detailed project schedule that provides
information about how and when each phase of the Green Line Extension will be completed and
specific reasons for why it is delayed. MassDOT should also involve the public in the
identification and selection of any Interim Offset Projects, as described further below for all
delayed transit projects.
Repeating last year's SIP Status Report omission, the SIP Status Report also does not
provide adequate information about the Commonwealth's funding plan for the Green Line
Extension. CLF hereby renews its request that MassDOT complete and make publicly available
a detailed funding plan for the Green Line Extension Project. The funding plan should cover the
fifty percent state match required if the project receives federal funds through New Starts as well
as the complete projected cost of the project in case no federal funding is obtained.
CLF continues to be troubled by the proposed segmentation of the Green Line Extension
Project into two phases. eLF is particularly concerned with MassDOT's assertion in the SIP
Status Report that "[a]n extension of the Green Line to Route 16IMystic Valley Parkway is
outside of the bounds of the SIP commitment." SIP Status Report at 15. To comply with the
SIP, MassDOT must construct an extension of the Green Line "from Lechmere Station to
In addition, as a result of the recent MassDOT Board of Directors' decision to require new procurement for
preliminary engineering services rather than amendment of an existing contract, a further delay of two to three
months can be expected.
2
eLF: "Protecting New Eng/and's Environmenr
2
CONSERVATION
LAW
FOUNDATION
Medford Hillside" by December 31, 2014. See 310 C.M.R. 7.36(2)0) 1. The Green Line
Extension Project, as proposed, does not comply with the SIP, since Medford Hillside's well­
documented historical boundaries do not include the location of the proposed terminus at the
intersection of College Avenue and Boston Avenue. 3
Fairmount Line Improvement Project
One week after MassDOT submitted the SIP Status Report, community leaders, elected
officials, MassDOT, and MBTA celebrated a groundbreaking ceremony for the Four Comers
station, the first for a new station on the line. This is a significant moment for this commuter rail
improvement project that will provide residents in the adjacent neighborhoods with new job
opportunities and easier access to downtown Boston as well as significant air quality benefits.
Unfortunately, it appears that since MassDOT last provided an update on this transit
commitment, as part of its Transit Commitments March 2010 Status Report dated March 18,
2010, the delay of the Fairmount Line Improvement Project has been extended. In March of
2010, MassDOT anticipated a delay of three to six months for completion of the Four Comers
Station, now the estimated delay has increased to twelve months. Likewise, in March of 2010,
MassDOT anticipated that the completion of the Talbot A venue Station would be delayed by six
to nine months, now a delay of ten to eleven months is expected. For the New Market Station,
the estimated delay has changed from six to nine months to approximately eleven to twelve
months. In March of 2010, MassDOT believed that the Blue Hill Avenue Station would be the
only new station completed on time, but now it states that it is unable to even provide a new
schedule for the design and construction of the Blue Hill A venue Station.
Despite the fact that it has been known and acknowledged that the Fairmount Line
Improvement Project will be delayed since at least March of this year, MassDOT has not yet
submitted a petition to delay the project to DEP as required by the SIP and does not intend to do
so until January of 2011. See SIP Status Report at 5. Again, MassDOT's failure to do so
illustrates its continuing disregard of the SIP disclosure requirements. MassDOT should
promptly provide an updated and more detailed project schedule that provides information about
how and when the project will be completed and specific reasons for why it is delayed for every
station. MassDOT should also involve the public in the identification and selection of any
Interim Offset Projects, as described further below for all delayed transit projects.
CLF renews its request that MassDOT identify and report on planned measures to
improve service and increase ridership for the Fairmount Line. The SIP specifically requires
MassDOT to implement "other measures to improve service and increase ridership" on the
Fairmount Line. 310 CMR 7.36(2)(h)1. As in past years, the SIP Status Report does not include
any information about these measures, despite the fact that a number of options were identified in
studies completed previously and that residents have actively engaged the MBTA and MassDOT
in requesting service improvements such as increased headways, evening and weekend service,
3 For a
more detailed explanation of this issue, please see CLF's comments on the Draft and Final Environmental
Impact reports for the project available at www.clf.orglworkIHCEJlbostonpublictransitcommitmentsJindex.html.
eLF: "Protecting New England's Environmen('
3
CONSERVATION LAW
FOUNDATION
and subway-level fares. DEP should therefore require MassDOT to report on the status of these
measures. To the extent that no such projects are planned, MassDOT should be required to
explain the failure to make progress on this commitment and identify Interim Offset Projects if
completion of this aspect of the Fairmount Line Improvement Project will be delayed. Measures
to improve service and increase ridership are an important part of this project. As reflected by
the SIP requirement to implement such measures, infrastructure investments standing alone, will
not yield the air quality benefits intended to be achieved through this transit commitment. Such
reporting should be included in an additional mid-year report that MassDOT should file on or
before December 31,2010.
Construction of 1,000 New Parking Spaces
Since MassDOT has not been able to advance the parking garage projects at the Salem
and Beverly commuter rail stations originally slated for fulfilling this transit commitment
sufficiently, it has decided to shift its focus for meeting the December 31, 2011 deadline to the
proposed South Garage at Wonderland Station in Revere. MBTA is building this garage in
coordination with the larger Waterfront Square development at Revere Beach. While South
Garage has the potential of fulfilling this transit commitment in part, CLF is concerned that due
to the multi-use nature of the Waterfront Square development the number of spaces actually
available for users of the MB T A's public transit system will be smaller than predicted and
therefore too small to contribute sufficiently to SIP compliance.
South Garage is being constructed adjacent to the Waterfront Square development at
Revere Beach, which includes new retail outlets, residential units, offices and a hotel. In addition
to the existing public beach, these new buildings constitute a significant draw for automobile
traffic. There would therefore be a strong need to ensure that sufficient parking is reserved for
MBTA customers. As planned, South Garage, unlike the garage planned for the Waterfront
Square project, would include parking for MBTA customers, but not all spaces in the garage
would be for transit riders. See MBTA South Garage Environmental Assessment (dated January
11,2010) at 1-2. To meet the SIP requirement, according to the SIP Status Report, a net gain of
at least five hundred and eighty parking spaces is needed at this location. SIP Status Report at 8.
Added to the 1273 existing commuter transit parking spaces at Wonderland, which are being
replaced, a total of at least 1853 parking spaces would have to be reserved for MBTA riders. See
MBTA South Garage Environmental Assessment (dated January 11,2010) at 1-2. The only way
to ensure that a parking garage that serves more than just a commuter transit facility consistently
has enough space available for transit riders is to reserve a specific number of parking spaces for
MBTA customers at all times and implement a system, such as parking ticket validation, which
enforces such restriction. It appears, however, that no such plans have been put into place for
South Garage. The contribution of sufficient transit commuter parking spaces from South
Garage to meet the SIP requirement can therefore not be guaranteed. Furthermore, since South
Garage is estimated to be completed by November of 2011, even a small delay would cause
MassDOT to miss this SIP commitment deadline.
In addition to South Garage, MassDOT is now also counting four hundred and twenty
existing parking spaces in Beverly, Dorchester, Newton and Quincy towards this transit
eLF: "Protecting New England's Environment"
4
·. CONSERVATION LAW
FOUNDATION
commitment. To comply with the SIP requirement, however, one thousand additional parking
spaces have to be constructed rather than merely provided. The parking spaces near the Beverly
commuter rail station, at least, appear only to have been opened to the public but have not been
constructed. For the Savin Hill Station, MassDOT is counting thirty spaces towards the
requirment. However, there are only twenty-six parking spaces in the lot, three of which are
reserved for MBTA station inspectors and hence not available to commuters. 4 As a result, an
additional one hundred and twenty nine spaces would have to be constructed.5
For all these reasons, and based on the facilities' own merits, CLF therefore urges
MassDOT not to abandon its projects in Salem and Beverly and to develop pedestrian-friendly
and transit-oriented parking garages at these commuter rail stations with input from the
respective communities.
Blue Line Platform Lengthening and Station Modernization
CLF disagrees with MassDOT's continued claim that its obligations under this SIP
commitment are complete by virtue of implementing six-car train service despite the failure to
modernize all Blue Line stations. The SIP requires both Blue Line platform lengthening and
station modernization. ~31 0 C.M.R. 7.36(2)(g) ("Before December 31, 2008, construction of
the following facility shall be completed and opened to full public use: Blue Line Platform
Lengthening and Modernization." (emphasis added». MassDOT's failure to report on this
commitment therefore violates the law. Furthermore, both components of this project are
necessary to achieve the increased ridership and attendant improved air quality required under the
Clean Air Act through the SIP. Increased ridership is a function of available capacity, access,
and attractiveness of service. Modernization of old, inaccessible, uncomfortable, and otherwise
non-user friendly stations and facilities leads to increased ridership and thus to improved air
quality.6
.
The failure to modernize all Blue Line stations is a continuing violation of the SIP, which
required that Blue Line station modernization be completed by December 31,2008. Last year's
2009 SIP Status Report indicated that Government Center station modernization will not
commence until the Spring of 2011, that Orient Heights Station modernization will not
commence until Spring of 2010, which it did not, and that the State Street Station modernization
is still underway. These delays are significant and the reasons for them largely unspecified. DEP
should therefore require continued status update reports and Interim Offset Projects for the delay
in completion of this commitment. MassDOT, in tum, should make every effort to hasten the
completion of this overdue commitment.
The MBT A does not list the availability of any parking spaces at Savin Hill Station on its website. See
http://www.mbta.comlschedules and maps!subwavninesistationsl?stopld-14289&lat=42.3l1 099&lng--71.053175
(1ast visited September 30, 2010).
5 eLF has not double-checked MassDOT's numbers for the parking spaces at Woodland Station in Newton and at
the Quincy Shipyard, which, like those at the Savin Hill Station, may be lower than reported.
6 See,~, Stacey Falzarano, Richard Hazlett, and Thomas Adler, Quantifying the Value a/Transit Station and
Access Improvements/or Chicago's Rapid Transit System (Transportation Research Board Paper No. 01-2987, Jan.
2001).
4
eLF: "Protecting New England's Environment"
5
.. CONSERVATION
LAW
FOUNDATION
CLF remains pleased that all work has been completed to accommodate six-car trains and
that eighty-two new Blue Line vehicles have been in service since September 15,2008. This is a
major achievement. The increased capacity on the Blue Line is already relieving overcrowding
and improving quality of service for riders. When coupled with full modernization of the Blue
Line, CLF is confident that even more riders will be attracted to the service and this increased
capacity will be well-utilized.
Red Line-Blue Line Connector
CLF commends MassDOT for its progress on the Red Line-Blue Line Connector and is
looking forward to MassDOT's responses to public comments on the Draft Environmental
Impact Report and its release of the Final Environmental Impact Report. This project is the only
remaining SIP transit project clearly on schedule. CLF continues to strongly support the
construction of the Red Line-Blue Line Connector and considers it essential for improving the
MBTA system in order to reduce air pollution, improve mobility and benefit public health,
environmental justice, and economic development throughout the region.
The MBTA' s Red and Blue Lines are the only two of Boston's rapid transit lines that do
not intersect. As a result, transit riders travelling from points along the Blue Line to the Red
Line, or vice versa, must transfer twice by using either the Green or Orange Line, thereby
reducing ridership and unnecessarily increasing congestion at downtown Boston stations
including Government Center, Park Street, State and Downtown Crossing. The need to transfer
twice also restricts access to jobs, such as those at the academic and medical institutions along
the Red Line, particularly for residents of East Boston, Revere, Winthrop and Lynn. The Red
Line-Blue Line Connector is projected to more than double daily boardings (22,390 instead of
10,050 boardings by 2030) at Charles/MGH Station alone.
The Red Line-Blue Line Connector is therefore a cost-effective project and would be a
sound investment in the entire MBT A system. Extending the Blue Line to CharleslMGH would
significantly improve travel time and convenience for those traveling between Red Line and Blue
Line locations. Furthermore, it would reduce travel time on public transportation to Logan
Airport, providing a necessary incentive for a large number of travelers to leave their cars behind.
