Medford
Everett
Chelsea
Somerville
Circumferential Transportation Improvements in the Urban Ring Corridor Cambridge
Boston
Urban Ring Phase 2 Brookline
NOTICE OF PROJECT CHANGE EEA #12565
June 2009
TABLE OF CONTENTS TABLE OF CONTENTS URBAN RING PHASE 2 RDEIR NOTICE OF PROJECT CHANGE
NOTICE OF PROJECT CHANGE FORM AND ATTACHEMENTS
Notice of Project Change Form Attachment 1: Secretary’s Most Recent Certificate on the RDEIR ............................................... 1 Attachment 2: Plan showing Most Recent Previously-Reviewed Proposed Build Condition........ 3 Attachment 3: Plan Showing Currently Proposed Build Condition ............................................... 5 Attachment 4: Original U.S.G.S Map or Good Quality Color Copy Indicating the Project Location and Boundaries ..................................................................................................... 7 Attachment 5: List of All Agencies and Persons to Whom the Proponent Circulated the NPC, in Accordance with 301 CMR 11.10(7)...................................................................... 9
5.1
Federal Agencies and Federal Elected Officials........................................ 9 5.2
State Agencies and Elected Officials....................................................... 10 5.3
Other Agencies/Authorities ...................................................................... 13
5.4
Local Agencies/Municipalities.................................................................. 13
5.5
Urban Ring CAC Members ...................................................................... 15 5.6
Institutions................................................................................................ 16
5.7
Other Organizations and Individuals........................................................ 17 Attachment 6: Project Change Description – Supporting Details ............................................... 19 6.1
Alignment Changes to the Locally Preferred Alternative ......................... 19 6.2
Implementation Plan ................................................................................ 20
6.3
Special Review Procedure....................................................................... 30 6.4
Response to Comments on RDEIR ......................................................... 35 Urban Ring Phase 2 RDEIR Notice of Project Change
Page i June 2009
Commonwealth of Massachusetts
Executive Office of Environmental Affairs g MEPA Office
For Office Use Only
Executive Office of Environmental Affairs
MEPA Analyst:
NPC
Phone: 617-626-
Notice of Project Change
The information requested on this form must be completed to begin MEPA Review of a NPC in
accordance with the provisions of the Massachusetts Environmental Policy Act and its
implementing regulations (see 301 CMR 11.10(1)).
Project Name: Circumferential Transportation Improvements in
the Urban Ring Corridor – Phase 2
Street: N/A
Municipalities: Boston, Brookline, Cambridge,
Chelsea, Everett, Medford, and Somerville
EEA #:12565
Watersheds: Charles, Boston Harbor
(Mystic), and North Coastal
Universal Tranverse Mercator Coordinates: N/A Latitude: N/A
Longitude: N/A
Status of project construction: 0% construction.
Proponent: Executive Office of Transportation
Street:
10 Park Plaza
Municipality: Boston
State: MA
Zip Code: 02116
Name of Contact Person From Whom Copies of this NPC May Be Obtained:
Rebecca Arsenault
Firm/Agency: AECOM Technical Services, Inc. Street: 300 Baker Avenue
Municipality: Concord
State: MA
Zip Code: 01742
Phone: 978-371-4141
Fax: 978-371-2468
E-mail:
Rebecca.arsenault@aecom.com
In 25 words or less, what is the project change?
Short term action plan and long range phasing and implementation schedule, with
responses to comments on RDEIR in accordance with March 6, 2009 Certificate.
See full project change description beginning on page 3.
Date of ENF filing or publication in the Environmental Monitor: August 8, 2001
Was an EIR required? X Yes
No; if yes, was a Draft EIR filed? X Yes Date: DEIR December 8, 2004; RDEIR December 10, 2008 was a Final EIR filed? Yes (Date:
) X No was a Single EIR filed? Yes (Date:
) X No
Have other NPCs been filed? X Yes Date(s): 8/31/05; 6/11/07; and 4/23/08.
If this is a NPC solely for lapse of time (see 301 CMR 11.10(2)) proceed directly to
“ATTACHMENTS & SIGNATURES” on page 4.
PERMITS / FINANCIAL ASSISTANCE / LAND TRANSFER
List or describe all new or modified state permits, financial assistance, or land transfers not
previously reviewed: The Commonwealth of Massachusetts has an agreement with CSX that
establishes the general terms under which EOT will purchase certain property interests of CSX,
including some of the rights of way needed for implementation of Urban Ring Phase 2 as
identified in the project RDEIR filing.
Are you requesting a finding that this project change is insignificant? (see 301 CMR 11.10(6))
Yes X No; if yes, attach justification.
Are you requesting that a Scope in a previously issued Certificate be rescinded?
Yes X No; if yes, attach the Certificate
Are you requesting a change to a Scope in a previously issued Certificate?
yes, attach Certificate and describe the change you are requesting:
Summary of Project Size
& Environmental Impacts
Total site acreage
Acres of land altered
Acres of impervious area
Square feet of bordering vegetated
wetlands alteration
Square feet of other wetland alteration
Acres of non-water dependent use of
tidelands or waterways
Previously
reviewed
Yes
Net Change
X No; if
Currently
Proposed
LAND
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
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N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
STRUCTURES
Gross square footage
N/A
Number of housing units
N/A
Maximum height (in feet)
N/A
TRANSPORTATION
Vehicle trips per day
N/A
Parking spaces
N/A
WATER/WASTEWATER
Gallons/day (GPD) of water use
N/A
GPD water withdrawal
N/A
GPD wastewater generation/ treatment
N/A
Length of water/sewer mains (in miles)
N/A
Does the project change involve any new or modified:
1. conversion of public parkland or other Article 97 public natural resources to any purpose
not in accordance with Article 97?
