State Implementation Plan – Transit Commitments 2008 Annual Status Report Agency Responses to Public Comments Submitted to the Massachusetts Department of Environmental Protection January 6, 2009 For questions on this document, please contact: Katherine S. Fichter Executive Office of Transportation Office of Transportation Planning 10 Park Plaza, Boston, Massachusetts 02116 617‐973‐7342 katherine.fichter@eot.state.ma.us INTRODUCTION This document summarizes and responds to public comments received by the Massachusetts Executive Office of Transportation (EOT) on the State Implementation Plan ‐ Transit Commitments 2008 Status Report submitted to the Massachusetts Department of Environmental Protection (DEP) on July 1, 2008 in order to fulfill the requirements of 310 CMR 7.36(7), Transit System Improvements. The report detailed the status of six public transit projects – listed below – required of EOT under 310 CMR 7.36. The projects are: ƒ Greenbush Commuter Rail Restoration ƒ Blue Line Platform Lengthening and Station Modernization ƒ Fairmount Line Improvement Project ƒ Construction of 1,000 New Parking Spaces ƒ Red Line/Blue Line Connector ‐ Design ƒ Green Line Extension to Somerville and Medford This document also responds to questions on projects not included in the Status Report. EOT received public comment on the Status Report through September 12, 2008, following a two‐part public meeting (September 8, 2008) at which EOT presented on the content of the Status Report. The majority of the comments received by EOT pertain to the extension of the Green Line to Somerville and Medford. EOT has reviewed all of the comments received – they are included here in full, as is a list of all of the submitting individuals and organizations – and has grouped and summarized them so as to capture the salient ideas while reducing redundancy and overlap. As much as possible, we have listed the comments here in the same language as that used in the original comment, with clarifying notes as needed. In this document, indication of the authorship of each comment has been removed. Project Critical Path Issues A number of critical path issues have arisen on several of the SIP‐required projects since the submission of the Status Report in July. While we are not yet at the point at which we need to consider interim emission reduction offset projects, in the interests of transparency we wanted to notify DEP and the general public of the following schedule‐related concerns: Green Line Extension to Somerville and Medford ƒ The challenge of siting a northside support facility for the storage and maintenance of Green Line vehicles – a facility integral to the implementation of the Green Line Extension as a whole – has proven formidable. Despite months of work, EOT has not been able to identify a location that is both technically and financially viable for the Project and acceptable to the City of Somerville. ƒ The delayed implementation of the NorthPoint development project has forced the Green Line Extension project to absorb responsibility for the design of the relocated Lechmere Station, and has left the funding – and, to a lesser extent, the timing – of the relocation uncertain. ƒ The process of determining an appropriate terminus for the Green Line Extension – whether at College Avenue or at Mystic Valley Parkway/Route 16 – has been lengthy, with strong arguments in favor of both locations. While EOT continues to work toward a resolution, the exact timeframe within which the decision will be made cannot be guaranteed at this point. ƒ The most time‐consuming single component of the overall Green Line Extension project is the design, procurement, and receipt of new Green Line vehicles to be used to service the line. The process of retaining a design consultant has been lengthy and the exact timeframe for the completion of this effort is subject to variables outside the control of EOT. Executive Office of Transportation January 6, 2009 Page 1
Construction of 1,000 New Parking Spaces ƒ The process of identifying appropriate locations in which to construct the required 1,000 new parking spaces has been lengthier than expected. While the effort is now underway, the exact timeframe within which all of the 1,000 spaces will be sited is not fully defined. Public Input The projects described in the Status Report each have public input processes associated them, but the public process associated with the State Implementation Plan (SIP) provides an additional opportunity for EOT to hear from interested individuals and organizations about the progress and direction of our projects. This is a valuable reminder that our projects will serve real people in real communities, and to strive always to shape our efforts to meet the needs of the users of the transportation network, both present and future. At the same time, the framework of the SIP obliges us to retain a regional perspective and to understand that the portfolio of projects mandated under the SIP are intended to work together to bring benefits to the Boston Metropolitan Region as a whole. With that balance in mind, we are grateful to the individuals and institutions who participated in this public comment process and who participate in the development of all transportation projects. This document follows the general format of the Status Report submitted on July 1, 2008, which is also included in this binder. Executive Office of Transportation January 6, 2009 Page 2
I. GREENBUSH COMMUTER RAIL RESTORATION Public Comments ƒ No public comments were received on the Greenbush Commuter Rail restoration. Executive Office of Transportation January 6, 2009 Page 3
II. BLUE LINE PLATFORM LENGTHENING AND STATION MODERNIZATION Public Comments ƒ
[We] object to the assertion in the SIP Status Report that modernization of the Blue Line does not directly relate to air quality and that the deadlines in the SIP should apply only to station lengthening and not station modernization. The SIP clearly requires both Blue Line station platform lengthening and Blue Line station modernization…Since EOT reports that the completion of Blue Line station modernization will be delayed beyond the deadline in the SIP and the ACO [Editor’s Note: Administrative Consent Order], EOT has an obligation to identify and implement mitigation. While Blue Line station modernization is important and the MBTA is aggressively trying to complete the necessary work, station modernization does not, in and of itself, have an impact on air quality. Therefore, no adverse impact on air quality arises from minor delays in the completion of the modernization efforts, nor would mitigation be appropriate. ƒ