At the same time, the Project would relieve congestion in the central tunnel, which can be
expected to increase even further as the Green Line extension to Somerville and Medford goes
into service. This reduction in congestion at the intersections of the Red Line with the Green
Line and Orange Line would benefit passengers throughout the system. As a reSUlt, more people
would choose to take public transportation which would reduce automobile traffic-and
therefore harmful auto emissions-in local neighborhoods. It would also decrease vehicle miles
traveled ("VMT') overall. The associated reduction in greenhouse gas emissions, in turn, would
help the Commonwealth in its efforts to meet the important goals of the Global Warming
Solutions Act.
eLF: "Protecting New England's Environment"
6
•
CONSERVATION
LAW
FOUNDATION
Interim Emission Reduction Offset Projects or Measures
In its SIP Status Report, MassDOT states that it will submit a petition to delay the
Fairmount Line Improvement and Green Line Extension projects to DEP in January of 2011. SIP
Status Report at 5 and 18. According to the report, this petition will include proposed Interim
Offset Projects for both of these transit commitments. Id. Although MassDOT and MBTA are
already investigating possible bus and rail service improvements as Interim Offset Projects,
MassDOT does not appear to be seeking public comment until after it has determined how it will
mitigate these delayed SIP projects and submitted its petition to DEP. See id.
Seeking public input that late in the selection process, however, is almost like closing the
bam door after the horse has already left. It is crucially important for MassDOT to seek public
input much earlier, i.e., while investigating ideas for Interim Offset Projects. Considering that
both of these transit commitments enjoy a high level of involvement by knowledgeable members
of the public, MassDOT should offer a public participation opportunity prior to January of 2011
that seeks and collects ideas for potential Interim Offset Projects. MassDOT could then choose
the best options for each of the SIP projects, taking the communities' ideas, concerns, and
interests into consideration. MassDOT could then propose these options to DEP in January of
2011 as part of its petition. A public comment period following its selection would allow for
additional input after MassDOT has made its choices.
Recently, MassDOT received a letter dated September 17, 2010, attached to these
comments, from the Fairmount Line Coalition with ideas for potential Interim Offset Projects
that might be able to temporarily reduce emissions during the delay of the Fairmount Line
Improvement Project. MassDOT also received a letter dated September 22,2010, attached to
these comments, from local stakeholders similarly making suggestions for potential Interim
Offset Projects for the Green Line Extension Project. CLF hopes that MassDOT will consider
and analyze all of these proposed Interim Offset Projects closely as it develops a plan to address
the delays of the SIP projects.
As these letters reflect, all suggested Interim Offset Projects are located in the
neighborhoods that are intended to benefit from the delayed SIP projects. While CLF recognizes
that keeping the Interim Offset Projects in the same neighborhoods as the delayed transit
commitments is not a legal requirement of the SIP, we strongly believe that failing to adhere to
this approach would be patently unfair and politically unwise. CLF therefore strongly
recommends that all Interim Offset Projects considered be located in the respective
neighborhoods of the delayed projects. Specifically, for the Green Line Extension Project, the
Interim Offset Projects should be located in and serve the Somerville, Medford and Cambridge
neighborhoods that are adjacent to the extension of the Green Line. Likewise, for the Fairmount
Line, they should be placed in and provide service to the Dorchester, Hyde Park, Mattapan and
Roxbury neighborhoods adjacent to the Fairmount Line.
Any Interim Offset Project ultimately selected by MassDOT for the Fairmount Line
Improvement Project should be in place by December 31, 2011, and by December 31, 2014 for
the Green Line Extension Project. See 310 CMR 7.36(4). Sufficient Interim Offset Projects
eLF: "Protecting New England's Environment"
7
< •
CONSERVATION LAW FOUNDATION
should also be put in place to address the delay of the Blue Line Platfonn Lengthening and
Modernization Project. All Interim Offset Projects shall achieve emission reductions equal to or
greater than the emission reductions that would have been achieved had the project not been
delayed. See id. To comply with the SIP, for the Green Line Extension Project, the appropriate
benchmark for determining whether the air quality benefits of the Interim Offset Projects meet
the required standard is the expected emissions reduction from the complete SIP project, which
includes the extension of the Green Line to Union Square and Medford Hillside, not just the
shortened extension to College Avenue MassDOT has proposed.
Conclusion
CLF appreciates MassDOT's continued work on the transit commitments in the SIP and
the progress it made during the past year. The Red Line-Blue Line Connector seems to be
progressing quite well and CLF is aware that MassDOT and the MBTA have been working hard
on the Green Line Extension, Fainnount Line Improvement and Blue Line Platfonn Lengthening
and Modernization. However, MassDOT's disregard for the SIP disclosure requirements, the
projected delays for the Green Line Extension and the Fainnount Line Improvements, the failure
to acknowledge that the Green Line Extension as planned does not comply with the SIP, the
continued delay of the Blue Line Platfonn Lengthening and Modernization, and the lack of
clarity with respect to the construction of one thousand additional parking spaces serving
commuter transit facilities raise serious concerns regarding the lawfulness of MassDOT' s
activities. DEP must provide greater oversight during the coming year and MassDOT must
allocate all needed funding and take all necessary steps to complete the SIP commitments as
quickly as possible.
Thank you for the opportunity to comment.
Sincerely,
?/-~f#::~/
Rafael Mares
Staff Attorney
cc
Donald Cooke
Air Technical Unit
US Environmental Protection Agency - Region 1
5 Post Office Square, Suite 100
Mail Code OEP05-2
Boston, MA 02109
eLF: "Protecting New England's Environment"
8
September 13, 2011
Kaiser Comment Letter to MassDOT and DEP Page 1
-
,.- -- ---------=---;--... -.
.
-;-
": ·-.~'--~'·-tl~""'·-t
1>0FC~Z."--1 ,~-
,. "~-;:':::;'';'; ,J_""'~_:- (I.ill..•.)
.' -
_.~.
.
_.
..'
~-
..
'
.
,
.
~'l
To : Richard Davey, Secretary of Transportation
Kenneth Kimmel, Commission, Department of Environmental Protection
From :
Stephen H. Kaiser, PhD
Comments on proposed SIP revisions: Schedule
and Funding Challenges for the Green Line Extension
The essential issue before us is schedules. When should the Green Line
Extension be built? It is not a matter of why or how or by which consultant or
contractor. It is a matter of when.
A hundred years ago rail service existed with stops in Cambridge, Somerville
and Medford. It is a matter of when this former rail service can be restored. In
modem times, commuter rail has come to mean that rail service will be continued for
suburbanites, but there will be no stations and no service for central city residents
and businesses. The Green Line extension is a compromise based on the proposition
that the state can provide service for both, equitably.
Because the corridor and the land are already in transportation use, it seems
that such a simple proposal to rebuild the tracks and the stations would be an easy
matter. Unlike the field of dreams, we do not have to "Build It and They Will Come."
Instead, the Green Line motto should be "Build it ... the Riders are Already There."
Our most recent history of imaginative scheduling has shown how rapid
progress can be made on rebuilding the 1-93 bridge decks in Medford. In decades
past, the state highway department used to have employees who served as expediters,
moving projects along, unplugging bottlenecks and smothering delays. We need more
expediters for the Green Line.
How fast can you build things, absolutely from scratch? Go back to over 180
years ago when the Boston and Lowell railroad was chartered by Legislature in 1830.
Three years later they were buying land in Somerville and just two years after that
were running trains in 1835. A total of five years to build a railroad in from Lowell.
Page 2
Kaiser Comment Letter to MassOOT and DEP
September 13,2011
In more recent years, the Mass Transit Commission of 1945 proposed a
Lechmere trolley extension .... but the proposal sat on a shelf. In 1970, the idea was
revived, yet here we are forty years later with a request to delay the project once
again.
My sense is that MassDOT is worthy of sympathy in the challenges confronting
them in the 21st century. But there are serious dangers in offering soft compliance
in the form of an unconditional extended deadline. If MassDOT can start meeting
their schedules and commitments, they gain backbone and credibility in all they do..
What happens if we come to 2018 to 2020, and there is still inadequate
progress? Do we roll over and extend their allowance for delays .... again? Is this
good for potential Green Line customers? Are unsubstantiated promises good for the
credibility and accomplishments of government? Are they good for MassDOT?
Delays beget more delays. This is not a healthy solution.
I do not see evidence that MassDOT understands the elements that contribute
to delay. not does it have a strategy. nor does it have a strategy to find a strategy. I
believe that MassDOT is trying, indeed struggling to move the Green Line forward,
but we need to give them assistance in the form of design stimulus, efficient
scheduling, plus a financial plan with identified revenues and savings.
I recognize that many critics of the delays attribute the problem to a lack of will
and commitment by MassDOT, combined with bureaucratic foot-dragging. If these
critics are correct, does their viewpoint require us to presuppose the existence of a
villainous MassDOT?
This perspective doesn't make sense to me. I do not see an Administration
conspiring to sabotage the Green Line -- a hundred Dick Cheneys running about
seeking to thwart the will of the people.
The essence of our problem was displayed in a cartoon this past week of a
meeting of a group identified as Debtor's Anonymous. Membership included Uncle
Sam, economists, international bankers, corporate CEOs, homeowners, and local
government officials all waiting in anticipation for the arrival of a messiah. But there
is no leader to guide their discussion. The last place one would want to go to for help
would be academia, given the spiraling costs of college tuition and the tremendous
debt loads imposed on newly minted university graduates.
We are not even in kindergarten when it comes to dealing with major public
debt. No one seems to have any answers -- not Uncle Sam, the economists, bankers,
local officials, professors, or citizens. We have an Executive Office of Administration
and Finance, but it is irrelevant and in hiding.
What is MassDOT to do? How can we help?
Page 3
Kaiser Comment Letter to MassDOT and DEP
September 13,2011
My solution is to set out a specific, ambitious schedule and to develop a
financial plan to fund the Green Une and the MBTA in general. DEP would set the
schedule. Cambridge and Somerville citizens and leaders would work with MassDOT
to deal with the issue of debt by preparing a financial plan -- to get them out of the
fiscal quagmire they are now trapped in.
A financial plan should be constructed with awareness of the many money
problems of the MBTA. Today there are numerous factions at the MBTA, some in favor
of the Green Une and some opposed. I recognize the validity of their objections -­
that the MBTA today does not have the resources to handle the Green line
extension ... that higher priority should be given to a capital improvement project for
existing infrastructure ... and that fare increases and service cuts must be avoided,
even as the operating budget slides further into deficit.
The solution for Green Une advocates is not to appease or ignore the factions,
but instead is to offer and stimulate a credible and practical financial package that
can serve as the model for the MBTA to put its entire financial house in order.
I recently submitted to MassDOT a listing of 23 options for funding the Green
Une through some form of deficit reduction involving cost savings and new income.
I have yet to receive a substantive response, but I have no awareness that any state
official has a comparable list of funding options. We all need to be more inventive
and comprehensive in seeking funding solutions for the MBTA.
DEP, by setting tough schedules to be met as part of the SIP process, can help
MassDOT deal with its fundamental budget problems. If MassDOT is not proactive,
we could lose the entire transit system, not just a future service extension. The MBTA
could become another Greece, dragging the whole system down because everyone
lacks an ability to deal with debt. Granting the requested schedule delays will simply
prolong the agony of fiscal decline. Such capitulation and denial perpetuates the basic
illness of unresolved debt.
On page 6 of this letter. I proposed a new schedule for the Green Une which
should yield the initiation of serve from Lechmere to Washington Street by the end of
2015. I have identified a number of intermediate check points that will verify
progress towards schedule compliance.
Primarily for the attention of MassDOT (and as background only for DEP) I have
prepared a list of five suggested cost saving and revenue items that would improve
the MBTA's financial situation and especially the Green Line. These I have selected
from a list of 23 suggestions previously submitted to MassDOT.
The list of five items below should also include a necessary increase in the bond
limit of $500 million, due to past and present expenses. The five items reflect the
funds possible over the next ten-year period.