Yes X No
2. release of any conservation restriction, preservation restriction, agricultural
preservation restriction, or watershed preservation restriction?
Yes X No
3. impacts on Estimated Habitat of Rare Species, Vernal Pools, Priority Sites of Rare
Species, or Exemplary Natural Communities?
Yes X No
4. impact on any structure, site or district listed in the State Register of Historic Place or
the inventory of Historic and Archaeological Assets of the Commonwealth?
Yes X No; if yes, does the project involve any demolition or destruction of any listed or
inventoried historic or archaeological resources?
Yes
X No
5. impact upon an Area of Critical Environmental Concern?
Yes X No
If you answered ‘Yes’ to any of these 5 questions, explain below:
PROJECT CHANGE DESCRIPTION (attach additional pages as necessary). The project change
description should include:
(a) a brief description of the project as most recently reviewed
(b) a description of material changes to the project as previously reviewed,
(c) the significance of the proposed changes, with specific reference to the factors listed
301 CMR 11.10(6), and
(d) measures that the project is taking to avoid damage to the environment or to minimize
and mitigate unavoidable environmental impacts. If the change will involve modification of any
previously issued Section 61 Finding, include a proposed modification of the Section 61 Finding (or
it will be required in a Supplemental EIR).
Project Description – This Notice of Project Change is in response to the EOEEA Certificate
dated March 6, 2009 on the RDEIR for the Urban Ring Phase 2 project. The project as most
recently reviewed by EOEEA is the recommended Locally Preferred Alternative (LPA), which is
a proposed circumferential bus rapid transit (BRT) system. BRT is a transit mode that employs
modern bus vehicles within a system of coordinated infrastructure and service enhancements
that enable the buses to operate more like rapid transit service. The Urban Ring Phase 2 would
operate in a roughly circular “ring” through densely developed portions of Boston, Brookline,
Cambridge, Chelsea, Everett, Medford and Somerville. The project would provide faster and
more direct transit service both for the high volume of trips within the Urban Ring corridor, as
well as better connections between points in the corridor and the MBTA’s existing radial rapid
transit and commuter rail systems. As a result, the Urban Ring Phase 2 would improve transit
access and capacity in the corridor, reduce crowding in the central subway system, and support
transit-oriented development and smart growth plans and policies.
Material Changes to the Project as Previously Reviewed – The March 6, 2009 Certificate on
the RDEIR set forth three primary requirements to be addressed in the NPC, as summarized
below.
• Early Action Implementation Plan: to identify near-term actions that EOT can undertake
to improve transit service in the corridor.
• Implementation Plan for the Full Project: to define project phasing and implementation
approach for the full Urban Ring Phase 2 project.
• Comment Responses: to provide thorough responses to the comment letters received
on the RDEIR document.
The early action and full project implementation plans provided in the NPC do not materially
change the project as previously reviewed, but rather provide further details on phasing,
implementation, and schedule than were available in the RDEIR document due to conditions
external to the project that were not yet known at that time.
Significance of Proposed Project Changes pursuant to 301 CMR 11.10(6) – The
proposed project changes are insignificant in consideration of the following factors:
(a) The proposed change will not result in an increase in the physical dimensions of
the overall project by more than 10%.
(b) The proposed change will not result in an increase of any impacts in excess of
25% of any review threshold and will not generate any increase in the release of
emission of pollutants or contaminants during or after completion of the project.
(c) The proposed project change is expected to result in earlier implementation of
some project elements compared to the schedule assumed for the LPA in the
RDEIR. By identifying a minimum operating segment (MOS) and early action
items the NPC implementation schedule will enable project benefits to be
realized sooner.
(d) There is no change in the project site.
(e) The proposed change will not result in any new applications for permits, financial
assistance, or land transfer not already identified in the RDEIR.
(f) The proposed project change will not prevent or delay the realization of net
benefits to environmental quality and resources or public health. The NPC is
expected to expedite the realization of net benefits.
(g) The proposed project change does not involve a lapse of time.
Measures to Avoid, Minimize, and Mitigate Environmental Impacts – The proposed change
consists of identifying potential early actions and full project implementation plans and schedule,
which do not change the environmental impacts of the project or the measures to avoid,
minimize, and mitigate them as identified in the RDEIR.
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 1:
Secretary’s Most Recent Certificate on the
RDEIR
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 1
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 2:
Plan showing Most Recent Previously-Reviewed
Proposed Build Condition
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 2
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Urban Ring Phase 2 RDEIR/DEIS Locally Preferred Alternative
Ev e re tt
Wellington
Downtown
Chelsea
Station
Me df or d
S o m erv i lle
Assembly
Square
Chel sea
Sullivan
Square
Harvard
Square
Ea st
Bo st o n
New
Lechmere
Airport
Ca mbri dg e
Logan
West
Garage
Cambridgeport
Kendall /
MIT
Al ls to n
World
Trade
Center
Yawkey
Broadway
BU Bridge
LMA
Ruggles
Washington
Street
Br o ok lin e
So uth Bo s to n
Newmarket
Dudley
Square
Ro xb ury
JFK/UMass
Do rch es t er
Proposed Alignment
Intermodal Connections
Mixed Traffic
Commuter Rail
Buslane
Silver Line
Busway (Surface)
Blue Line
Busway (Tunnel)
Green Line
Proposed Stop
Area of Ongoing
Analysis
Red Line
Orange Line
Route Options
Base map data provided by MassGIS.