EOT is required to provide information about any known funding or other obstacles and measures being taken to address these obstacles. [We] request that this information be provided for all outstanding aspects of [Blue Line platform lengthening and modernization], and in particular that detailed information be provided about the Government Center station including the anticipated completion date and funding sources. The current MBTA Capital Investment Program includes $47.6 million for improvements to Government Center Station. A scope for the effort is currently under development, and no project schedule has yet been finalized. The Government Center project is to make improvements for mobility and accessibility, but will not by itself provide air quality benefits. Executive Office of Transportation January 6, 2009 Page 4
III. FAIRMOUNT LINE IMPROVEMENT PROJECT Public Comments ƒ
The SIP Status Report does not indicate whether EOT is on track to meet the next deadline contained in the SIP for this project. EOT is required to complete final design, apply for all necessary permits and grants, file any required legislation and initiate all land takings by October of 2009. The MBTA is on track to complete all necessary requirements under the SIP for the Fairmount Line Improvement Project by the October 2009 deadline. In particular, project design and real estate due diligence are both proceeding on schedule. Design for the station at Four Corners/Geneva has been completed and the construction contract was put out to bid in December 2008. The MBTA anticipates that design of Newmarket Station will be completed in the second quarter of 2009, with design to be completed for the Talbot and Blue Hill/Cummins Highway stations in the third quarter of 2009. Design for the Talbot/Woodrow/Neponset River bridges is also slated for completion in the third quarter of 2009. ƒ
The SIP Status Report also fails to provide information about ‘measures to improve service and increase ridership’ on the Fairmount Line. EOT believes that the infrastructure improvements currently underway on the Fairmount Line will – when fully implemented – improve service and increase ridership, and that therefore the SIP Status Report does provide accurate and appropriate information. Nevertheless, following completion of the current infrastructure improvements, the MBTA may consider adding service frequency – both at peak and non‐peak times – subject to MBTA operating budget constraints. The financial position of the MBTA makes a definitive determination on such additional frequency impossible at this time. Executive Office of Transportation January 6, 2009 Page 5
IV. CONSTRUCTION OF 1,000 NEW PARKING SPACES Public Comments ƒ
Parking facilities should be included in any report that EOT presents in the SIP and how EOT is going to require access for the disability community, as well as, the planning of those accommodations with specific timetables. The SIP Status Report requires that EOT report on the progress of the construction of the 1,000 new commuter‐oriented parking spaces required by the SIP. As with all existing parking facilities owned and operated by the MBTA, the 1,000 new parking spaces – the construction of all of which is still in the planning stages ‐ will be designed to meet all necessary access requirements. Executive Office of Transportation January 6, 2009 Page 6
V. RED LINE/BLUE LINE CONNECTOR ‐ DESIGN Public Comments ƒ
We request that EOT provide an anticipated schedule for the remainder of this project to demonstrate how they intend to meet the 2011 deadline for completion of final design. EOT has recently initiated the development of a Draft Environmental Impact Report for the Red Line/Blue Line Connector project, and is currently anticipating the following project schedule: ƒ
Alternatives Refinement/Conceptual Engineering – Completed by September 2009 ƒ
Alternatives Analysis – Completed by December 2009 ƒ
Draft Environmental Impact Report – Submitted by April 2010 ƒ
Preliminary Engineering – Completed by September 2010 ƒ
Final Engineering – Completed by December 2011 Large infrastructure planning projects are subject to unanticipated vagaries, but EOT believes this schedule to be realistic and we will work diligently to achieve it. ƒ
It is already clear that the SIP Implementation Process is behind schedule, that DEP needs to focus now on how to mitigate that slippage, that the approach should be broad, recognizing that transportation models understate the severity of the problem because they fail to capture the negative dynamic impact of delay in transit improvement on auto ownership, land use, and transit ridership…That mitigation for delay should include construction of the Red‐Blue Connector. While EOT has admittedly missed some of the internal milestones set for the SIP planning processes, we believe that we will still be able to meet the deadlines defined in the SIP and therefore reject the assertion that mitigation measures should be adopted now. EOT is working diligently to meet all of the deadlines established by the SIP – given the uncertainties inherent in planning complex transportation projects – and will continue to do so. Should a SIP deadline prove impossible to meet, EOT will collaborate with DEP and as part of a public process to develop mitigation measures appropriate to the particular situation. ƒ
We are proposing that, if you find it likely, now or in the future, that the SIP commitments will not meet their timetables, you should then reinstate the construction, and not mere design, of the Red‐Blue Connector, as a SIP commitment. Should mitigation become necessary, EOT will work with DEP through the public participation process defined in the SIP to agree upon mitigation measures that further the regional air quality and mobility goals of both agencies. At this juncture, there is no way to know whether construction of the Red Line/Blue Line Connector would meet those aims. ƒ
Environmental commitments ought to mean something. DEP required the Red‐Blue connector in 1991, both in the SIP and the Vent Shaft permit, because the Big Dig was a highway project that would generate traffic and air pollution. This was to be offset by transit commitments. If our public and private actors are not expected to honor their ‘commitments,’ then the actions taken in reliance on those commitments will not achieve their real benefits, and the public suffers. EOT, and the Commonwealth as a whole, takes its commitments seriously and in good faith. At the same time, circumstances can change, project ideas that seem valuable at one time may be replaced by other project ideas that better meet contemporary needs, and conditions outside the control of EOT can influence whether a project remains viable and sensible. Given fiscal realities, Executive Office of Transportation January 6, 2009 Page 7