Page 4
Kaiser Comment Letter to MassDOT and DEP
September 13, 2011
(1). Tax on Fiber-Optic cables installed in railroad rights of way ...... $200-500 million
In the last decade, private communications companies have
installed fiber-optic cable conduits in railroad rights-of-way
by direct negotiations with railroads. Conduits were installed
at no cost to the railroads, for which railroads were paid
millions of dollars. Those rights-of-way were made possible
by state actions chartering the railroads with powers of
eminent domain, while also giving the state the power to
regulate rates, fees and income. This new tax would be
equivalent to a real estate or excise tax, hence the variation in
the estimate.
(2). Pass a Gas tax explicitly for Big Dig purposes. Minnesota ............ $140 million. recently passed an 8-cent gas tax. The Massachusetts tax
would be 7 cents, with 6 cents for highways and 1 cent for
the MBTA. This tax would be limited to paying off the
past obligations of the Big Dig. The current bonded
indebtedness from the Big Dig is $8 billion, which would
be retired in 60 years with a six-cent increase in the gas tax.
(3). Sale of 13 acres of state tidelands at North Point, lands not ......... $80 million currently owned by the developer. The value is based on recent land transfer arrangements for MBTA lands at North Point. (4). Energy savings at the MBTA generally. Initially for ten years ....... $65 million of the Green Line, thereafter credited to operating budget for the entire transit system. This estimate has been based on the MWRA being able to achieve a 15% savings in energy use over the past two years, with the same expectation applied to the MBTA. (5). Avoidance of a taking of the Walker Building in the Inner Belt ....... $50 million Industrial Park. Alternate consideration should be given to the use of underutilized track areas and parking lots, as well as different maintenance building configurations. Total: $550 to $850 million over ten years.
Simultaneously with this submission of my comments to MassDOT and DEP,
I am submitting a copy of Version 2.1 of my track plan and ideas for the Brickbottom
area of Somerville. I anticipate that within a month I will be submitting Version 3.0 of
the plan, while will include the entire corridor from Washington Street to Lechmere.
I should caution that both of these plans are comprehensive intermodal plans intended to show that all of the pieces fit together without conflict. Any phasing, Page 5
Kaiser Comment Letter to MassDOT and DEP
September 13, 2011
financing and agency responsibilities will vary. All Green Line obligations of the MBTA will be limited to transit and commuter rail work, plus retaining walls for the community path. Specifically, a future highway bridge to North Point would be a highway responsibility, not a transit one. Version 2.1 shows an illustration of the community path and its connection to a
Grand Junction path that has between studied by Cambridge. It includes the long­
planned expansion of the commuter rail storage area by three tracks, an improvement
in the mainline commuter rail S-curve from 25 to 45 mph, and the relocation of the
"drill track" into the yard and away from its location immediately adjacent to the
Brickbottom housing.
Brickbottom has open windows in the summer, with early morning train idling,
with noise, odor and air pollutants. Not only is the overall Central Artery mitigation
an issue, but the MBTA should recognize an obligation to mitigate existing commuter
rail noise and air pollution impacts.
Sincerely,
Stephen H. Kaiser, PhD
Page 6
September 13, 2011
Kaiser Comment Letter to MassDOT and DEP PROPOSED SCHEDULE FOR GREEN LINE TASKS
(a)
Resolve all eleven track moves in BrickbottomlYard area ... end of Sept 2011
(b)
Resolve pedestrian circulation issues at Lechmere ........... end of Oct 2011 (c) Separate Maintenance building into a separate phase for design, land-taking and construction: alt, plans by ..... end of Nov 2011 (d)
Prepare acceptable budget for Federal & state officials ....... end of Dec 2011 (e)
Unify MassDOT/MBTA forces .............................................. end of Dec 2011 (f)
Complete HDR design work ................................................ end of Dec 2012 (g)
Award Design-Build Contract ............................................... end of Mar 2013 (h)
Begin Green Line service, Lechmere to Washington Street... end of Dec 2015
(i)
Begin Green Line service to Medford .................................. end of Dec 2016 (j)
Open Green Line service to Union Square ........................... end of Dec 2016 (k)
Complete Maintenance Building (1)
All Green Line Bonds paid off ............................................. end of Dec. 2021 end of Dec 2018
****++++**++++*****
Prepared by S. Kaiser 9-13-2011
MASSPIRG
Publiclnterest
AdvDcate
SUBMITIED TO :
44 Winter Street, 4th Floor
www.masspirg.org
info@masspirg.org
I Boston, MA 02108
(617) 292-4800 (ph)
(617) 292-8057 (fx)
Katherine Fichter, MassDOT
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston, MA 02116
Via email: Katherine.fichter@dot.state.ma.us
Jerome Grafe, MassDEP
Bureau of Waste Prevention
th
One Winter Street, 6 floor
Boston, MA 02018
Via email: Jerome.grafe@state.ma.us
SUBMITIED BY:
Micaela Preskill, on behalf of MASSPIRG
DATE:
September 13, 2011
RE:
Testimony in Support of Green Line Extension and Blue-Red Connector Design
Thank you to the Massachusetts Department of Transportation and the Massachusetts Department of
Environmental Protection for considering MASSPIRG's testimony today.
My name is Micaela Preskill and I am the transportation associate at MASSPIRG. MASSPIRG is a
statewide, non-profit, non-partisan public interest advocacy organization with thousands of members
across the state. We have long been involved in the issues of public health and consumer protection,
and more specifically, issues associated with transportation .
I am here today to urge you to reject MassDOT's request to delay the Green Line opening for another
nine years and to similarly reject their request that they be relieved of the obligation to complete
environmental review and final design of the Blue/Red Connector project.
Public transportation takes cars off the road, relieves us of our dependence on foreign oil, and reduces
congestion. The Green Line extension will run through one ofthe densest cities in the Bay State,
connecting Somerville, Cambridge, East Arlington, and Medford to every corner of our transit system.
The Blue/Red Connector would provide a critical link to the only two unconnected rapid transit lines in
the Massachusetts Bay Transportation Authority's system. We simply cannot afford to delay or abandon
these projects.
Green Line Extension
PRINTED ON RECYCLED PAPER
The Green Line extension is a legally mandated project which the state is required to complete in order to meet its legal obligations under the Clean Air Act. It is the Commonwealth's largest Transportation Control Measure (TCM) under the State Implementation Plan (SIP) and has held that spot for twenty years. Simply put, we cannot wait another nine years to complete this valuable project. We have already waited long enough. MassDOT is under a legal obligation to show realistic funding sources and timely completion ofthe project in the 2012-2015 TIP and the Long Range Transportation Plan . Despite this obligation, MassDOT and the Commonwealth have failed to create a fiscally constrained plan, falling short in their requirement to secure funding and meet their environmental commitments. They should not be allowed to delay the project further, as its delay will only result in significant harm to the communities affected by the project as well as the entire Bay State. We should be making significant investments in expanding public transportation, particularly at a time when gas prices are at all-time high and are only expected to rise. Any cancelled expansion hurts the entire system. Finally, further delay of the project could jeopardize the Commonwealth's federal transportation funding streams and it will certainly increase the cost of the project. This represents an undue and unfair double-burden to taxpayers. Blue/Red Connector Transit riders travelling from points along the Blue and Red lines are currently forced to transfer twice. This results in reduced ridership and increased congestion at critical points along the MBTA's route. Connecting the lines would provide critical links in our rapid transit system, and facilitate travel between the North Shore, the South Shore, and Cambridge/Somerville. The Blue/Red Connector is an overdue investment, with initial engineering work having taken place in the mid-1980s. In fact, when the MBTA rebuilt the Charles/MGH red line station, it designed the new station so as to allow for the creation of an underground Blue Line station directly beneath it. The Connector is estimated to avert an additional 1,400 automobile trips per day into our already crowded downtown core. Reduced congestion, coupled with the associated reduction in greenhouse gas emissions, would help the Bay State to meet the goals set forth in the Global Warming Solutions Act. In order for a transit project to be constructed, it must first be designed. We should position ourselves to design a "shovel-ready" project that is available for an infusion of federal funding. Despite inflated cost estimates, the Connector project has been called one of the most cost-effective transportation projects in terms of its benefit to the system and anticipated increase in ridership . Now is the time to make this investment. Conclusion For all of these reasons and those articulated by our colleagues, we urge the Department of Environmental Protection to reject the Massachusetts Department of Transportation's request to delay the Green Line Extension and abandon its requirement to design the Blue/Red Connector. The state must honor its commitment to all of us, and quickly pursue completion of these critical projects. Thank you for your consideration. EXECUTIVE OFFICE OF TRANSPORTATION TRANSIT COMMITMENT SUBMISSIONS ASSOCIATED WITH THE STATE IMPLEMENTATION PLAN PUBLIC HEARING DATED SEPTEMBER 13, 2011 DEPT. OF ENVIRONMENTAL PROTECTION and MASSACHUSETTS OFFICE OF TRANSPORTATION SUBMITTED BY
Green Line Advisory Committee for Medford (GLAM) clo 25 Bussell Road Medford, Mass. 02155 SUBMITTED TO
Katherine Fichter Mass. Dept of Transportation Office of Transportation Planning Room 4150 Ten Park Plaza Boston, Mass. 02116 Katherine.fichter@state.ma.us and Mr. Jerome Grafe Mass DEP One Winter Street Boston, Mass. 02018 Jerome.grafe@state.ma.us September 13, 2011
Public Comments on State Implementation Plan - Transit Commitments 2011 Annual Status Report These public comments written and submitted by the Green Line Advisory Committee
(GLAM) are focused on that portion of the Transit System Improvements pertaining to
the transit system known as the Green Line extension from Lechmere to Medford
Hillside. These comments are based upon documents known as the State
Implementation Plan -Transit Commitments 2011 Annual Status Report.
Based upon our participation within the Mass DOT citizen participation process
over the last year. these public comments are essentially our report card on Mass
DOT and the proposed Green Line project process. GLAM's comments build
upon our comments regarding the 2010 Annual Status Report from last year. Our
public comments submitted on September 13,2011 are as follows:
Advocacy Announcement
Glam is an educational group and in that role we often receive data and information from
supporters, non supporters and those who are ambivalent about the proposed Green
Line process. We are seen as a group focused on candid and open discussion, fairness
in social equity issues and transparent in our methods. We have attached to our public
comments a document sent to us by a Medford Neighborhood Green Line Neighborhood
Alliance (MGNA) supporter regarding a MGNAISTEP announcement of which they had
concern. This person's name has been not been released to protect their privacy and
confidentiality and to prevent possible retaliatory measures against them as we have
seen in the past and is noted by Medford Police Chief Sacco. .
Within this lengthy document under the heading of Transparency/Credibility in section c.,
(page 7 of 8) STEP pronounces in its push for the proposed Green Line that "Thirty
years is an unacceptable delay." Yet, in historic review it can take up to fifty years to get
a project off the ground from concept to completion as in the case of projects such as
Kendall Square. Even the MAPC in their recent community visioning meeting admits it
can take another 20-25 years for a project to take place at Route 16. Other reports by
the CTPS state similar points when looking at transit expansion in the suburbs by the
time you deal with regulations, municipalities, sensitivity variables, citizen education,
planning, engineering and final construction.
On page 1 of their declaration, STEP encourages their supporters to "... attend to fight
the latest, proposed delays" referring to the Public Hearing on September 13th • Whom
are they intending to fight? They are fighting the financial conditions that were created
by the Big Dig, which is known across the country as the Big Fiasco.
They go on to state on page 2 of their document under Part 1 they are "furious" about
the latest delays. We cannot as an educational group state that we have heard fury in
our community, or even in Somerville. A small group of activist who left out the
environmental justice and disability communities in Medford is furious.
Yet what the environmental justice and disability community in Medford called for was an
investigation of this project to research as to whether the project is truly representative of
2
the 1964 Civil Rights Act and the updated 1991 Americans with Disabilities Act (ADA. A
feat we have achieved recently with notice from the FTA's Office of Civil Rights that our
concerns will be address and broaden through a compliance audit review of the Mass
DOT. We questioned the incestuous relationship of special interest groups with a
government agency called Mass DOT and the resulting marginalization and
discrimination of the authentic voice of the environmental justice and disability
communities from the proposed Green Line process and citizen participation venues.