0
0.5
1
Urban Ring Phase 2
RDEIR/ DEIS
Locally Preferred Alternative
Miles
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 3 June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 3:
Plan Showing Currently Proposed Build
Condition
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 4
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Urban Ring Phase 2 RDEIR/DEIS Currently Proposed Build Condition
Ev e re tt
Me df or d
So merv i lle
Chel sea
Northern Tier
First Implementation Stage
Ea s t
Bo s t o n
Ca mbri dg e
Logan
West
Garage
Al ls to n
Kendall /
MIT
Southern Tier
Br o ok lin e
So uth Bo sto n
Ro xb ury
Do rch est er
Northern Tier
Southern Tier
Mixed Traffic
Mixed Traffic
Buslane
Buslane
Busway (Surface)
Busway (Surface)
Busway (Tunnel)
Busway (Tunnel)
Proposed Stop
Route Option
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 5 June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 4: Original U.S.G.S Map or Good Quality Color
Copy Indicating the Project Location and
Boundaries
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 6
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Urban Ring Phase 2 RDEIR/DEIS Study Area on U.S.G.S Map
Me df or d
Ev e re tt
So merv i lle
Chel sea
Ea st
Bo st o n
Ca mbri dg e
Br o ok lin e
So uth Bo sto n
Ro xb ury
Do rch est er
Portion of Boston North, Boston South,
Lexington, and Newton USGS 7.5' quadrangles.
Date of quads: 1985 and 1987.
Scanned quadrangles provided by MassGIS.
Urban Ring Phase 2
0
0.5
Miles
1
RDEIR/DEIS
Study Area
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 7
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 5: List of All Agencies and Persons to Whom the
Proponent Circulated the NPC, in Accordance
with 301 CMR 11.10(7)
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 8
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
United States Army Corps of Engineers,
New England District Attn: Alan R. Anacheka-Nasemann, PWS Senior Project Manager/Ecologist, Regulatory Division (CENAE-R) 696 Virginia Road
Concord, MA 01742-2751 List of Agencies and
Persons
5.1 Federal Agencies and Federal
Elected Officials
Federal Transit Administration, Region 1
Attn: Richard Doyle
Regional Administrator
55 Broadway, Suite 920
Cambridge, MA 02142
US Department of Transportation Federal Railroad Administration United States Department of Transportation
Attn: NEPA Coordinator 1200 New Jersey Avenue, SE Washington, DC 20590 Federal Transit Administration, Region 1
Attn: Mary Beth Mello,
Deputy Regional Administrator
55 Broadway, Suite 920
Cambridge, MA 02142
United States Environmental Protection
Agency, Region 1, New England Attn: Betsy Higgins, Director, Environmental Review
1 Congress Street, Suite 1100 (CWP) Boston, MA 02114-2023 Federal Transit Administration, Region 1
Attn: Peter Butler
55 Broadway, Suite 920
Cambridge, MA 02142
Federal Transit Administration, Region 1
Transportation Systems Center
Attn: NEPA Coordinator
55 Broadway, Suite 920
Cambridge, MA 02142-1093
United States Environmental Protection
Agency, Region 1, New England Attn: Edward Reiner, Senior Wetland Scientist 1 Congress Street, Suite 1100 (CWP) Boston, MA 02114-2023 Federal Highway Administration
United States Department of Transportation
Attn: NEPA Coordinator
55 Broadway, 10th Floor
Cambridge, MA 02142
United States Environmental Protection1
Agency, Region 1, New England Attn: Timothy L. Timmerman, Environmental Scientist Office of Environmental Review Mail Code: RAA 1 Congress Street, Suite 1100 Boston, MA 02114-2023 National Park Service
Attn: Environmental Compliance Program
Boston Support Office
15 State Street
Boston, MA 02109
United States Fish and Wildlife Service New England Field Office Attn: Maria Tur 70 Commercial Street, Suite 300 Concord, NH 03301 NOAA National Marine Fisheries Service
Attn: Chris Boelke
1 Blackburn Drive
Gloucester, MA 01930
1
Urban Ring Phase 2 RDEIR Notice of Project Change
Submitted written comments on the
REDIR/DEIS.