no state can take on all worthwhile infrastructure projects at the same time, and choices need to be made about which projects offer the best balance of public benefits and public costs. For all of these reasons, EOT feels that the current portfolio of SIP projects – including final design of the Red Line/Blue Line Connector, but without a commitment to construction – is a good one that will meet established air quality and mobility goals while also recognizing the other infrastructure responsibilities of the Commonwealth. ƒ
Since the original SIP commitments, congestion has increased on the central subway, particularly on the Red and Green Lines. The Red Line/Blue Line Connector is the only project that addresses over‐crowding on the central subway system. While the proposed Red Line/Blue Line Connector could assist in diverting some passengers from the central MBTA subway system, we believe that other existing MBTA services – including the Silver Line and many of the bus routes – can adequately serve that purpose without incurring the costs that would be associated with the Red Line/Blue Line Connector project. Furthermore, while relieving pressure on the central subway is a worthy goal, it is not now and never has been a goal defined in the SIP regulations. Executive Office of Transportation January 6, 2009 Page 8
VI. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD Public Comments ƒ
[We] request additional information to verify that the project will be completed on schedule and will result in emission reductions at or surpassing levels guaranteed through the SIP. EOT is working to advance the Green Line Extension project through both the state and federal environmental review processes at a pace that is simultaneously expeditious and recognizes the complexity of the undertaking. We anticipate that we will submit a Draft Environmental Impact Report/Environmental Assessment early in 2009; once that submission is behind us, we will be able to more accurately develop a schedule for the next phases of the project. Also, it is important to note that the air quality commitments in the SIP are neither corridor‐ nor project‐
specific. Rather, the commitments are and have always been to regional improvements based on a portfolio of projects. Benefits should be analyzed based on the portfolio as a whole, and not based on the performance of individual projects or individual segments of individual projects. ƒ
[We] are concerned about the impacts of the delay in relocation of the Lechmere Station and request that EOT provide an update to the Department of Environmental Protection and the public about the impact of this delay on the overall project schedule. EOT shares the concern about the delay in the relocation of Lechmere Station – originally intended to be done as part of the as‐yet uncompleted NorthPoint development – and has for that reason taken steps to include the design of the relocated Lechmere Station in the environmental review process currently underway for the Green Line Extension. This change will allow the relocation of the station to be incorporated into the overall progression of the Green Line Extension project. Nevertheless, this remains an important critical path component of the Green Line Extension project, and one with significant uncertainty surrounding it. EOT will continue to monitor the situation and will notify DEP and the general public if the relocation of Lechmere Station threatens to jeopardize the Green Line Extension project schedule as a whole. ƒ
[We] are concerned that analysis of air quality benefits be provided so that appropriate siting, service frequency, and, if necessary, mitigation, decisions can be made. EOT believes that the Green Line Extension project will offer significant air quality benefits both locally and regionally. Nevertheless, EOT does not believe that air quality should be the sole determinant of the final preferred alternative for the Green Line Extension, as many other factors are of importance to the overall viability and success of the project. Also, and as stated above, the air quality commitments in the SIP are neither corridor‐ nor project‐specific; they are commitments to regional improvements based on a portfolio of projects, not on the performance of individual projects or individual segments of individual projects. Analysis of the air quality impacts of the four alternatives currently under consideration for the Green Line Extension project have been presented to the Green Line Extension Project Advisory Group and are available at: https://www.commentmgr.com/projects/1228/docs/Air_Quality_120108.pdf. In addition, the air quality analysis will be documented in greater detail in the Draft Environmental Impact Report for the Green Line Extension. ƒ
At many [Green Line Extension Project Advisory Group] meetings it was encouraged and self‐evident that non disabled persons who are friendly to EOT got special treatment. Executive Office of Transportation January 6, 2009 Page 9
EOT rejects this assertion as untrue and demeaning to the public involvement effort undertaken by EOT and supported in good faith by many participating individuals and institutions, including the Access Advisory Committee to the MBTA. ƒ
ƒ
ƒ
ƒ
Why does EOT set up [Green Line Extension project] meetings in locations without disability access? For all of its public meetings, EOT always uses buildings with adequate disability access, and has adhered to this policy for all public meetings associated with the Green Line Extension project. The only possible exception to this would be a tour of the Green Line maintenance facility at Riverside – offered to Green Line Extension Project Advisory Group members on July 31, 2008 – in which some areas might have been inaccessible. EOT notified participants of this possibility well in advance of the tour. Though EOT is allowed to meet with community groups [as part of the Green Line Extension project process], the question is should they be allowed to meet with community groups that do not have disability or environmental justice membership and then have that group speak for those environmental justice or disability communities? EOT meets with any organization that asks for a meeting and will speak with the members of that organization or any other attendees on any pertinent topic. We believe that all viewpoints have validity and should be heard. If you discriminate against these populations, is the Green Line extension a legitimate project with legitimate goals set by the federal and state government of helping the disability community and the EJ [Editor’s Note: Environmental Justice] populations? EOT rejects the notion that it discriminates against any population in its planning for the Green Line Extension project – or any of its projects – and believes, based on its transportation modeling and other analysis, that the Green Line Extension project offers the promise of significant mobility improvements for disability and Environmental Justice populations. On October 25th of 2007, [we] submitted to EOT [an] alternative study proposal to ask that a study be conducted to enhance the proposed