These groups have been charged in doing so.
There have been cases around the proposed Green Line process that were settled
about disability participation where the state ruled that equal rights were not given to a
hearing impaired individual (MCAD). Most recently the Somerville High School and
Somerville City Hall locations were ruled by the U.S. Dept. of Education as being
inaccessible to the disability community. This is where Mass DOT has held Green Line
public meetings and continues to hold public meetings despite being told by the disability
community of this accessibility violation and ruling. Now the city of Somerville must fall
into compliance with this accessibility issue.
These are just a few of the issues that the disability and environmental justice
community have encountered. Neither STEP nor MGNA have been able to attract or
organize the environmental justice or disability community to come to meetings to speak
in their authentic voices around the proposed Green Line project. We are especially
knowledgeable about this as it pertains to the three proposed stations in Medford, Ball
Square, College/Boston Ave. and the Phase \I area of Route 16.
Recently there has been a complaint filed against the MPO about the MPO and its
practices and attitudes concerning people with disabilities. So when STEP speaks bout
being furious, they need to provide the whole context of the proposed Green Line.
It is imperative states STEP that they make Governor Patrick build the Green Line
Extension during his term in office (pg 7 of their declaration). But it is also imperative
that Governor Patrick enforce his Executive Order #478 of 2007 on supporting ADA
which has not been followed within the Green Line process.
According to STEP in their statements on page 2 of their declaration, the MPO has
made a funding strategy to delay the proposed Green Line within the TIP and LRTP in
concert with Mass DOT's delay request This is true. But none of the environmental
justice or disability communities in Medford were organized to speak to this obscure
MPO process by these special interest groups when the MPO was deciding on whether
to eliminate the money for Rte 16 back in May and June. Only a small ban of activists
that when you speak to the total population of three cities estimated at 120,000 to
200,000 and, depending upon what communities you are speaking for, appear to
represent their own self interest.
Does Mass DOT and Mass DEP not want to wait until the FTA OCR audit process is
complete before putting additional money forward on this project? Or does it wish to
continue forward with its Jim Crowism? As the late Supreme Court Justice Thurgood
Marshall noted in the past, he had not seen such Jim Crowism, even in the African
American community, as he has seen toward the disability community. Yet the state
continues to follow the separate but equal path forward in funding.
3
We must recognize the civil rights of individuals and when violated we must consider
what that means. Was there true diverse citizen participation in the processes of this
project, including the processes of STEP and MGNA, and as organizers can they truly
hold high the Vision Statement of the MAPC when only 34 people identified themselves
as attending the last meeting according to MAPC's own polling results? And no one self
described themselves in the room as African Americans or from the disability
community. An important point when you consider that 50% of the African American
population in Medford lives in the Route 16 impacted area according to Medford's HUD
action plan.
Yet it appears that STEP and MGNA are doing back room politics concerning the Civil
Rights and ADA legal obligations regarding inclusionary purposes as they try to side
step processes in place around Route 16.
Mass DOT is being asked to make its judgments concerning Rte 16 based on 34 people
out of 200,000 estimated populations from three cities, Cambridge, Somerville and
Medford. And Mass DOT is being asked to base its judgment on a small ban of people
who continue to know how to write boiler plate letters and Mass DOT continues to
project that this small ban of people represent people in Cambridge, Somerville, Medford
and Arlington.
Though GLAM has supported the Green Line through College/Boston Avenue where we
believe there is consensus, it does not support continuing beyond that legally mandated
point for financial reasons and for civil rights issues, as well as, the need for more
studies as Mayor McGlynn has requested. We believe there are substitutions that can
be achieved to bring this project into reasonable realms of financial reality such as bus
routes.
No where in this project is it legally required that the environmental justice and disability
communities be discriminated against. In fact, it is shameful that many legal people
have participated in the determination of the proposed Green Line and have never stood
up and said publicly that these civil rights groups have a right to participate in their own
authentic voices. Only GLAM has come forward with these civil rights issues. This is
especially egregious when you realize these legal people are officers of the courts. As
the Congress of the United States as proclaimed in enacting the ADA, there is inherent
discrimination in the system, which includes state and public activists.
Political Transparency
We find STEP and MGNA's feigning of indignation and furiousness about this delay
quite hilarious. It is much like the line in the movie Casablanca where Claude Raines
character cries out "I am shocked to find gambling in the house" while picking up his
gaming winnings in his back hand.
The proposed Green Line is a microcosm of larger issues citizens are finding in their
discontent with government across the country, the lack of political transparency and
forthright honesty in dealing with issues, the domination of special interest group
lobbyists, and political representation that plays to the crowd for votes for re-election
instead of presenting the reality of the situation. This all occurs while the individual
citizen's voice is stifled.
4
As we predicted in our FEIR comments to MEPA, the separate but equal planning
process set up by Mass DOT around Route 16 has been nothing more than a political
ruse. In knowing the project would need to be delayed as there has never been enough
funding for this project even for Phase I, then allows Mass DOT and its special interest
groups to perform a slight of hand and put in a notice of project change to include the
Route 16 station through the SIP program, claiming broad support. Anyone with a
contractual law background knows that Mass DOT can amend this project at any time,
especially if you have a dual study process on going as they have been doing with the
MAPC.
This push has now tainted the MAPC process and brings MAPC's credibility into play
since we are aware that Mayor McGlynn has been looking for studies to determine the
impact to these neighbors before any decision can be made in support of Route 16. He
re-emphasized his position in a recent article in the Medford Transcript. If Mass DEP or
Mass DOT in any way approve the inclusion of Route 16 into the SIP process, it will
appear that there have been misrepresentations at all levels of government concerning
the intent of the Route 16 process, especially when you consider only 34 people
identified themselves at the last MAPC meeting.
As we also pointed out within our FEIR comments in a Chronicle of Higher Education
article, dated July 16, 2010, essays were presented on the topic "Anger, How We
Became the United States of Fury", a multi viewed discussion on how our country has
become one of rhetoric that threatens to swamp our politics due to the"... schism of the
role of government in American life." In the essay entitled "The Fairness Instinct" by
David P. Barash, professor of psychology at the University of Washington, he points out
that government policies that depart from perceived even handedness have a long
history of rousing departures from citizen complacency and even from civility.
Paternalistic governmental dictates are often seen as unfair when the government does
not consider the action of human freedom and rights in decision making nor in the role of
history.
We have been aware for over a year that the proposed Green Line Extension would be
delayed beyond the original 2015 proposed deadline in speaking to more objective state
house sources. It has been known for quite sometime there is no money for this project
and representations that there has been money do not know the difference between
funding obligations and line item designations in a reform budget. Citizens should be
furious that they have been told by politicians who have informed them that there is
money available. Much of the proclamations about money have been mostly good photo
ops and political rhetoric fodder for political campaign literature. But as Somerville
learned last year, the money promised is not always the reality as they had to upfront
money to continue the Assembly Square project. We cannot believe that the reality of
the situation has not been shared with special interest groups by elected officials in their
districts who have catered to them for re-election efforts while keeping out the
environmental justice and disability populations in the process.
To believe that elected officials from cities and towns across the Commonwealth want to
fully bond 100% of the proposed Green Line for one city is an illusion especially in a
forthcoming election year where focus in the Democratic side will be geared to get
President Obama re-elected. I don't think these officials will want to tell their
constituencies that they will be putting more debt service upon the MBTA.
5
At what cost to the public will the Commonwealth take on this additional debt and what
other services will suffer to meet these debt obligations that have not all ready received
deep cuts in the past? How will the MBTA keep up with this expansionist attitude when
they all ready have a maintenance backlog and operational efficiency problems? And
what social equity impact will it have on the environmental justice and disability
communities in regards to increased rate hikes in fares that surely will be forthcoming to
offset these problems or the decrease in commuter rail service that Sec. Davies recently
spoke to in the Metro Newspaper. How many times can we ignore the D'Aliesandro
report's recommendations concerning slowing down expansion instead of putting
additional burden on the transportation we have.
Yet in reviewing the APA transit ridership reports over the last fifteen years for the
MBTA, the fastest growing service population for the MBTA is the demand ridership for
The Ride, a service for the disability population who are expressing their wish for
mobility under the ADA. This population will continue to grow as baby boomers grow
older, veterans with disabilities return, and those who are temporarily abled bodied find
themselves with disabilities.
The recent quarterly report from the APA on ridership from January 2011 to March 2011
shows that the light rail system decreased in ridership by 6.12%, while the Ride and
Hard rail increased. The proposed Green Line is considered since 1984 a light rail
system (LRn. Although LRT is an additional mobile option, it is not the panacea that
will take cars off the rode in a population that values its freedom in movement. That is a
utopian's dream. According to a NCTR study on Ridership Trends of New Start Rail
Projects, while LRT systems play an important role in provlding options for transit, LRT
systems are a lengthy process with a mixed record in terms of providing substantial
growth in ridership and after initial interest in the newness of a transit system as it comes
to maturity ridership eventually levels off. .
As we have seen the CTPS report on the Before and After Study of the Green Bush line,
the ridership numbers on this commuter rail system did not pan out to the expectations
of planners. The increase of ridership was from one public transit mode to another with
only small transfer of drivers from their cars. And for those who did leave their vehicle
for the commuter rail, there were more cars to follow in their place to replace them. This
trend has also been seen in bike sharing programs as reported by McGill University in
Montreal. The hype of the program was more than the reality where folks who all ready
rode bikes increased their participation while drivers continued to use their vehicles.
We believe that the delay of the Green Line allows the state to look at other alternatives
and prepare real studies based in cost benefit analysis with financial breakdowns that is
inclusive of all information and will provide time for a social equity study for the
environmental justice and disability populations. Now is the time to put the activist on
notice that there may be other ways to mitigate the Green Line and still support phases
of the proposed Green Line with reasonable financial stewardship.
Conclusion
GLAM in the past has brought up different alternative suggestions. In our FEIR
comments with members support, we came up with the idea to break the Green Line
down into further phases as it was obvious that the funding issue was becoming
6
insurmountable in light of economic issues. We supported the Mass DOT at the federal
EPA in their request to propose substitutions to the proposed Green Line as we
predicted this moment would come.
GLAM has taken many positions during the proposed Green Line process. We have
pointed out that the Somerville High School was inaccessible, that meetings were being
held without proper sound systems and without minimum standards to ADA. We have
stated that presentation material must be provided in other media, such as in second
languages or in Braille for those who came to meetings with visual impairments. We
have pointed out that meetings have been held in non neutral settings that have left out
the environmental justice and disability communities since these setting have
represented civil rights issues.
The boiler plate advocacy letters only prove they cannot cooperate and compromise with
other cities or citizens. They are only the Green Line supporters, not the taxpayers.
They state that Mass DOT's performance has been awful. We might support this
statement if it was inclusive of what we have observed in this process.
STEP and MGNA have been equally awful in their performance in accepting meetings
at inaccessible places, and in not accepting Roberts Rule of Orders so questions could
be asked by the environmental justice and disability communities when attending Mass
DOT meetings. They have supported a double standard, one standard for themselves
and another for others who they perceived as naysayers, thus dominating all meetings.
The Mass DOT Citizens Advisory group was nothing more than to rubber stamp Mass
DOT actions, not discuss the type of issues being addressed in our comments. Yet
these same advocates stated nothing. Therefore, why should supporters be surprised at
the proposed Green Line's current condition when they supported the stifling of dialogue
to deal with these issues and instead shouted down the disability member who asked
critical questions with "you do not support the Green Linen.
That is why GLAM took the approach to educate the public on issues that were not
allowed to surface at meetings that were conducted in ways to stifle free and open
discussion. This process is still happening. The legal obligation of the state is fair
partiCipation. The Urban League in their State of Black Boston report along with a recent
Pew Research report point out the growing gap of income inequality in our region and in
the country. These types of social inequity issues have not been address in the
proposed Green Line process or in the MAPC community vision process. Yet advocates
cry that they have not gotten their way even after being appointed to the Station Design
Workshop group, while the Mass DOT excluded members of the Medford environmental
justice and disability community. In fact, we are aware the local NAACP president
applied and was denied participation in this group.