Page 9
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
United States Fish and Wildlife Service
Northeast Regional Office
Attn: NEPA Coordinator
300 Westgate Center Drive
Hadley, MA 01035-9587
Elected Officials:
Representative Michael Capuano
110 First Street
Cambridge, MA 02141
Representative Barney Frank
29 Crafts Street
Newton, MA 02458
Representative Steven Lynch
Boston Office
88 Black Falcon Avenue, Suite 340
Boston, MA 02210
Representative Edward Markey
4 High Street, Suite 101
Medford, MA 02155
Senator Edward Kennedy
2400 JFK Building
Boston, MA 02203
Senator John Kerry
One Bowdoin Square
Tenth Floor
Boston, MA 02114
5.2 State Agencies and Elected
Officials
Central Transportation Planning Staff
Attn: Scott Peterson
State Transportation Building
10 Park Plaza, Suite 2150
Boston, MA 02116
Department of Conservation and
Recreation Areas of Critical
Environmental Concern Program
Attn: Elizabeth Sorenson, Director
251 Causeway Street, Suite 700
Boston, MA 02114
Department of Conservation and
Recreation1
Attn: Julia O’Brien, Director of Planning
251 Causeway Street, Suite 600
Boston, MA 02114
Department of Conservation and
Recreation
Attn: Nat Tipton, MEPA Coordinator
251 Causeway Street, Suite 600
Boston, MA 02114
Department of Conservation and
Recreation
Division of State Parks and Recreation
Attn: Andy Backman
251 Causeway Street, Suite 600
Boston, MA 02114
Executive Office of Energy and
Environmental Affairs
Attn: Secretary Ian A. Bowles
100 Cambridge Street, Suite 900
Boston, MA 02114
Executive Office of Energy and Environmental Affairs
Attn: David Cash, Assistant Secretary for Policy 100 Cambridge Street Boston, MA 02114 Urban Ring Phase 2 RDEIR Notice of Project Change
Page 10
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Executive Office of Energy and
Environmental Affairs
MEPA Office
Attn: Rick Bourre, Assistant Director
100 Cambridge St., Suite 900
Boston, MA 02114
Executive Office of Energy and
Environmental Affairs
MEPA Office
Attn: Alicia McDevitt, Director
100 Cambridge Street, Suite 900
Boston, MA 02114
Executive Office of Transportation and
Public Works
Attn: Secretary James A. Aloisi, Jr.
10 Park Plaza, Suite 3170
Boston, MA 02116
Executive Office of Transportation and
Public Works
Public/Private Development Unit
Attn: Lionel Lucien
10 Park Plaza, Room 3510
Boston, MA 02116-3969
Massachusetts Aeronautics Commission
10 Park Plaza, Room 3190
Boston, MA 02116
Massachusetts Bay Transit Authority
Attn: Andrew D. Brennan,
Director of Environmental Affairs
10 Park Plaza, 6th Floor
Boston, MA 02116
Massachusetts Bay Transit Authority
Attn: Joseph Cosgrove, Project Manager
10 Park Plaza, 5th Floor
Boston, MA 02116
Massachusetts Bay Transit Authority
Attn: Scott Darling, Environment Dept.
10 Park Plaza, 6th Floor
Boston, MA 02116
Urban Ring Phase 2 RDEIR Notice of Project Change
Massachusetts Bay Transit Authority
Attn: Melissa Dullea
10 Park Plaza, Suite 3190
Boston, MA 02116
Massachusetts Bay Transit Authority
Attn: Dan Grabauskas, General
Manager
10 Park Plaza, 6th Floor
Boston, MA 02116-3969
Massachusetts Department of
Environmental Protection
Attn: Laurie Burt, Commissioner
One Winter Street
Boston, MA 02108
Massachusetts Department of
Environmental Protection
Attn: John Felix
One Winter Street
Boston, MA 02108
Massachusetts Department of
Environmental Protection
Attn: Jerome Grafe
One Winter Street
Boston, MA 02108
Massachusetts Department of
Environmental Protection
Attn: Philip Weinberg
One Winter Street
Boston, MA 02108
Massachusetts Department of
Environmental Protection
Air Quality Control Program
Attn: MEPA Coordinator
One Winter Street
Boston, MA 02108
Massachusetts Department of
Environmental Protection
Bureau of Resource Protection
Attn: Lealdon Langley/Mike Stroman,
Wetlands Program Chief
One Winter Street
Boston, MA 02108
Page 11
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Massachusetts Historical Commission