Green Line project by taking it underground through tunnel boring from Ball Square, Somerville to Clarendon Hill, Somerville and then taking the Urban Ring concept as supported by MPO and connecting the proposed Green Line to the existing Red Line either at Alewife Brook Parkway or back to Davis Square…After promises of responding to this enhanced study on its agenda, EOT finally responded on June 2, 2008 turning down this proposed enhancement because it did not meet the SIP destinations… We again ask that EOT include in its environmental studies and cost analysis the comparison of doing tunneling boring in Medford versus overland implementation of the proposed Green Line. On December 1, 2008, EOT released a thorough study of the proposed tunneling options for the Green Line Extension project, including the one described in this comment. The report determined that tunneling would not be a viable alternative for this project, nor would the alignment proposed in this comment meet the requirements of the SIP. For these reasons and others, EOT will not be pursuing tunneling as the Green Line Extension project progresses. The tunneling report can be found at: https://www.commentmgr.com/projects/1228/docs/Draft%20Document‐
TunnelAlts_11252008%20for%20posting.pdf Executive Office of Transportation January 6, 2009 Page 10
ƒ
A Green Line Extension terminus at College Avenue would not serve the majority of Medford Hillside, which is a densely populated area with a lot of residents who do not own cars and who could benefit enormously from frequent light rail transit service. EOT is attempting to develop an overall Green Line Extension project that can, in totality, be successfully implemented and effectively serve all of the potential riders within the full project corridor. Within that framework, we believe that College Avenue is not only a reasonable location for a station – technically feasible, well‐spaced within the corridor, at an established transportation node, within walking distance of several residential neighborhoods, requiring no property acquisition, and with other impacts that can be mitigated – but one that will encourage greater ridership over time. College Avenue is a good location for a station, and allows us to meet the spirit and intention of the SIP commitment. ƒ
ƒ
ƒ
There should be a much more public and thorough accounting of why there is no longer study of a station at Winthrop Street and why a handful of abutters at Brookings Street could not have been given sufficient mitigation to make a combined station a viable alternative. Large numbers of residents of Medford Hillside will not be served if there are no stations between College Avenue and Route 16, and many generations to come will forfeit the benefit of this type of public transportation. Based on the feedback that the Green Line Extension project team received during the period in which we were considering the options for future Medford stations, we concluded that a Winthrop Street station would be unacceptable to a critical mass of both residents and local officials. This opposition, combined with certain technical advantages of a College Avenue station (see the above response), led to the decision that College Avenue would be a more favorable location for a Green Line stop. Discussion of a Mystic Valley Parkway/Route 16 station has devolved so that this proposed station seems doomed to fail. The station now seems burdened with encumbrances that are not being contemplated for other stations along the Extension: a much longer platform, a requirement for 5 tracks, an “Alewife‐style” parking facility, and expected taking of a large amount of commercial real estate at and around 200 and 222 Boston Avenue. EOT strongly objects to the assertion that the planning for a potential Green Line station at Mystic Valley Parkway/Route 16 has been managed in such a way that the station is ‘doomed to fail.’ The Green Line Extension project team has performed a thorough and professional analysis of the costs and benefits of constructing a station at Mystic Valley Parkway/Route 16, including an analysis of infrastructure that would be needed to operate a successful terminal station at that location. Any potential property acquisition that could be required there is simply a function of the geometry of the area. EOT has been consistent in its position that the Green Line Extension project minimize real‐estate acquisition; therefore, EOT has no interest in inflating the estimated property needs for any particular proposed station. The analysis of a parking garage has been done as a component of an overall analysis of the optimal characteristics – those that generate the greatest ridership – of a terminal station, and should be understood in that context and not as a subterranean effort to turn public opinion against a possible station at Mystic Valley Parkway/Route 16. For the record, EOT has never contemplated the construction of an ‘Alewife‐
style’ parking facility at a possible Mystic Valley Parkway/Route 16 station. This phraseology is continuously and incorrectly applied to the intentions of the Green Line Extension project team. EOT is perhaps painfully aware that many Medford citizens are extremely anxious about the subject of land‐takings, the ramifications of moving the commuter rail closer to many homes, and possible Executive Office of Transportation January 6, 2009 Page 11
exacerbation of an already difficult traffic and parking environment. The lack of concrete answers along with many unexplained twists and turns in the process have caused some to believe that this project is being decided with backroom dealing rather than a process the public has any access to or effect upon. I sincerely hope that is not true and hope EOT will proceed in a more open, deliberative manner that will restore public confidence that legitimate questions will be answered and legitimate needs are being taking into account in planning the best possible project for us and for future generations. EOT is acutely aware of the public anxiety that can be caused by the uncertainties of the planning process, particularly around the issue of property acquisition. We have tried as much as possible to strike an appropriate balance between releasing any information we believe to be pertinent and not speculating inappropriately on subjects for which we do not yet have complete answers. The transportation planning process is lengthy and often encounters unexpected situations, and we have believed it to be irresponsible to provide information on subjects – like land acquisition in particular – before it is finalized. Nevertheless, public input has been and will continue to be of great influence and importance in this project, and we will endeavor always to be as transparent as possible in our decisionmaking. ƒ
ƒ
ƒ