./' GLAM supports the delay in the proposed Green Line to 2020 due to lack of
financial feasibility .
./' We continue to support breaking the project down into further phases and would
suggest you start with the reference of North Point and Lechmere Station, which
we believe would not require a maintenance facility to be built at this time since
one is not required right now with the current Lechmere Station. In our
discussions with residents there, both long term and short term, there is a desire
7
to move Lechmere across the Highway to obtain a better character for the
neighborhood .
./ Our support for a further breakdown of the proposed Green Line is based upon
the caveat that a before and after study be performed on each phase that
determines whether ridership numbers were accurate and reveal a determination
of the true impact on surrounding neighborhoods pertaining to mitigation and
social equity development regarding gentrification and displacement.
./ We would be opposed to land banking by the state in any form. It has been
noted to us that if the state buys the property and holds it for over three years
without using it, you are breaking a common trust with the public. More
information on this point will be coming forth
./ We believe there are substitutions that can bring the state into compliance with
the SIP. Substitutions to consider:
o Using bus routes more efficiently and bringing more natural gas or
hybrid buses into the cities affected.
o Consider the use of express buses mixed in with a regular bus
route. We clarify we are not suggesting buses such as the current
Haymarket Express out of West Medford, but an express concept
on ordinary routes used in other cities at peak times. For
example, you would determine key bus stops during peak times
where ridership is high and only have these express buses stop
there during peak times. The regular bus on the route would stop
at the smaller stops as usual. In this way you are moving people
faster to work, staying on schedule, and allowing the express bus
to go around the regular route bus for those who choose a slower
route mode. This has been done in Los Angeles for many years
according to one of our members and does not necessarily require
a dedicated bus lane. The commuter rail also performs this way
during peak hours as well.
o Can bus turnouts be developed in certain areas?
o Studying coordination of traffic lights to curtail the idling at red
lights at every stop. This technique is used well in New York City.
o Research your dispatch techniques regarding The Ride. Instead
of widening the region in which The Ride driver operates, treat the
operation in a more locally centralized dispatch area as cab
companies do. Use GPS systems on The Ride to prevent jam ups
in traffic congestion.
o Coordinate with GPS system companies in educating the public
on how they can use GPS systems in avoiding traffic congestion
and idling in traffic. Tom Tom and Nissan have programs they are
trying to promote in partnering with government to reduce traffic
congestion. What tax incentive can the state provide drivers in
using a GPS system?
o With all the new applications that the MBTA is using, how do we
set up a carpool application where residences can share rides
with neighbors they may not be aware go to the same direction
8
o Not all suburbs are the same and Medford is not Somerville. Tailor
transit needs to the specific suburb. Medford is a car driving city
with our own traffic patterns, our own purpose and our own goals.
These patterns are not likely to change. The focus on Medford
Square has been to make it a transit center for development
purposes. How best to use that has a central transit site without
creating more congestion and diesel fumes within the area? Can
vanpools or shuttle buses be centered there from local
employment centers such as to Station Landing or Rivers Edge to
cut down on traffic within the city?
o And lastly, consider using some of your current projects as
mitigation substitutions in reaching air quality goals.
We believe if Mass DOT opens its mind to those other than special interest groups who
have their own agenda in supporting university expansionism that is focused solely on
research and development for those with advanced degrees, they can be creative in
thinking outside the box in achieving transit goals while also meeting more socially
equitable goals that do not harm the environmental justice and disability communities
established within their communities. Although everyone may want everything out of a
project, common sense must over ride special interest considerations so the project can
move forward in a way that all taxpayers can live with.
These comments are respectfully submitted by GLAM:
cC!to~
Chairperson
GLAM
9
Page 1 of13 GLAM
From:
To:
Sent:
Subject:
"carolynrosen" <carolynrosen@comcast.net> "GLAM" <glamtwo@comcast.net> Monday. September 12. 2011 10:25 PM Fw: [MGNACommunity] Digest Number 610[1 Attachment] - - Original Message ---­
From: To: Bill Wood ; Carolyn Rosen
Sent: Tuesday. September 06. 2011 10:46 AM
Subject: Fwd: [MGNACommunity] Digest Number 610[1 Attachment]
Begin forwarded message:
From: MGNACommunity@yahoogroups.com
Date: September 6,2011 9:33:37 AM EDT
To: MGNACommunity@yahoogroups.com
SUbject: [MGNACommunity] Digest Number 610[1
Attachment]
Reply-To: "No Reply"<notify-dg­
MGNACommunity@yahoogroups.com>
MGNACommunity
Messages In This Digest (1 Message)
1. Fw: Your comments needed by Sept 13 to save
the Green Line Extension From: Ken Krause
Message 1. View All Topics I Create New Topic
RECENT
ACTIVIT'
Visit You
Check 0
Fw: Your comm ents needed by Sep t
13 to save the Green Line Exten sion
V! Groul
blog
Posted by: "Ken Krause" kenneth.krause@comcast.net kenmedford Stay up
speed
Mon Sep S, 2011 7:36 pm (PDT) on all th
Groups!
[Attachment(s) from Ken Krause included below]
Dog Zor
Below and attached is information
prepared by members of the Somerville
Transportation Equity Partnership (STEP)
on Vaho
Groups
9/12/2011
Page2of13
to help Green Line Extension supporters
to prepare comments and know about
important meetings to attend to fight the
latest, proposed delays. Please forward this
information to friends, colleagues and
email lists.
Join a Group
all about
dogs.
Yahoo!
Groups
Ellin Reisner, STEP
Mental Health
Zone
Please help get the Green Line back on
track toward timely completion!
Find support
for
This message contains important
information on the most impactful things
you can do to fight back against the
proposed Green Line delay. We have been
successful in turning things around in the
past and with your help we will be
successful again.
Part 1. Key information on current status
DELAYS and what you can do about them.
Mental
illnesses
Need to
Reply?
Click one ofthe
"Reply" links to
respond to a
specific message
in the Daily
Digest.
Part 2. Where to send written comments.
Dates and times of important meetings.
Part 3. Speaking points for your written
comments or for speaking at meetings
Part 1. Green Line Extension supporters
are furious about the LATEST announced
delays. TO REVERSE THE GREEN UNE
DELAYS SEND WRITIEN COMMENTS
via email or letter by 5 PM, SEPTEMBER
13 to:
9112/2011 Page 3 of 13 . The Mass Department of Environmental
Protection (DEP) to reject MassDOT's
request to delay the Green Line opening to
2018-2020.
. The Boston Region Metropolitan
Planning Organization (MPO) to reject the
same delays that are contained within the
2012-2015 Transportation Improvement
Program (TIP) and Long Range
Transportation Plan (LRTP).
Use the contact information and key
points below to write your comments. We
believe it will be most effective to write a
single comment to multiple recipients and
reference the "SIP transit commitments",
the "Boston MPO 2012 - 2015 TIP" and
the "Boston MPO LRTP".
MassDOT's performance has been awful,
but YOUR COMMENTS can make a
difference.
Your actions and letters have saved the
Green Line before. We need to do it again
NOW!
IMPORTANT POINTS about the Green
Line Extension:
The original legal agreement in 1990 to
extend the Green Line was revised in 2000
for planned completion in 2011. Then it
was delayed to 2014 in revisions to the
State Implementation Plan (SIP), legal
obligations under the Clean Air Act. Then
9/12/2011 Page 4 of 13 last year MassDOT said the Green Line
Extension (GLX) would not open until
2015. Now, they have announced even
more delays, to 2018 to 2020!
SUSTAINABILITY. It is important to
remember that the Green Line Extension
is a great, sustainable transportation
project. It's light rail that will provides
clean transit to the city most health­
burdened by highway and diesel
commuter rail pollution. 85% of
Somerville residents will have access to
rail and many of our neighbors in East
Cambridge, Medford and Arlington will
have access to new light rail. It will also
integrate with the Community Path,
providing convenient access to Green Line
stations and completing a bike and
pedestrian route from Bedford to
downtown Boston. The Green Line
Extension fully embodies the principles
espoused by GreenDOT*.
It is no wonder the Green Line is
overwhelmingly supported in Somerville
and surrounding communities.
THE GREEN liNE IS A LEGAL
OBUGATION UNDER THE CLEAN AIR
ACT. It has been the state's single largest
Transportation Control Measure (TCM)
obligation under the State Implementation
Plan (SIP) for twenty years. Thus, it is a
binding legal obligation under the Clean
Air Act. Federal Transportation
Conformity Regulations require that SIP
9112/2011 Page 5 of 13 TCMs like the Green Line Extension must
be given funding and completion priority
by the region and state.
Meeting this legal obligation requires the
Boston MPO to show realistic funding
sources and timely completion of the
Green Line Extension in both the 2012 ­
2015 Transportation Improvement
Program (TIP) and the Long Range
Transportation Plan (LRTP). Currently the
TIP shows less than 50% of the money and
less than 50% of the Green Line Extension
being completed by the legal deadline of
20 14.
The Draft 2012 - 2015 TIP and the Draft
LRTP "Paths to a Sustainable Region" fail
to meet both the "fiscal constraint"
requirement for full funding and the
"environmental" requirement for timely
completion of the SIP TCMs. And, beyond
the binding legal obligations, MassDOT
and the Commonwealth have failed over
and over again to meet promised deadlines
given to the Green Line Extension
communities. Citizens deserve greater
respect.
FUNDING, TIMING and
TRANSPARENCY. The Green Line
Extension communities have repeatedly
welcomed project staff from MassDOT, the
MBTA and their consultants. Cooperation,
rapport and enthusiasm have generally
been high on both sides whenever people
have rolled up their sleeves to tackle
9112/2011 Page 6 of 13 project details. However, MassDOT has
too often been coy and tactical, squirming
at major steps with regard to securing real
funding for the project and making
reasonable time commitments.
PART 2. Primary email "SIP and TIP"
comment recipients are as follows: (mail
addresses available on STEP website,
www.somervillestep.org):
Mr. Jerome Grafe, Mass Department of
Environmental Protection, jerome.grafe@
state.rna.us
Ms. Christine Kirby, Mass Department of
Environmental Protection,
christine.kirby@state.rna.us
Mr. David Mohler, Chair, Boston MPO
Planning & Programming Committee,
David.rnohler@state.ma.us
Ms. Katherine Fichter, MassDOT Office of
Transportation Planning,
Katherine.fichter@dot.state.rna.us
Via email to Boston MPO Staff at
publicinforrnation@ctps.org
Important Federal agency transportation
plan reviewers to copy your comments to:
Ms. Anne Arnold, Manager, EPA Region 1
Air Quality Planning Unit, arnold.anne@
epa.gov
9112/2011 Page 7 of13 Mr. Donald Cooke, Conformity and mobile
monitoring, EPA Region 1 Air Quality,
cooke.donald@epa.gov
Ms. Rosemary Monahan, EPA Region 1
Smart Growth Coordinator,
monahan.rosemary@epa.gov
Ms. Pamela Stephenson, MA Division
Administrator, Federal Highway,
pamela.stephenson@dot.gov
Mr. Michael Chong, Federal Highway
Planning and Environ. Program Manager,
michael.chong@dot.gov
Ms. Mary Beth Mello, Regional Director,
Federal Transit Region 1, william.gordon@
dot.gov
If you can, please also consider
ATTENDING these TWO IMPORTANT
MEETINGS:
1. Tuesday,
Sept 13, 1 pm or 5 pm
Mass Department of Environmental
Protection (DEP) Hearing on SIP
One Winter St, Boston - Conference
Center, 2nd floor
2. Thursday, Sept 22, 10 am
Boston Region MPO Meeting - MPO vote
on TIP and LRTP
10 Park Plaza, Boston, 2nd floor
Short or long, written or spoken, every
personal comment will help our
9/12/2011 Page 8 of 13 community.
We have been very patient, we love the
Green Line, but we want more than just
hearing what a great project the Green
Lineis--enoughisenough!