The Massachusetts Archives Building
Attn: Brona Simon, Executive Director
220 Morrissey Boulevard
Boston, MA 02125
Massachusetts Department of
Environmental Protection1
Northeast Regional Office
Attn: John D. Viola,
Deputy Regional Director
205B Lowell Street
Wilmington, MA 01887
Massachusetts Department of Fish and
Game
Attn: Mary Griffin, Commissioner
251 Causeway St., Suite 400
Boston, MA 02114
Massachusetts Division of Fisheries and
Wildlife
Natural Heritage Program and Endangered
Species Program
Attn: Jon Regosin
1 Rabbit Hill Road
Westborough, MA 01581
Massachusetts Division of Fisheries and
Wildlife
Natural Heritage Program and Endangered
Species Program
Attn: Henry Woolsey
1 Rabbit Hill Road
Westborough, MA 01581
Massachusetts Highway Department
Attn: Peter Cavicchi
10 Park Plaza, Suite 4160
Boston, MA 02116
Massachusetts Office of Coastal Zone1
Management
Attn: Leslie-Ann McGee, Director
251 Causeway Street, Suite 800
Boston, MA 02114
Massachusetts Office of Coastal Zone
Management
Attn: Project Review Coordinator
251 Causeway Street, Suite 800
Boston, MA 02114
Massachusetts Port Authority1
Attn: Lourenco Dantas,
Senior Transportation Planner
One Harborside Drive, Suite 200S
East Boston, MA 02128-2909
Massachusetts Turnpike Authority
Attn: Office of the Attorney General
One Ashburton Place
Boston, MA 02108
MassBike
171 Milk Street, Suite 33
Boston, MA 02109
MBTA Advisory Board
Attn: Paul Regan, Executive Director
177 Tremont Street
Boston, MA 02111
Massachusetts Highway Department
Attn: Patricia A. Leavenworth,
District Highway Director - District 4
519 Appleton St.
Arlington, MA 02476
State House, Boston, MA:
Massachusetts Highway Department
Attn: Luisa Paiewonsky, Commissioner
10 Park Plaza, Suite 3170
Boston, MA 02116
1
Massachusetts Historical Commission
The Massachusetts Archives Building
Attn: John Patten
220 Morrissey Boulevard
Boston, MA 02125
Senator Cynthia Creem
Senator Anthony Galluccio1
Senator Jack Hart1
Senator Patricia Jehlen
Senator Anthony Petruccelli1
Senator Steven A. Tolman
Senator Sonia Chang-Diaz
Senator Marian Walsh
Representative Willie Mae Allen
Representative Carlo P. Basile
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 12
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Representative Aaron Michlewitz (elect)
5.4 Local Agencies/Municipalities
Representative Paul J. Donato
Representative Marie P. St. Fleur
Representative Linda Dorcena Forry
Representative Gloria L. Fox
Representative Kevin G. Honan
Representative Elizabeth A. Malia
Representative Michael J. Moran
Representative Eugene L. O’Flaherty
Representative Denise Provost
Representative Kathi-Anne Reinstein
Representative Michael R. Rush
Representative Byron Rushing
City of Boston, MA:
Boston City Council One City Hall Square Boston, MA 02201 Boston Conservation Commission
Attn: Chris Busch, Executive Secretary
Boston Environment Department,
Boston City Hall, Room 805
Boston, MA 02201
Boston Environment Department1
One City Hall Square, Room 805
Boston, MA 02201
Representative Jeffrey Sanchez
Representative Angelo M. Scaccia
Representative Carl Sciortino, Jr.
Representative Frank Israel Smizik
Representative Timothy J. Toomey, Jr.
Representative Brian P. Wallace
Representative Martin J. Walsh
Representative Martha M. Walz
5.3 Other Agencies/Authorities
Metropolitan Area Planning Council1
Attn: Marc Draisen, Executive Director
60 Temple Place, 6th Floor
Boston, MA 02111
Massachusetts Department of Public Health
(DPH) 1
Attn: Director of Environmental Health
250 Washington Street
Boston, MA
Massachusetts Turnpike Authority
Attn: Jeffrey Mullan, Executive Director
10 Park Plaza, Suite 4160
Boston, MA 02116
MA Water Resources Authority1
Attn: MEPA Coordinator 100 First Avenue Charlestown Navy Yard Boston, MA 02129 Urban Ring Phase 2 RDEIR Notice of Project Change
Boston Parks and Recreation Department1
Attn: Antonia Pollak
1010 Massachusetts Ave. Boston, MA 02118 Boston Public Health Commission
1010 Massachusetts Ave., 2nd floor
Boston, MA 02118
Boston Redevelopment Authority1
Boston’s Planning and Economic
Development Office
Attn: Kairos Shen, Chief Planner
Once City Hall Square
Boston, MA 02201-1007
Boston Transportation Department
Attn: Thomas Tinlin, Commissioner
One City Hall Square
Boston, MA 02201
Boston Water and Sewer Commission
Attn: John Sullivan, Chief Engineer
980 Harrison Ave
Roxbury, MA 02119
Honorable Thomas Menino
City of Boston
One City Hall Square, Suite 500 Boston,
MA 02201
Page 13
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Town of Brookline, MA:
City of Chelsea, MA:
Brookline Board of Health
Attn: Alan Balsam, Director
11 Pierce St.
Brookline, MA 02445
Chelsea Board of Health
Attn: Dr. Dean Xerra, Chair
Chelsea City Hall
500 Broadway
Chelsea, MA 02150
Brookline Board of Selectmen1
Old Lincoln School
194 Boylston Street 2nd Floor
Brookline, MA 02445
Brookline Conservation Commission
Old Lincoln School
194 Boylston Street
Brookline, MA 02445
Brookline Preservation Commission1
Attn: Sheri Flagler, Chair
Brookline Town Hall
333 Washington Street
Brookline, MA 02445
City of Cambridge, MA:
Cambridge City Council
City Hall, 2nd Floor
795 Massachusetts Avenue
Cambridge, MA 02139
Cambridge Community
Development Department
344 Broadway
Cambridge, MA 02139
Cambridge Conservation Commission
344 Broadway
Cambridge, MA 02139
Cambridge Health Department
119 Windsor St.
Ground floor
Cambridge, MA 02139
Cambridge Redevelopment Authority1
Attn: Joseph F. Tulimieri,
Executive Director
One Cambridge Center/Fourth Floor
Cambridge, MA 02142
City of Cambridge Executive Dept.1
Attn: Robert W. Healy, City Manager
Cambridge City Hall
795 Massachusetts Avenue
Cambridge, MA 02139
Urban Ring Phase 2 RDEIR Notice of Project Change
City of Chelsea
Attn: Jay Ash, City Manager
Chelsea City Hall
500 Broadway, Room #306
Chelsea, MA 02150
City of Chelsea1
Attn: Chelsea Planning & Development
Department
Chelsea City Hall
500 Broadway, Room #101
Chelsea, MA 02150
City of Everett, MA:
Everett Board of Health
Everett City Hall
484 Broadway
Everett, MA 02149
Everett City Council
Everett City Hall
484 Broadway, Room 38
Everett, MA 02149
Everett Conservation Commission
Everett City Hall
484 Broadway
Everett, MA 02149
Everett Planning Department
Everett City Hall
484 Broadway
Everett, MA 02149
Honorable Carlo DeMaria, Jr.