Somerville is an environmental justice community that has been overburdened with regional transportation infrastructure. It is unacceptable to ask our city to house yet another regional transportation infrastructure facility without making concessions to the economic development needs of the city that can only be met if the city retains the opportunity to develop the Inner Belt. The siting and construction of a northside Green Line support facility – for the maintenance and storage of Green Line vehicles – is integral to the overall Green Line Extension project, a project that itself offers significant transportation benefits for Environmental Justice populations within Somerville and Medford. Without such a facility, the Green Line Extension will not be possible. There are few locations within the Green Line Extension corridor that could possibly be appropriate for such a facility, and only one – the so‐called ‘Yard 8’ parcel – that is really viable (for more information on the support facility analysis, see: https://www.commentmgr.com/projects/1228/docs/final_maintenance_facility_aa_110608_highqu
alityprint11d7783afb9.pdf). EOT appreciates that Yard 8 is located within an area that the City of Somerville has identified as a possible site for future growth, and EOT has committed publicly to working with Somerville to develop an overall design for the support facility that not only does not preclude other development in the immediate neighborhood but could actually enhance the area over the long‐
term. There is community‐wide support in Medford and Somerville for terminating the Green Line branch through Medford at Route 16 that has been documented by the petition prepared by the Medford Green Line Neighborhood Alliance. EOT is aware of the public support along the project corridor for terminating the Green Line Extension at Mystic Valley Parkway/Route 16. We also appreciate that there is public concern and opposition to a possible Mystic Valley Parkway/Route 16 terminus. We feel that we must weigh not only public support and opposition but also all of the technical merits and challenges to such a station, a process in which we are currently engaged. As a member of the Community Advisory Committee I have found the Green Line Project Management easily accessible and well intentioned when I have had questions about the project. However, overall it is my belief and that of other interested community residents who have spoken with me about their concerns that the community process that was announced by EOT at the beginning of the environmental review has Executive Office of Transportation January 6, 2009 Page 12
been less than satisfactory. At this point I am very discouraged that the concerns voiced by residents are not being treated as substantive. I can assure both DEP and EOT that we want the Green Line extensions to be designed and built to optimally meet current and future transportation needs. EOT regrets if any member of the Green Line Extension Project Advisory Group – or any member of the general public – feels that efforts at public outreach and inclusion have not been fully satisfactory. We take pride in our efforts to reach a broad audience and to hold public meetings and other events (more than 30 for the Green Line Extension project) that provide opportunities for the public to communicate with EOT and for the project team to better understand the needs and wishes of the future users of the Green Line Extension. We have endeavored, throughout the planning process, to strike an appropriate balance between our desire to incorporate the opinions and preferences of individuals and the need to weigh objective planning criteria and overall project goals. We also understand that we will never been able to satisfy all members of the public and the Project Advisory Group on all relevant matters, which we do not believe means that our outreach has been subpar. ƒ
ƒ
ƒ
It’s not surprising, and I do not blame EOT for being primarily transportation planners. But many will, I’m afraid, blame EOT if land use planning is neglected, and the Green Line extension in important ways fails to realize its magnificent potential. Although its progress has been driven by air quality regulations, its transportation and economic development benefits can multiply its value exponentially. EOT agrees that the Green Line Extension project is a project with the potential to spur economic growth along the project corridor. By providing better access and mobility both within and to multiple commercial districts, the Green Line Extension offers the promise of expanded economic opportunity for Somerville and Medford. At the same time, EOT is sensitive to the fact that land use planning is both the responsibility and the prerogative of municipal governments. Accordingly, we have and will continue to work with both Somerville and Medford to endeavor as much as possible to integrate the Green Line Extension with ongoing local planning and development efforts. Keep the focus on ‘smart growth.’ See how the transit investment can be designed to attract the most ridership, and provide the best connectivity among workers, universities, and present and future businesses. Such an analysis would value urban land appropriately; and remain sensitive to proximities, access, making connections. EOT feels that one of the many core strengths of the Green Line Extension project is the existing density and land use patterns of the project corridor. East Cambridge, Somerville, and Medford are all areas that are – simply by virtue of their historical development patterns – well‐suited to public transit: the neighborhoods and retail districts are all walkable; many of the households own one or no automobiles; and many residents are accustomed to using the bus or other modes of public transit. Unlike transit projects in exurban areas, in which concerted thought must be given to developing station sites and transportation hubs that can support public transit usage, the Green Line Extension corridor is naturally predisposed to strong transit ridership. We agree that we must do all that we can to create integrated connections between the Green Line Extension and the surrounding communities, and feel confident that the Green Line Extension will strengthen existing land use patterns that so support public‐transit usage. On the sensitive question of siting maintenance and storage facilities, we need a more open process, which takes an outcome‐neutral look at present and future operational needs of the whole transit system, at the distribution of burden associated with current facilities, as well as economic development benefits of other land use options in the urban core. Executive Office of Transportation January 6, 2009 Page 13