ADDITIONAL POINTS YOU CAN USE TO
MAKE YOUR COMMENTS
STATE IMPLEMENTATION PLAN:
a.. MA DOT states that securing federal
"New Starts" funding for the Green Line is
risky because of the MBTA financial
condition, but MA DOT has not
demonstrated it has a funding plan and
design and construction schedule to meet
the SIP requirements using only state
funding - which has been agreed to by the
Commonwealth in the SIP agreement.
b.. Monthly SIP reports as late as May 2011
committed to completing the Green Line
Extension at the end of 2015, with no
suggestion of further possible delays. This
reflects a lack of transparency and
seriousness in meeting the SIP
requirements.
c.. MassDOT's assertion that land
acquisition is a primary factor in the latest
delay is not acceptable. Commuter rail
track could be moved and track could be
laid while waiting to acquire land for the
Ball Square and Union Square Stations.
Using Greenbush Line land acquisition
delays as a lesson learned for the GLX is
not a valid comparison because the land
9112/2011 Page 9 of 13 required was for right of way. This is not
the case for the GLX. GLX land acquisition
is for station locations and the
maintenance facility (not included in the
SIP agreement)
d .. The suggested phasing scenario
proposed for constructing the GLX should
only be permitted if the State is legally
bound to complete of the full GLX to
Route 16 by 2018.
IMPACT OF DELAY ON HEALTH
The Green Line Extension is supposed to
mitigate the health effects ofvehicle
pollution from 1-93 and regional highway
traffic as well as regional ozone. Delaying
completion ofthe project without
mitigation of the pollution will continue to
negatively affect the health of Somerville
and regional residents. Somerville has the
greatest daily exposure to commuter traffic
and diesel rail pollution in the state from
250,000 vehicles on 1-93, Mystic Avenue
(38) and McGrath Highway (28). We also
breathe fumes from 200 daily diesel
commuter and freight trains that cut
through the city but (fortunately) do not
stop.
People who live in the most
transportation-polluted 10% of a large
urban region may have:
20% higher overall mortality rates; 50%
higher lung cancer mortalities
9112/2011 Page 10 of13 50% higher childhood asthma rates 50%
higher heart attack mortalities
IMPACT OF DELAY ON
REGIONAL/STATEWIDE ECONOMICS:
a.. Could jeopardize the State's federal
transportation funding, a loss of $650
million per year.
b.. Would significantly increase the cost of
the GLX project and needlessly cost
taxpayers statewide $200 million or more,
plus the costs of required air quality
mitigation to offset the delay.
c.. Will deny a key regional transit link for
employers, universities, research centers
and residents.
d.. Will result in significant loss of sales
and income tax revenues to the
Commonwealth because it misses the
opportunity to create construction and
other jobs when we really need them.
e.. Will cause us to miss the benefits seen
by other regions in the country such as Salt
Lake City, Utah and Dallas, Texas that
have recently built light rail on time and
sometimes under budget.
IMPACT OF DELAY ON THE
COMMUNITY PATH
a.. Delaying GLX also delays the
Community Path. The 2.3 mile
Community Path extension will connect
the regional Minuteman Path network to
Boston and to the Charles River network.
9112/2011 Page 11 of13 TRANSPARENCY/CREDIBILTIY:
a.. Governor Patrick committed to build
the Green Line Extension during his term
in office.
b .. Governor Patrick and the Lieutenant
Governor must honor this commitment.
c.. The Green Line Extension was legally
mandated in 1990. Thirty years is an
unacceptable delay.
d.. The Green Line Extension has never
been given top priority, even though it is a
legally obligated Transportation Control
Measure specified in the State
Implementation Plan (SIP).
a.. The state must pursue full bond
funding of GLX to satisfy Federal
Transportation Conformity.
Why is GLX not being moved as
aggressively as the Fast14 Bridge
replacement project? With all the
supposed brain power of our region, why
can't we get a 7 station transit extension
built in a timely, cost-effective way? We
have just recently built a massive new
highway bridge on the Cape and we are
widening our highways with a multi-year
Route 128 mega-project, but we just can't
seem to get a shovel in the ground on time
for a sustainable urban light rail project.
*GreenDOT http://transportati
on.blog.state.ma.us /blog/
2010/06/massdot-Iaunches-greendot.
html
"GreenDOT, a comprehensive
9112/2011 Page 12 of13 environmental responsibility and sustainability initiative that will make MassDOT a national leader in "greening" the state transportation system. GreenDOT will be driven by three primary goals: reduce greenhouse gas (GHG) emissions; promote the healthy transportation options of walking, bicycling, and public transit; and support for smart growth development." Ellin Reisner, Ph.D.
reisnereSl@gmail.com
4.ttachment(,) from Ken
Krau~e
1 of 1 File(s)
~
~
GLXOutreach.pdf
Reply to sender I Reply to group I Reply via web post
Messages in this topic (1) Back to top Create New Topic I Visit Your Group on the Web
Messages
I Files I Photos I Links I Database I Polls I Members I Calendar
MARKETPLACE
Stay on top of your group activity without leaving the page you're on - Get the Yahoo! Toolbar now. A bad score is 579. A good idea is checking yours at freecred itscore.com. 9112/2011
Page 13 of13 8
I ..
Chan ge settin gs via the Web (Yahoo! 10 required)
Change settings via email: Switch delivery to Individual I Switch format to
Traditional
Visit Your Grou p I Yahoo! Grou ps Terms of Use I Unsubscribe
9/12/2011 Memo to:
Kenneth Kimmell, David Mohler, Katherine Fichter, Jerome Grafe, Christine Kirby, Arnold
Anne, Donald Cooke, Rosemary Monahan, Pamela Stephenson, Michael Chong, William
Gordon
From: Fred Salvucci
Subject: Appropriate Mitigation for MassDOT Request to Amend Transit System
Improvement Regulations dated July 1, 2011
Date: Sept 14, 2011
I am writing to comment on the Boston MPO TIP and LRTP and the Annual Status Report of the
transit projects in the State Implementation Plan. This memo contains my comments on the
appropriate actions which should be required of Mass DOT to mitigate the damage to the
environment caused by the latest announced slippage in timetable on the SIP commitments entered
into in 2006 pursuant to their agreement to settle the litigation with the Conservation Law
Foundation concerning prior slippage on the commitments of the 1993 SIP. Because of the
heightened attention which the Conservation Law Foundation lawsuit settlement has brought, it is
all the more important for the DEP to hold MassDOT to a very high standard of mitigation.
Moreover, MassDOT is also in violation of the more extensive commitments entered between
MassDOT predecessor agencies with CLF in 1990, and the conditions attached by the DEP to the
ventilation shaft permits of 1991, required for the construction of the Big Dig. Again, the new
slippage in timetable should trigger an even higher level of mitigation, in light of the prior. litany of
failures to honor their original commitments and the various Administrative Consent Orders entered
into in the late 1990s and early 2000s, which are themselves mitigation for previous failure and
slippage. It is important to recognize that these commitments were made by the Commonwealth
and MassDOT, not primarily by the lYIDTA, so that these are financial obligations by the
Commonwealth and all its agencies, including MassDOT, Massport, and Administration and
Finance, and not only the MBTA.
A) Appropriate mitigation for the most recently announced slippage
1. Fairmount Branch: Slippage on this element of the SIP is the most modest. Station
construction is actually underway, if somewhat behind schedule, and a bus service
enhancement is proposed as mitigation. But in addition it would be appropriate for
MassDOT to purchase or lease Diesel Multiple Units (DMUs) and initiate frequent 10
minute service, as the community has requested for several years to make this a truly urban
quality rail service and contribute to community stabilization and revitalization. MassDOT
should be required to model and test the potential effectiveness of frequent DMU service,
along with a sensitivity analysis of different service frequencies for discussion with the city
and community groups, and then implement a suitably frequent schedule.
2. Revere Parking Facility: This is behind schedule, but MassDOT suggests that no mitigation
is required because there is surplus vacant parking available adjacent to the proposed
facility. This situation is an indication that the parking was an inappropriate action to
propose in substitution for the Blue-Red connection to begin with, and that the appropriate
mitigation is to revisit the planning assumptions. Since the program to increase the capacity
of the Blue Line by 50%, through increasing station length to accommodate 6 car rather
than 4 car trains is almost complete, increased utilization of the Blue Line is a prime
opportunity to increase transit access to Boston. In the absence of an effective program,
there is significant risk that the l'vIDTA could lengthen trains and reduce frequency, actually
wor~ening
service to the Environmental Justice communities of East Boston, Chelsea, and
Revere. At a minimum, MassDOT should be required to not worsen current levels of
frequency on the line, and conduct planning analysis of how to effectively use the newly
increased capacity. The planning analysis should include short-term actions like improved
bus feeder services from Lynn, Revere, Chelsea, \Vinthrop, and East Boston to the Blue
Line. Longer range options should include the possibility of extensions of the services to
Charles Street via the Blue-Red connector, and to Lynn via a new extension from
Wonderland. These planning analyses should be prepared and discussed with the affected
communities and municipal governments in order to develop both short and long term
mitigation for the ineffectiveness of the parking expansion.
3. The Blue-Red Connector Extension to Charles St Station Engineering Design: This was
committed by MassDOT for completion by December 2011. One year ago MassDOT
reported that it was on target to complete the design. Now, with no prior discussion with
affected communities, MassDOT has pr<?posed to not complete the design and argues
disingenuously that no mitigation should be required, because completion of engineering
designs without construction and operation would not in and of itself reduce air pollution.
Of course the design was considered as a first step towards implementation, which is why it
was agreed to as part of the settlement. It is also important to remember that the
predecessor to MassDOT committed to having the Blue-Red connector in operation by the
year 2000 in the 1991 DEP ventilation shafts permit, and to recognize that MassDOT has
now conceded that the \Vonderland garage will have no beneficial impact on air quality.
But by its inaction, MassDOT has caused delay in completion of engineering. The
appropriate mitigation action is to achieve actual service on the Blue-Red connection at the
earliest achievable date, by conducting a value engineering review of the current state of
design, preparing design-build procurement documents, and including the Blue-Red
connector construction in the design-build package for the Green Line extension, in order
to achieve economy of scale and timely implementation at a reasonable price.
Of the many valuable transit improvement projects which are being left in varying
. states of disarray by MassDOT, the Blue-Red is the one project whose implementation is
achievable in a relatively shorter time frame which addresses a critical failure point in the
current Boston transit system: namely, the lack of capacity in our core transit system which
depends on the convergence of our major radial transit lines in the Boston regional core
(Red, Green, and Orange as well as Blue Lines). While other projects that address this
failure point have also been advocated (e.g., the Urban Ring), we are told by MassDOT that
those projects must await advancement in a manner addressing core system congestion until
some undefined time when new resources become available. The Blue-Red Connector
project should not and need not be lumped into this same miasma.
4. The Green Line Extension to Union Square and Medford Hillside: This extension was
committed to by 2014 in the 2007 SIP (service should have commenced to Medford
Hillside by 2011, according to the 1993 SIP). A year ago MassDOT announced that the
schedule had slipped to 2015, and now MassDOT has announced further slippage to 2018,
or even possibly 2020, on the flimsiest of excuses. Property acquisition for the maintenance
facility cannot commence until the federal NEPA approval is secured, so MassDOT
indicates reluctance to commence the design build process without first acquiring all the
necessary real estate. But the federal environmental process should have been completed
about one year ago, along with the state and MEPA process, and in any case seems likely to
be complete before the end of this year. A design-build process is lengthy in any case, so if
the state proceeds in parallel, the federal environmental approval and land
acquisitio~
can
be in place in time for design-build contract award. In any case, the maintenance facility,
while desirable, is not necessary to complete the extension and commence service, and
could be added later if necessary, as long as the appropriate track and switches are put in
place to access the area. Much of the schedule slippage has been self-inflicted by the
Commonwealth. Significant delay was caused by the MassDOT effort to locate the
maintenance facility at an unacceptable location (Yard 8) and by Mass EOEA insisting on
an additional environmental process to address the revised maintenance location, even
though the proposed facility is not an essential element of the extension promised in the
SIP. Moreover, MassDOT chose to change consultants partway through the process,
almost certainly causing further delay.