City of Everett
Everett City Hall
Everett, MA
City of Medford, MA:
Medford Board of Health
Medford City Hall
85 George P. Hassett Drive, Room 311
Medford, MA 02155
Page 14
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Medford City Council
85 George P. Hassett Drive, Room 207
Medford, MA 02155
Boston Public Library – East Boston
276 Meridian St.
East Boston, MA 02128
Medford Community Development
Department
Attn: Lauren DiLorenzo
85 George Hassett Drive
Room 308
Medford, MA 02155
Boston Public Library – South Boston
646 East Broadway
South Boston, MA 02127
Medford Conservation Commission
Medford City Hall
85 George P. Hassett Drive
Medford, MA 02155
Honorable Michael McGlynn
85 George P. Hassett Drive
Medford, MA 02155
Boston Public Library
Honan-Allston Branch
300 North Harvard Street
Boston, MA 02134
Boston Public Library
Uphams Corner Branch
500 Columbia Road
Dorchester, MA 02125
City of Somerville, MA:
Somerville Board of Alderman
93 Highland Avenue
Somerville, MA 02143
Somerville Board of Health
Attn: Health Department Director
City Hall Annex
50 Evergreen Avenue
Somerville, MA 02145
Somerville Conservation Commission
Attn: Elizabeth Pyle
93 Highland Avenue
Somerville, MA 02143
Somerville Office of Planning &
Development
Attn: Monica Lamboy, Director
93 Highland Avenue
Somerville, MA 02143
Honorable Joseph Curtatone
City of Somerville
93 Highland Avenue
Somerville, MA 02143
Boston Public Library
700 Boylston Street
Boston, MA 02116
1
Boston Public Library
Washington Village Branch
1226 Columbia Road
South Boston, MA 02127
Boston Public Library
Parker Hill Branch
1497 Tremont Street
Roxbury, MA 02120
Boston Public Library
South End Branch
685 Tremont Street
Boston, MA 02118
Cambridge Public Library
359 Broadway
Cambridge, MA 02139
Chelsea Public Library
569 Broadway
Chelsea, MA 02150
Libraries:
Medford Public Library
111 High Street
Medford, MA 02155
Boston Public Library – Dudley
65 Warren St.
Roxbury, MA 02119
Parlin Memorial Library
410 Broadway
Everett, MA 02149
Public Library of Brookline
361 Washington St.
Brookline, MA 02445
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Somerville Public Library 79 Highland Avenue Somerville, MA 02143 Jeffrey Levine, Town of Brookline
Alternate: Todd Kirrane
State Transportation Library of Massachusetts 10 Park Plaza, 2nd Floor Boston, MA 02116 Arthur Mombourquette, Brigham &
Women’s Hospital
Alternate: Jennifer Nadelson
5.5 Urban Ring CAC1 Members
Kelly Brilliant, Fenway Alliance
Larry Brophy, Northeastern University
Kelley Brown, Massachusetts Institute of
Technology
Peter Cusato, Boston University
Alternate: James Shaer
John DePriest, City of Chelsea
Paul Ellis, City of Medford
Maureen Flaherty, BU Medical Center
Alternate: William Gasper
Thomas Nally, A Better City
Charlotte Nelson, Roxbury Strategic
Master Plan Committee
Stephen Oakley, Livable Streets Alliance Aditi Pain, University of Mass/Boston
Susanne Rasmussen, Cambridge
Community Development
Alternate: Cara Seiderman
William Richardson, Fenway Civic
Association
Marzie Galazka, City of Everett
Carrie Russell, Conservation Law
Foundation
Richard Garver, Boston Redevelopment
Authority Alternate: John Read Karen Wepsic, On the Move/MBTA
Riders Oversight Committee
Elizabeth Gerlach, Beth Israel Deaconess Medical Center Alternate: Diana Tuttle Vineet Gupta, Boston Transportation
Department
Sarah Hamilton, MASCO1
Alternate: Tom Yardley Aaron Henry, Fenway Community
Development
Deborah Kuhn, Harvard University
Alternate: Harris Band
Daniel Wilson, Move Massachusetts
Alternate: Peter Koff
Wig Zamore, Somerville Transportation1
Equity Partnership (STEP)
Alternate: Ellen Reisner
5.6 Institutions
Annunication Greek Orthodox Cathedral
of New England
Beth Israel Deaconess Medical Center*1
Boston Latin School
Boston Medical Center*
Monica Lamboy, City of Somerville
Alternate: Stephen Winslow
Urban Ring Phase 2 RDEIR Notice of Project Change
Boston University* 1
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Brigham and Women’s Hospital*
CBR Institute for Biomedical Research
5.7 Other Organizations and
Individuals
Children’s Hospital Boston1
A Better City (ABC)* 1
Dana-Farber Cancer Institute
Adaptive Environments Emmanuel College
Advocates for Transportation Alternatives
Harvard Medical, Dental, and Public Health
Schools
Harvard University* 1
Alternatives for Community &
Environment (ACE)1
Association of Public Transp.1
1
Isabella Stewart Gardner Museum
*Indicates representation on the Citizen’s Advisory
Committee
Joslin Diabetes Center
Judge Baker Children’s Center
Massachusetts College of Art and Design
Massachusetts College of Pharmacy &
Allied Health Sciences
Massachusetts General Hospital
Massachusetts Institute of Technology* 1
MGH Chelsea Healthcare Center
Museum of Fine Arts
Northeastern University*
Partners HealthCare System1
Audubon Circle Neighborhood
Association1
George Bailey, MBTA Advisory Board
Bike to the Sea, Inc.1
Sean Bender
Boston Freight Terminals
Boston Harbor Association
John F. Burckardt, PE1
Charles River Watershed Association1
Chelsea T Riders Union
Maggie Cohn
Conservation Law Foundation*
Simmons College
Cottage Farm Neighborhood
Association University of Massachusetts at Boston
(UMass Boston) * 1
Anne Deane1
Wentworth Institute of Technology1
Wheelock College1
Winsor School1
Urban Ring Phase 2 RDEIR Notice of Project Change