EOT appreciates that the question of where to locate a support facility for the Green Line Extension is controversial. We have been consistent since the beginning of the current planning process in recommending the Yard 8 site as the only viable location for a support facility for the Extension. At the same time, we have objectively analyzed more than a dozen possible locations, and have always been open to any viable enhancements to our proposal (for more information on the support facility analysis, see: https://www.commentmgr.com/projects/1228/docs/final_maintenance_facility_aa_110608_highqu
alityprint11d7783afb9.pdf). We understand that the MBTA faces larger system‐wide issues related to insufficient maintenance and storage capacity, and EOT will continue to work with the MBTA to try to address those needs over the long term. We feel strongly, however, that the Green Line Extension project cannot go forward without the construction of a proximate support facility, and we are concerned that delays associated with locating the support facility could jeopardize the schedule for the Green Line Extension project as a whole. We will continue to coordinate with the City of Somerville and do all that we can – within the parameters and constraints of the project – to site and design a facility that will also meet the long‐term growth goals of the City for the Inner Belt district. ƒ
ƒ
ƒ
ƒ
If, as I fear, your current plans for a Mystic Valley Parkway stationed are imperiled due to expense, I urge you to undertake whatever redesign is necessary to render that station viable. Whether you do that or not, if you intend to satisfy your mandate to extend the Green Line to Medford Hillside, you must take it as far as Winthrop Street. The SIP does not require that the Green Line Extension serve the full extent of what residents may consider to be the Medford Hillside neighborhood; rather the Green Line is required to be extended to Medford Hillside, and College Avenue is commonly considered to be within the boundaries of the Medford Hillside neighborhood. Therefore, we believe that terminating the Green Line Extension at College Avenue would meet the minimum requirements of the SIP. All of that being said, EOT has not yet made a final decision on the terminus of the Green Line Extension. The SIP requires that the Green Line extension serve “Medford Hillside.” A station at College Avenue/Boston Avenue, which is being considered as a terminus for the extension, would sit at the extreme southern boundary of “Medford Hillside” and would be nearly a mile away from portions of what is considered the “Medford Hillside” neighborhood. EOT understands and appreciates that some segments of the Medford Hillside community believe that a Green Line station at College Avenue wouldn’t fully serve the Medford Hillside neighborhood. Nevertheless, we believe that terminating the Green Line Extension at College Avenue – a decision in no way finalized – would meet the requirements of the SIP. The DEIR RFR requires EOT to study the viability and potential impacts of including a community path in the Medford sections of the project area. However, the Annual Report only makes reference to community path connections at the stations proposed in Somerville. The Draft Environmental Impact Report for the Green Line Extension project will address the feasibility of providing a community path in the Medford sections of the project. The DEIR RFR requires EOT to study potential connections between the Lowell commuter rail line and the Green Line either at Tuft University (presumably the College Avenue station) or at Gilman Square. The descriptions of the stations currently proposed make no mention of possible commuter rail connectivity. Executive Office of Transportation January 6, 2009 Page 14
ƒ
ƒ
ƒ
ƒ
The option of constructing a Commuter Rail station to connect with the proposed Green Line Extension was evaluated early in the project. The infrastructure requirements necessary to accommodate a commuter rail station (tracks, platforms, etc.) would have significant impacts on properties in the area. As such, providing a commuter rail station at these locations is not recommended, as will be described in the Draft Environmental Impact Report. This project is required to improve air quality in the corridor by reducing auto emissions by shifting auto person trips to transit. The inclusion of a large structured parking facility at the Route 16 terminus station would contradict this effort and attract more cars to the corridor, not reduce their number. EOT is still in the process of evaluating whether the inclusion of a 300‐space parking facility at a Mystic Valley Parkway/Route 16 terminal station would, on balance, be worthwhile for the Green Line Extension project. The final decision, which has not yet been made, will be based on many factors including cost, ridership, traffic, noise, as well as air quality and the estimated reduction in vehicle miles traveled. It is important to note that SIP‐mandated projects are not required to provide air quality benefits in any given corridor, but rather for the region as a whole. In addition, we believe that the construction of a parking facility at a possible Mystic Valley Parkway/Route 16 station would not in fact attract more cars to the project corridor, but would divert cars at the outskirts of the corridor and thereby prevent them from driving through the corridor on their way to downtown Boston. The Annual Report omits any mention of an important area of concern in the community – mitigation, particularly in terms of the additional noise and vibration that will occur when the commuter rail tracks are moved closer to existing residences. This is an important area that must be specifically addressed in the DEIR both in terms of what mitigation obligations the EOT will undertake, and also in the project cost estimate that is required in the DEIR. EOT is aware of public interest in mitigation, particularly to manage any possible increases in noise and vibration that may result from the construction of the Green Line Extension, and will include a discussion of proposed mitigation solutions in the Draft Environmental Impact Report. However, the Green Line Extension project – like all transportation projects currently underway in Massachusetts – is under strict budgetary restrictions. Any costs for mitigation – which the project will include – must be balanced against public requests for project amenities and other enhancements. At all [Green Line] stations, adequate bus connections are critical to contribute to ridership and ensure that the disabled community can fully access the benefits of the extension. EOT fully agrees that – in order to maximize its benefits for all riding populations – the Green Line Extension must be well‐integrated with the MBTA bus network. Adequate capacity for bus connections was one of the criteria by which EOT evaluated possible Green Line station locations, and more detailed planning for bus pull‐ins will be done as the Green Line Extension project advances through the design and engineering processes. It is very important that sufficient bicycle parking be built into the design of every [Green Line] station. EOT fully agrees that good bicycle access and sufficient bicycle parking will be important for the Green Line Extension stations to function well as neighborhood stations. EOT is and will be working with its project team and with the City of Somerville and the City of Medford to develop estimates for an appropriate amount of bicycle parking at each of the proposed stations. Executive Office of Transportation January 6, 2009 Page 15