At this point, the first obligation of MassDOT is to mitigate the extent of the
schedule slippage, which will otherwise cause both cost increases because of construction
cost inflation, and delay of air quality benefits, service, economic development, and other
benefits to Somerville and the region. MassDOT should be required to develop a revised
and more reasonable schedule in discussion with the City of Somerville and the affected
communities.
Secondly, it is clear that there are significant features of the Green Line Extension
project that have substantial transit and air quality value, which MassDOT has been
proposing to defer, and which should be implemented as part of the design-build process as
early actions. These include the bridge connecting Inner Belt Road to North Point
Boulevard, essential to facilitate the Urban Ring connection between Lechmere and Sullivan
Square, enable the transit-oriented economic redevelopment of the Inner Belt area, and
establish a critical link of the community path and bicycle connection from Alewife through
Somerville to the Charles River. This critical link should be built as part of the earliest
construction, linking Lechmere to Washington Street and Union Square. If, as increasingly
appears likely, the mitigation of the schedule slippage involves a staged opening to
Washington Street and Union Square prior to completion of Medford Hillside, the Urban
Ring connection to Sullivan Square can help to mitigate the delay by improving transit and
expediting the transit-oriented development, both of which will contribute air quality
benefits.
In a similar way, including the Twin City/Target Store station in the first stage of
construction can further improve transit ridership, economic development, and air quality.
B) Methodology for Evaluating the Effectiveness of Possible Mitigation Strategies
Typically, MassDOT has used a methodology to predict regional air quality impacts
based on vehicle miles of travel by autos (VMT). But the methodology is inadequate for
evaluating the damage of schedule slippage, particularly for the Green Line extension and the
Blue-Red connector.
First, the entire basis of the air quality calculations for the Big Dig was not VMT, but
VHT (vehicle hours traveled by auto). VHT is a better indicator of air quality impact, but
requires the ability to measure and predict congestion effects of growth in auto use. Because the
CTPS methodology predicts traffic volumes which exceed the capacity of key highway facilities,
the predictions of the methodology do not properly reflect the fundamentally congested nature
of key parts of the highway system. Congestion causes more delay, more VHT, and more air
pollution. Therefore, the methodology is inadequate as a tool to model air quality for the
purpose of enforcing the SIP or for evaluating conformity. The core of the transit system is
similarly predicted to carry significantly more passengers than is possible, underscoring the
inadequacy of this methodology. Because of this fundamental flaw in methodology the entire
SIP revision proposal should be rejected by DEP. It should be sent back to MassDOT for
appropriate modification of the methodology, and reconsideration of the entire proposal based
on the revised results.
Secondly, the most significant drivers of VHT are land use, trip distribution, and mode
share. Delay in implementing the Blue-Red connector and the Green Line extension affect not
only the transit and auto mode share of a fixed set of trips, they affect the distribution of activity
and trips being made, as well as land use. For these reasons the methodology used to estimate
the damage done to air quality by schedule slippage on transit improvements needs to be based
upon a more fundamental review comparing the land use and trip distribution and VHT
projected in the 1990 Big Dig FEIS, and the originally assumed transit improvements in the
1990 model, in comparison with what has actually occurred, to measure whether the
improvement in air quality predicted for the year 2010 actually occurred or not, the differential
air quality impacts as a result of differences identified, and the likely effectiveness of various
mitigation strategies.
It is highly likely that using appropriate methodology which identifies the projected state
of VHT in the year 2010 according to the Big Dig versus what has actually transpired, the
mitigation options suggested in section 1 would be useful but not sufficient to fully mitigate the
excessive VHT being generated by the actual measured land use, trip distribution, and VHT, and
that additional transit improvement is required to address the adverse impact of late delivery of
transit improvements assumed in the base documents of the 1990 FEIS, the 1991 vent shaft
DEP permits, and the 1993 SIP. It would be useful and appropriate to consider the various
measures proposed in these original documents, as well as in the various Administrative Consent
Orders, such as the Urban Ring and the missing link of the Silver Line, to identify suitable
additional mitigation measures to not only achieve the state of performance of the
transportation system initially projected to result from the Big Dig, and the resultant state of air
quality, but to deal with the new challenges to improve both economic and environmental
performance for the next century.
c. Financing the Additional Mitigation Measures Required
There has been speculation that part of the explanation for the very poor record of
implementation of the committed transit improvements is that the cost increases during
implementation of the Big Dig along with the change in federal law which limited the availability
of federal funding to cover the cost increases at the traditional 90% level,
l~d
the state to fail to
complete the program of transit improvements it had promised as part of the Big Dig. The state
share of Big Dig costs grew from under $1 billion projected in 1990, to over $8 billion by today,
an unprogrammed increase of $7 billion from MassDOT to actually implement the promised
transit improvements at a scale and timetable adequate to be effective will require identifying a
source of revenue to support the necessary transit investment, in light of the extremely stressed
state of MassDOT and MBTA Finances. The cost increases associated with the Big Dig may at
one time been avoidable, but they are now physical and financial facts which cannot be wished
away. Morally, MassDOT and Mass Administration & Finance are obliged to fund the transit
commitments of the Big Dig, which are necessary to achieve the benefits identified in the 1990
SFEIS and the 1991 vent shaft permits. But, in light of other pressing financial problems, the
Commonwealth is in fact unlikely to fund its outstanding Big Dig obligations unless a viable
funding strategy can be identified. Central and \Vestern Massachusetts toll payers and taxpayers
are understandably reluctant to finance the missing 7 billion dollars of Big Dig expenditures, let
alone the additional transit investment necessary to make it function properly. One mechanism
which may reasonably fill the financial gap is an additional Big Dig assessment on Massport, the
primary beneficiary of Big Dig investment. If a Big Dig access fee of appropriate size is assessed
on Massport for every parking space at Logan and the South Boston waterfront, the funding for
completion of the Big Dig obligations can be identified in a manner that does not unfairly toll or
tax Central and \Vestern Massachusetts for Eastern Massachusetts economic infrastructure.
Again, it must be underscored that the transit mitigation projects agreed to by MassDOT and its
predecessors are obligations of the Commonwealth, not MBTA, and that "flexing" of "highway"
funds, and
"creativ~
finance" options with the support of Administration and Finance must also
be available. SIP projects are supposed to be prioritized over other transportation projects in
the TIP and long range transportation plan. Continued failure to implement is not a legitimate
option, and the Massport airport/seaport parking, and aGcess management assessments is likely
to emerge as the most equitable approach.
Finally, while as a matter of equity and credibility of the MEPA and DEP processes
the commitments made in 1990 and since should be honored in their entirety, it needs to be
recognized that the last comprehensive and multi-modal review of the metropolitan and urban
transportation was the Boston Transportation Planning Review of 1971-1972. Much of the
transit agenda which emerged from that process, with the exception of the proposed Blue Line
extension to Lynn, had either been completed (like the Red Line extension from Harvard Sq to
Alewife) or is in fairly advanced state of environmental analysis and planning (such as the Green
Line, the Blue-Red connector, the missing link of the Silver Line, the Urban-Ring). The
timetable slippage by one, two or more decades should not distract us from recognizing the
enormous improvement in public transportation required to meet the challenges of the new
century, especially climate change and sustainable economic growth. Yet for decades now the
region has been stuck in a rut of endless "planning" and priority revision among existing
commitments, with little implementation. Meanwhile, there in insufficient intellectual capital
investment in developing the next set of necessary transit investments to support sustainable
economic growth. But the economic world does not stand still. The Green Line is operating
beyond its capacity, as is the Red Line. As The Longwood Medical Area becomes more
congested, a key economic and social engine is approaching gridlock. The region needs to catch
up by implementing the overdue investments supported by past planning, while simultaneously
developing the agenda for the next generation of investment required to ensure an equitable and
sustainable region for this century. The lack of this forward agenda is a casualty of the past two
decades of inaction. In short, DEP should require both an action agenda as identified above, and
a planning process for the environmental needs of the future.
Sincerely,
Frederick Salvucci
September 16~ 2011
From: Mary Anne Adduci
2 North Street
Medford, MA 02155-431S
Phone:
~TO:
781-396-5138
Ms. Kate Fichter
MassDOT
Office of Transportation Planning, Room 4150
Ten Park Plaza
Boston MA 02116
To: Mr. Jerome Grafe MassDEP Bureau of Waste Prevention Easton MA 02018 To: Mr. David Mohler, Chairman Transportation, Planning & Programming Committee Boston Region
Metropolitan Planning Organization 10 Park Plaza - Suite 2150 Ebston MA 02116 Subject: Submission of written testimony for inclusion with the
9/13/11 MassDEP Public Meeting testimony regarding the
planned MassDOT Green Line Extension Project.
Dear Sir/Madam:
In 2010, I submitted both DEIR and FEIR public comments to MEPA
regarding the Green Line Extension Project. In these comments I
explained why I could not support the Green Line Extension, and
voiced my opposition to a Route 16 station, in either Phase I, or
in a later Phase II. My 2010 DEIR and FEIR comments are already
sn record so please include them with the following testimony.
I want to make clear that I'm opposed to the issuance of any MA
state Bonds to fully, or partially fund the construction of the
Green Line Extension. In these tough economic times, the State
has been forced to cut-back spending in many crucrial areas, and
it is outrageous to think that the State would rather divert
funds from crucial areas to the Green Line Project which isn't
urgent, or isn't an absolute necessity. What some people seem
to forget is that we already have other forms of public trans­
portation in the Green Line Extension Service Area that works
and is not over-burdened with demand. So the building of this
Green Line Extension is not an absolute necessity, but rather
falls into the "nice to have category" that the State should be
addressing with a much lower priority. Neither the State or the
September 16, 2011
Page 2
MBTA/DOT has any extra money, or should be ralslng any ex~ra money
for anything other than urgent needs and urgent projects. Although
it's not your issue, I feel the same about the spending of Federal
Funds on the Green Line Project.
I do not feel the MAPC Community Visioning Process for the Route 16
Station planning reached-out enough for the opinions of those local
residents and abutters to the Route 16 Station area. Some of these
local people are elderly, do not buy newspapers, or have computers.
As recent as this week, I spoke to a Walkling Court resident when I
went to tme Walkling Court Polling Place to vote, and she did n~t
know anything about the Green Line Extension Pro~ect, or the proposed
Route 16 Stationl The MAPC process collected oplnions of anyone who
showed up at their meetings (including those who live beyond the
adjacent Route 16 residential community) and will represent these
opinions as an inaccurate representation of the local residents)
because so few local residents showed up, or eY&n knew about the MAPC
meetings.
One of the points being marketed for building a Route 16 station is
the potential for economic growth to the adjacent parcel of land
which is partially Somerville, and partially Medford due to the city
boundary at this locatlion. However, this parcel of land is already
economically developed from what it was years ago when an abandoned
mattress factory oce.upied 196 B'o ston Avenue, and a paper box manu­
facturing company occupied 200 Boston Avenue. Cummings Properties
bought and renovated these buildings into offices, labs, and a health
club and have photographs of the "before and after". Elizabeth Grady
set up their school in the vacant building that they renovated and
which sits next to the North Street Bridge. Over lQ ye~rs ago}
Elizabeth Grady also built a smaller new building on Boston Avenu~ in
front of t~eir school building, however, this new building has been
vacant, and has a for-lease sign on it for ten years dispite the fact
that it is located a few feet from bus stops for buses dispatched
between Lechmere & Arlington Center, and between Medford Square and
Davis Square. There is no guarantee that more public transit at the
Route 16 location will encourage economic growth as evidenced by the
10-year vacancy of the newly built Elizabeth Grady property!
Somerville has been the driving force for the Green Line Extension,
but when discussing the Route 16 Station, they should yield to the
position of Medford as the impact of a Station in this area will have
a significant negative impact on the Medford residential community
that abuts and is surrounding this parcel of land. Medford and
Somerville are different in many ways: Som~rville is one of the most
dense areas in the state where there is very little green space, and
comme~i81 properties and residential properties are all jammed to­
gether side-by-side. A large majority of it's residents are renters
in multi-unit houses, and a significant number of residents do not
own a car so more public transportation makes sense for Somerville.