Carol G. Deane1
Susan DeLong
Matilda Drayton Michael S. Dukakis1
Page 17
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Emerald Necklace Citizens Advisory
Committee1
Mission Hill Neighborhood Housing
Services
Alan Moore1
Emerald Necklace Conservancy
Gloria Murray
Environmental Oversight Committee
Fenway Alliance*
1
Fenway Civic Association* 1
Patricia Murray1
On the Move/MBTA Rider Oversight*
Pioneer Institute
Fenway Community Development
Corporation 1
Sasha E. Polonsky1
Sarah Freeman
Alison Pultinas
Hale & Dorr
Ellin Reisner, PhD1
Richard C Howard, Mayor, City of Malden
Michael P. Ross, Boston City Councilor
Inner Core Committee
Roxbury Strategic Master Plan
Committee*
Stephen H. Kaiser
Rob Kassel, Trustee, Brickbottom
Condominium Association, Somerville1
Fred Salvucci1
Shepley, Bulfinch Richardson & Abbott
Craig A. Kelley1
Sierra Club1
Kenneth J. Krause1
Mark Sutherland, Co-Chair Ward 5
Democratic Committee1
Shirley Kressel1
John Kyper
Robert J. La Tremouille1
Livable Streets Alliance*
MASCO*
TranSComm - BU Medical Center*
Walk Boston1
Joel N. Weber II1
Marilyn Wellons1
1
Karen Wepsic1
Massachusetts Academic and Scientific
Community Organization, Inc.
John M. Westcott, Jr.1
Massachusetts Taxpayers Foundation
Kaitilin K. Yaremchuk1
Move Massachusetts*
Arshag Mazmanian1
Anne McKinnon
Joshua D. Mello
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Attachment 6:
Project Change Description – Supporting Details
This Notice of Project Change (NPC) clarifies the Executive Office of Transportation’s approach to
implementing the Urban Ring Phase 2 project, in response to Secretary Bowles’ request in the March 6,
2009 Certificate on project’s Revised Draft Environmental Impact Report (RDEIR).
The NPC includes the following principal elements:
• Alignment Changes to the Locally Preferred Alternative. Identifies portions of the locally preferred
alternative (LPA) alignment where EOT is proposing a change, the resolution of alignment options, or
further evaluation of a potential alignment change.
• Implementation Plan. Describes EOT’s approach to phasing, environmental review, and
implementation for the Urban Ring Phase 2 project.
• Special Review Procedure. Proposes changes to the MEPA Special Review Procedure (SRP)
governing the project.
• Comment Response. Responds to comments that were raised on the RDEIR.
6.1
Alignment Changes to the Locally Preferred Alternative
The RDEIR recommended a preferred alignment through the project’s 25-mile corridor, the locally
preferred alternative (LPA). However, the LPA included segments where a single preferred alignment
could not be selected due to uncertainty or ongoing analysis. There are also segments of the corridor in
which changed conditions have led EOT to reconsider the LPA alignment included in the RDEIR, and to
recommend in this NPC either a changed alignment or a re-examination of the recommended alignment.
All of the recommended alignment changes were included either in the LPA (as alignment options) or in
one of the other alternatives evaluated in the RDEIR.
The following are the recommended alignment changes or areas for further review, as shown on the map
provided in Attachment 3:
Mystic River Crossing: Everett – Sullivan Square. Instead of traversing the Revere Beach Parkway –
Wellington Station – Route 28 – Assembly Square alignment included in the RDEIR, the revised
alignment would continue south along the Newburyport/Rockport commuter rail corridor, pass over or
under the commuter rail line in the vicinity of Chemical Way, cross the Mystic River in mixed traffic on
Route 99, and connect to Sullivan Square via bus-only roadways segments that are currently under study
by the City of Boston. Alternatives 4 and 4A in the RDEIR Chapter 3 starting on page 3-70 evaluated the
benefits and impacts of this alignment. EOT recommends this change due to issues raised about
environmental impacts of the busway along the edge of Revere Beach Parkway, environmental impacts
from the new bridge crossing proposed for the Malden River, congestion at Wellington Circle and
uncertainty about implementation of the proposed Wellington Circle grade separation. At the same time,
the City of Boston has undertaken a review of potential roadway configuration and circulation changes
that could help to provide a faster, more reliable connection from the Alford Street Bridge to Sullivan
Square Station. This alignment would also have the advantage of increasing the percentage of dedicated
right-of-way, compared to the LPA’s use of Revere Beach Parkway and Route 28 in mixed traffic.
Allston Alignment: BU Bridge – North Harvard Street. This segment of the corridor included a number
of alignment options in the RDEIR. Based on further technical and stakeholder work (as summarized in
the “Allston Bus Rapid Transit Routing Study”), the recommended alignment in this segment passes in
busway beneath the Massachusetts Turnpike viaduct, through the Beacon Park Yard property, and along
the southern edge of Cambridge Street, then connects to the proposed Stadium Way, Western Avenue,
and North Harvard Street. This was one of the options included in the RDEIR LPA, and the supplemental
analysis demonstrated that this is the preferable routing in terms of travel time, reliability, and availability
of dedicated right-of-way.