ƒ
ƒ
ƒ
ƒ
ƒ
With the potential exception of the Mystic Valley Parkway/Route 16 station, parking for riders is not appropriate in Somerville and should not be planned for. EOT has been consistent in its position that the design for the Green Line Extension stations – with the possible exception of a Mystic Valley Parkway/Route 16 station – should not include parking. The stations are intended to be primarily walk‐up and bicycle‐up stations, with the bulk of the riders expected to come from the surrounding neighborhoods and business districts. At the same time, we feel that several of the proposed stations may be appropriate for short‐term pick‐up/drop‐off areas – often known as ‘kiss‐and‐ride’ areas – and we believe that we should prudently provide such spaces to offer riders a safe area to exit or enter a waiting vehicle. Past experience indicates that even those public transit stations that are designed to be primarily for walking and bicycling are still occasionally used by motorists who wish to drop off or pick up transit riders, and the failure to provide safe spaces for cars leads to hazardous stopping and double‐parking. [The Mystic Valley Parkway station] will serve as a gateway to the recreational opportunities along the Mystic River and we recommend that space be set aside for an interpretive center that would include historic information and a map of paths, etc. EOT and the MBTA are not the appropriate agencies to design, construct, or manage an interpretive center. Should the communities of Somerville and Medford – perhaps in concert with local advocacy organizations – which to undertake the design, construction, and management of an interpretive center, EOT will be happy to try to facilitate that effort. Under full development scenarios, two stations are needed in the Inner Belt and Brickbottom areas therefore, planning for the Green Line Extension needs to include two stations even if one is not built until a later date when demand increases. EOT has been consistent in its position that the Inner Belt and Brickbottom areas will be well served by a single Green Line station. Additional stations are not only not warranted by the ridership projections for the area – based on current demographics and officially permitted projects – but would also require suboptimal spacing and inefficient transit operations. For all of these reasons, EOT will not recommend that a second station be included in the Inner Belt and Brickbottom areas. We believe that, as a matter of environmental justice, the City of Somerville should absorb only those functions and facilities related to the extension – and that under no circumstances should Somerville be further burdened by regional‐serving infrastructure that does not serve its residents and business community. The vehicles proposed to be stored at the Green Line Extension support facility are intended to service the Green Line northside service. While I recognize that the entire Green Line Extension project must meet transportation and engineering objectives, it is not in the Commonwealth’s best interest to diminish the economic opportunity that would arise were the Inner Belt and Brickbottom Districts developed to their full potential. That potential development, in turn, would actively support the Green Line extension by providing thousands of daily riders. EOT appreciates that the City of Somerville aspires to develop the Inner Belt and Brickbottom areas and believes – as does Somerville – that the implementation of the Green Line Extension is an important component of that development. EOT has been working with the City of Somerville to try to find common ground on the location and design of a support facility and the Executive Office of Transportation January 6, 2009 Page 16
siting of an Inner Belt/Brickbottom station, and hopes that the good collaboration that has so far taken place will continue as the project advances in the design and engineering process. ƒ
ƒ
ƒ
ƒ
The Department of Conservation and Recreation should do the roadway work at North Point. The MBTA should take the land at North Point, clear the title to the land, and resell it. EOT believes that its current approach (described above) to relocating Lechmere Station and making some ancillary roadway improvements will effectively serve the needs of both the East Cambridge community and the Green Line Extension project. There is a troubling aspect of the public meeting process. Members of the Green Line Extension Project Advisory Group were told that they would receive a report regarding the location of a proposed support facility, but that report has not yet been distributed. The members of the Group do not have a lot of time to review materials in advance and then to discuss the issues at meetings in a meaningful way. EOT regrets that materials are not always available for Project Advisory Group members as far in advance of meetings as would be optimal, but we endeavor to release materials in such a way that they can be discussed after an appropriate amount of time. The report regarding the Green Line Extension support facility was released on November 7, 2008 and is available at: https://www.commentmgr.com/projects/1228/docs/final_maintenance_facility_aa_110608_highqu
alityprint11d7783afb9.pdf. Consideration should be given to an intermediate station on the Union Square spur. An extension to the Red Line should not be precluded in the long run. Ridership demand does not warrant a second station on the Union Square Branch. One of the possible alignments for the Union Square branch – the alignment that travels solely within the MBTA’s Fitchburg Commuter Rail Line – does not preclude a possible future extension to the Red Line in Porter Square. The MEPA scope includes the alternative to come up the McGrath‐O’Brien Highway, but this alternative is not being looked at. An explanation is needed. The potential of using McGrath‐O’Brien Highway for the Union Square Branch of the Green Line Extension was evaluated early in the project process. Meetings were conducted with the owners of this segment of roadway, the Department of Conservation and Recreation. DCR currently has plans to perform only in‐kind structural upgrades to the existing roadway structures. As such, taking on the major reconstruction of the highway that would be required to accommodate a Union Square branch would prove cost‐prohibitive. Executive Office of Transportation January 6, 2009 Page 17