Medford, on tae other hand, has a lot of green space, is largely
residential with commercial areas clustered together, rather than
mingled-in side-by-sid~ with residences like Somerville. Medford has
a large number of single-family homes and a significant number of
it's residents own a car. There is obviously less need of more public
September 16, 2011
Page 3
transportation in Medford than in Somerville. Medford highly values
the fact that we are not all squeezed-in and compacted togetmer in a
"hodge..,podge" of commercial and residential property jammed together
side-by-side in an unappealing design. Medford sees itself from all
visual appearamces as "suburban" and not "urban", and we do not want
to negatively alter the visual landscape ana feel of our community
with,and for the sake o~ "economic development to the Route 16 parcel
of land". Somerville, due to an odd configuration, owns the "sliver"
of land where the Route 16 Station is to be located in the current
plans (in earlier plans a few years ago the proposed station was in
Medford). The above mentioned "sliver" of land, however, is not like
the rest of Somerville, as it is like an island that is surrounded by
the residential suburban community of Medford. Somerville is so
accustomed to seeing itself in the same dense urban way, that they do
not understand why Medford would object to a plan that would create
an uncomplimentary and unharmonious landscape where 2 to 4 story
commercial and residential buildings would be built next.to/across
from/or among the surrounding 1 and 2 family. homes. They also do not
understand (or c~re) why Medford would object to the loss of open
space when structures are built, the loss of green space and mature
vegetation along the railbed and among the parcels of land being
"~Gonomi~ally developed", and the added activity of bus and auto
drop-of.fs and pick-ups from this very very busy Route 16j:Boston Ave.
intersection. This does not even address the inc·rease in auto
traffic that would come to the commercial prope~ty added around the
Route 16 station to "economically develop" this location. A few
years ago, in the early plans for the Green Line Extension, DOT
clocked with a meter that there were 30,000 cars a day traveling on
Route 16, so it is likely this number would go up as a result of the
commercial development proposed for this location, and additioBBlly
burden a road that is already overburdened~ What happened to the
objective of "improving air quality"? ? ?
From MAPC meetings it appears that there is a desire to replace the
Walkling Court Senior Housing Complex as part of the economic develop­
ment around the proposed Route 16 Station
The scenarios ranged from
doubling the number of units with a new 4-story struct~re (with no
senior center on site), replacing the current structur~s with a new
2-story continueous structure consisting of the same number of units
as the present complex (with no senior center on site), or leaving
the current complex as is, which is the scenario I support. I feel
that it is 6 waste of money to rebuild the complex when all that is
needed is a little maintenance to "spruce-up" the buildings, and to
add elevators to make the buildings handicap accessable. Before
Walkling Court was built this lot was a vacant undeveloped field with
(Banta) a coal dealer occupying the area which is now the Walkling
Court parking lot beside the railbed. You could therefore say that
the Walkling Court site has already been "economically developed"l
At the time when it was built the design of Walkling Court was picked
due to its separate small 2-story structures that did not over­
shadow the abutter residences, and which would blend-in, appearance­
wise) with the adjacent residential neighborhood anu abutters (one
of these being Medford's Mayor McGlynn's Maternal Grandfather who
was politically "connected", as was Jack MeGlynn, the Mayors father).
I am also concerned about the displacement of the current' Walkling
Court residents if this complex is rebuilt, and whether or not the
new buildings would be exclusively occupied by the seniors and the
Q
September 16, 2011
Pae;e 4­
disabled, or would they be available to anyone. r am also concerned
about the gentrification that may result from the economic develop­
ment being proposed at the Route 16 location, and all other Medford
locations beyond Ball Square.
r am also against any further development on the land occupied by
Whole Foods and their parking lot as presented at the MAPC meetings
mentioned earlier. The Whole Foods store alon~ generates a lot of
vehicle traffic now, without the addition of more stores along the
Auburn Street side of their parking lot. There are peek shopping
times when the Whole Foods parking lot is pretty full, so if more
stores are added to reduce the size of this parking lot, the patrons
will park in the adjacent residential side streets, and cause more
traffic and congestion on Route 16, as vehicles and delivery trucks
go to and from this "economically developed ll Whole Foods parcel of
land.
I have heard that there are some project advocates who would be
willing to wait for a longer Green Line Extension completion date,
if the delay would bring the Green Line to Route 16, instead of
only College Avenue. I feel this position indicates that these
advocates are acknowledging t4at this project isn't as urgent as
they have been saying it is, because they can do without it for a
longer period of time. I think it would be useful to delay the
decisions about a Route 16 station, until the extension to College
Avenue is finished, so more information can be gathered at that
time to better determine whether or not a Route 16 station is really
needed. During the intrim between 2014 and the Gompletion of the
Extension to the College Ave. Station, I believe "alternatives" will
be used along the Green Line Extension Service Area. U$e of these
"alternatives ll may also provide valuable input to the decision
process to determine whether or not a Route 16 building process is
necessary and appropriate at that time. The State, therefore,
should not make any modifications to the "SIP" that mandates that
the Green Line will go up to College Avenue only. In the future,
if a Route 16 Station is still desired, and their is ample justifi­
cation, and money available to build it, I expect it will be built!
r am therefore opposed to any legal maneuvers by advocates, that
would alter the current plan, and legally mandate the State to
build a Route 16 Station. In my opinion, advocates who want a legal
mandate to build the Route 16 Station have doubts as to whether a
Route 16 build project would IIhold-up" to future scrutiny, and
prou.e to be a justified and worthwhile project down-the~road. I say
let the lIchips fall where they may", and not force the State into
spending money due to a legal mandate, rather than on the merits of
proposal. Isn't it better to be responsible, pradent, and judicious
in spending taxpayer money, especially in these tough economic times,
rather than making legal commitments that would require spending our
money, in order to pacify any outspoken groups?
I want to thank you for your time and attention, and for your
consideration of my testimony and remarks.
SincerelYI
CITY OF CAMBRIDGE
Robert W. Healy, City Manager
•
EXECUTIVE DEPARTMENT
Richard C. Rossi, Deputy City Manager
September 19, 2011
Katherine S. Fichter
Massachusetts Department of Transportation
10 Park Plaza, Room 4150
Boston, MA 02116
Re: Comments on State Implementation Plan - Transit Commitments
2011 Status Report
Dear Ms. Fichter:
The City of Cambridge submits the following comments on the State Implementation Plan- Transit Commitments 2011
Status Report submitted by Massachusetts Department of Transportation and Massachusetts Bay Transportation
Authority. Cambridge strongly supports improvements to transit facilities in Cambridge and the region to increase
transportation options for residents, improve livability and reduce the overall environmental impact of transportation.
The City of Cambridge is alarmed at the magnitude of the recently announced delays of the Green Line Extension project
to 2018-2020. The estimated delay is particularly disturbing because this project is a critical mitigation commitment of
the Big Dig, and is now proposed to be complete over a decade after that project was finished. In addition, this delay
comes on top of last year's SIP update which mentioned a one year delay, while the project proceeded under the new
design contract.
Time savings to the schedule must be found as the Green Line Extension is a very important project that will produce
significant air quality benefits and help support other sustainable forms of transportation. In addition, the project will
boost economic development in the areas of North Point and Inner Belt, bringing jobs that are close to transit and
requiring fewer car trips to access them. Short of keeping the project on schedule for 2014-2015, the state must find
readily-implementable substitution projects that would supply equal benefits in terms of air quality as this extension of the
Green Line.
I urge the Commonwealth to fully support and fund the Green Line Extension so that design and construction may
proceed swiftly with minimal, if any, delay. The City appreciates this opportunity to comment on this important project.
Ifthere are any questions on these comments, please contact Bill Deignan, Transportation Program Manager at 617-349­
4632 or wdeignan@cambridgema.gov.
.
Robert W. Healy
City Manager
cc: Christine Kirby, Mass Department of Environmental Protection
Donald Cooke, US Environmental Protection Agency - Region 1
795 Massachusetts Avenue, Cambridge, Massachusetts 02139
Voice: 617.349.4300 Fax: 617.349.4307 TTY: 617.349.4242 Web: www.cambridgema.gov
Smart Growth &- Regional Collaboration
METROPOLITAN AREA PLANNING COUNCIL
September 20, 2011
Katherine Fichter
Office of Transportation Planning, MassDOT
Room 4150
10 Park Plaza
Boston, MA 02116
Dear Ms. Fichter:
The Metropolitan Area Planning Council (MAPC) was deeply disappointed to learn in August that MassDOT
and the MBTA had determined that the completion date for the Green Line Extension from Lechmere to College
Avenue needed to be extended yet again. Federal, state and local partners have been working diligently for many
years to see this critical transit project come to fruition and serve one of New England's densest communities with
populations that rely on the availability of quality public transportation. The most recent delay put forth by
MassDOT places the anticipated opening of Green Line passenger service in the 2018 - 2020 time period, with
only 10% likelihood for service opening by September 2018.
Delaying the Green Line Extension four to six more years will have impacts on the significant work completed
around land use, zoning and economic development by the cities of Somerville and Medford and their partners.
The delay jeopardizes economic development opportunities that can bring new jobs and housing to the area,
spurred by an investment in public transit. The delay also places additional burden on environmental justice
populations that stand to benefit greatly by increased access to jobs and housing, air quality improvements, and a
reduced reliance on automobiles.
MAPC is concerned about the overall finance plan for the Green Line Extension. Solving this problem may
require the Legislature and the Governor to raise taxes, tolls, fares, or all three. These actions are not easy or
pleasant, but they are essential. Without these steps, we worry that the delay of the Green Line Extension is not
really a delay, but a long, drawn out termination.
With or without new revenues, we urge MassDOT to consider seriously proposals to fast-track at least a portion of
the project, even if the full project must wait for a longer time-frame. A phased approach may n ot be the most
efficient way to build the project, but it is certainly better than having no project at all, or waiting seven to nine
years for the full project to be built.
Furthermore, if the time-frame for the all or part of the project must be delayed, we urge MassDOT to consider
adding the segment between College Avenue and Route 16/Mystic Valley Parkway to the project that will be
completed between 2018 and 2020. In the long term, this would maximize air quality benefits and encourage
greater ridership of the new line.
MAPC understands that MassDOT/MBTA have yet to petition DEP regarding the delay to the Green Line
Extension, and that you are currently exploring options for interim offset mitigation. We urge MassDOT and
DEP to implement a public engagement process that involves stakeholder and public input in the early stages of
determining proper interim mitigation. Excellent ideas could come forward during this process that should be
considered and modeled as mitigation determinations are being made.
We also ask MassDOT and DEP to closely examine any interim mitigation proposals with an eye toward two
specific areas: interim mitigation should be located within the communities that will be served by the extension of
the Green Line, and interim mitigation should equal the air quality benefit the extension would have provided.
MAPC strongly supports expansion of public transit services in the project area and the timely completion of this
State Implementation Plan (SIP) commitment. The Green Line extension will improve access for residents and
businesses in the corridor and reduce auto trips and emissions. The project also provides benefits for walking and
biking through links to the Community Path and adjoining sidewalk connections. We urge MassDOT, the
MBTA and DEP to look closely at ways in which this project can be moved forward in keeping as close to the
original completion date as possible.
Thank you for the opportunity to comment on this important project.
Sincerely,
Marc D. Draisen
Executive Director
cc:
Richard Davey, Secretary of Transportation
Kenneth Kimmell, Commissioner, Department of Environmental Protection
Joseph A. Curtatone, Mayor, City of Somerville
MichaelJ. McGlynn, Mayor, City of Medford
60Temple Place, Boston, MA 02111 • 617-451-2770 • Fax 617-482-7185 • www.mapc.org
Michelle Ciccolo, President • Lynn Duncan, Vice President • Marilyn Contreas, Secretary • Taber Keally, Treasurer· Marc Draisen, Executive Director