VII. OTHER PROJECTS AND POLICIES EOT received public comment on projects not required to be covered in State Implementation Plan ‐ Transit Commitment Status Report. Those comments and attendant responses are listed below. ƒ Recognition should also be given to community paths regarding the disability issue. There is no SIP project that includes the construction of a community or other type of path. Therefore, EOT does not report on any policies relating to paths in the SIP Status Reports. Nonetheless, all public infrastructure projects are required to comply with accessibility regulations. ƒ
The question on the SIP report should be how do we encourage more groups that the government claims it wants to help and how do we report on the effectiveness of those efforts and how these groups become more an active part of the planning process within a safe environment? The question is what is EOT doing to accomplish that? The commitments articulated in the SIP are primarily about the design and construction of certain transportation projects, not about public outreach and inclusion. That being said, EOT endeavors always to include substantive and meaningful public outreach as part of its initiatives and the SIP projects are no different. EOT generally adopts a broad‐based approach to public outreach, advertising public meetings and other opportunities for public involvement through traditional media, direct mailings, the internet, and other means. Where possible and appropriate, we do targeted outreach to certain demographic groups from whom we wish to solicit additional or particular input. EOT is committed to fostering an environment of objective inclusion at all of our public meetings and other events, in which all voices and opinions are equally valid and are given equal time to speak and be heard. We believe that all ideas – even dissenting ones or ones hostile to the policy positions of EOT – deserve to be expressed, and we always strive to conduct conversations in an atmosphere of tolerance and civility. ƒ
Orange Line Signal Improvements and Additional Coaches: [The Status Report] should identify which year CIP [Editor’s Note: MBTA Capital Improvement Program] will include funds for third rail upgrades, which CIP will include funds for Wellington Yard special track work, which CIP will include funds for vehicle improvements. Some estimate should be made for the cost of each of these items and how much will be programmed into each CIP to be able to fully complete the project by 2015. Not only should the funds be fully programmed but benchmarks should be outlined for each item. The current version of the CIP includes funding for the major components of the Orange Line Vehicle Project. Specifically, $80 million has been programmed for new vehicles and another $43.25 million has been programmed for Orange Line infrastructure improvements. These improvements include major upgrades for power and power substations. At this point, the smaller elements of the Orange Line program, such as the Wellington Carhouse improvements and the third rail upgrades – both of which will occur towards the end of the 2015 horizon – have not yet been programmed into the CIP. The MBTA is cognizant of the need to program these funds and will work over the next two years, as new CIPs are developed, to secure funding for them. ƒ
Urban Ring Draft documents: EOT has not supplied the CAC with all of the draft documents for the Urban Ring DEIR/DEIS as of September 9, 2008. In particular we have not received the chapters on traffic nor the chapter on finance. The Revised Draft Environmental Impact Report/Draft Environmental Impact Statement for the Urban Ring project is available at: Executive Office of Transportation January 6, 2009 Page 18
http://www.theurbanring.com/currentmaterials.asp?area=gen ƒ
ƒ
ƒ
ƒ
ƒ
Signal Prioritization: The MBTA should provide a written record of its requests for signal prioritization at which intersections including mode of each request and the city’s response to each request and any followup. This issue is outside the SIP regulatory framework and involves neither EOT nor DEP. Questions on signal prioritization should be directed to the MBTA. Environmental, public health, and transportation agencies should fund work to study the impact of emissions on people near emission sources. EOT appreciates the growing public interest in determining the extent to which point‐source air pollution can contribute to illnesses such as asthma, respiratory disease, and cancer. EOT and the MBTA are committed to pursuing the use of fuels and vehicles that reduce emissions, and work closely with DEP to develop a portfolio of transportation projects that can positively influence air quality. In addition, EOT has, in recent years, made preliminary moves toward greater collaboration with the Department of Public Health on issues such as asthma reduction and healthy transportation for schoolchildren. Environmental impacts should be addressed in the SIP report. The content of the SIP Status Reports is determined by 310 CMR 7.36(7)(a). My public comments concern the lack of the disability access issue throughout the SIP status report…The report should have an update with timetables regarding the disability court settlement from the date it was started and the current timetable of completion of work to meet ADA requirements regarding any and all transit projects. The content of the SIP Annual Reports is determined by 310 CMR 7.36(7)(a). In addition, the settlement to which the question refers is a responsibility of the MBTA and – while EOT supports the MBTA in its efforts to meet the requirements of the settlement – it is the purview of the MBTA to report on its progress. How can the Commonwealth of Massachusetts spend millions of dollars on expanded projects such as the proposed Green Line project when people with disabilities still do not have the ability to get off at stations such as Symphony Hall, Boylston Street and other popular station sites on the Green Line due to lack of ADA accessibility? The challenge of making the Green Line fully accessible is real, and one that the MBTA has slowly been addressing for decades. Arlington and Copley Stations – two of the oldest stations in the MBTA system – are currently being renovated to include elevators and are expected to reopen within a few years. While EOT regrets that not all public transit facilities can be made fully accessible immediately, we believe that the inadequacy of access at some stations should not prohibit the construction of a new – and fully accessible – component of the Green Line system that will improve transportation for riders of all degrees of personal mobility. Executive Office of Transportation January 6, 2009 Page 19