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Columbia Point: Re-Evaluate Extension to UMass-Boston. The RDEIR LPA alignment terminated at
the JFK-UMass station. However, based on new planning efforts related to the UMass-Boston Master
Plan, the City of Boston’s Columbia Point Master Plan, and the proposed Edward M. Kennedy Institute for
the United States Senate, EOT will re-evaluate the potential for extending Urban Ring Phase 2 BRT
service to the Columbia Point peninsula. This connection was evaluated in RDEIR Alternatives 1, 2, 2A,
3, 3A, 3B, 3C, 4 and 4A in Chapter 3 starting on page 3-48. EOT will coordinate with these planning
efforts to identify potential for dedicated right-of-way and BRT stations at UMass Boston and other
destinations, and will work to ensure that Urban Ring Phase 2 service can be provided for Columbia
Point.
Fenway/Longwood Medical and Academic Area (LMA): Identify Interim Surface Routing. As
discussed below in the Implementation Plan, financial constraints are expected to delay implementation
of the proposed Fenway/LMA tunnel. EOT will coordinate with the MBTA, City of Boston, and
Fenway/LMA stakeholders in order to identify interim surface routing options through this portion of the
corridor.
EOT requests that EOEEA scope environmental review of these alignments in a manner that is
appropriate to its environmental impacts and to the proposed Implementation Plan (below).
6.2
Implementation Plan
The Urban Ring Phase 2 is a large and complex project that covers a great deal of the metropolitan
Boston core. Given the scale, complexity, and cost of the Urban Ring Phase 2 project proposed in the
RDEIR, the Commonwealth of Massachusetts is not currently in a position to implement the full project. At
the same time, the project has such a broad scope that it includes many different component parts that
can function independently and can offer significant transit benefits. However, there are also a number of
location-specific issues and impediments to project implementation that must be resolved before certain
components of the project can be advanced.
Therefore, EOT has undertaken an evaluation of potential implementation approaches that are intended
to enable major components of the overall project to advance as quickly as finances and location-specific
issues and impediments allow. EOT has analyzed a number of potential implementation stages and
corridors, relative to mobility benefits/projected ridership, capital cost, cost-effectiveness, environmental
justice benefits, development opportunities, impediments to implementation, and potential for
implementing a continuous service corridor. These criteria are closely related to the key rating criteria for
the Federal Transit Administration’s New Starts program, the discretionary federal funding program for
major fixed guideway transit system expansion.
The list of the potential implementation corridors are provided below and a summary of key evaluation
criteria and a summary of how different corridors perform are shown in Table 1.
•
•
•
•
•
•
Logan Airport to Kendall Square, “Northern Tier”;
Assembly Square to Yawkey Station;
Kendall Square to Logan Airport with tunnel;
Kendall Square to Logan Airport without tunnel;
Harvard Square to Logan Airport with tunnel; and
Harvard Square to Logan Airport without tunnel.
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Table 1: Summary Evaluation Matrix for Potential Implementation Corridors
Potential Implementation Corridors
Northern Tier – Logan Kendall2
Kendall - Logan
(tunnel)
Kendall - Logan (no
tunnel)
Assembly Sq - Yawkey
Harvard - Logan
(tunnel)
Harvard - Logan (no
tunnel)
66,000
$486 M
$8-$11
105,000
$2.1 B
$25-$28
89,000
$300 M
$4-$8
47,000
$300 M
$6-$10
105,000
$2.1 B
$24-$27
92,000
$345 M
$4-$8
12 miles
72,900
13 miles
120,700
13 miles
119,600
7 miles
67,800
15 miles
132,200
15 miles
131,100
Dedicated ROW4
55% (65% assuming Rt.
99 routing)
60%
50%
55%
60%
55%
Economic
Development
Opportunities
• Provide unserved EJ • Improved transit
residents with rapid
access for residents
transit access to jobs • Connections among
• New transit access to
existing nodes in “Life
under-developed land:
Sciences Cluster” –
Chelsea, Everett,
Kendall Sq, MIT, BU,
Sullivan Sq, Assembly
LMA, BUMC
Sq, Inner Belt
MEASURES
Daily Riders (2030)
Capital Cost (2009)
Preliminary
Cost-effectiveness
Corridor Length
3
EJ Population (2000)
• Improved transit
access for residents
• Connections among
existing nodes in “Life
Sciences Cluster” –
Kendall Sq, MIT, BU,
LMA, BUMC
• Improved transit
• Improved transit
• Improved transit access
access for residents
access for residents
for residents
• Connections among
• Connections among
• Connections among
under-developed areas proposed Harvard
proposed Harvard
(Assembly Sq, Sullivan development initiatives development initiatives
Sq, Inner Belt) and
and existing nodes in
and existing nodes in
established areas
“Life Sciences Cluster” “Life Sciences Cluster” –
(Kendall Sq, MIT, BU)
– BU, LMA, BUMC
BU, LMA, BUMC
• Charles River crossing • Charles River crossing • Charles River crossing • CSX transaction,
• CSX transaction
– CSX transaction,
– CSX transaction,
– CSX transaction,
railyard consolidation/
• Malden River crossing
operating agreement
operating agreement
operating agreement
relocation
– environmental
Implementation Issues impacts5
• BU Academy
• BU Academy
• BU Academy
• Uncertainty about
and Impediments
relocation
relocation
relocation
Harvard Allston
• Wellington Circle
Initiative schedule
• Fenway/LMA tunnel
• Local opposition to
congestion5
costs
Fenway/LMA surface
• Fenway/LMA tunnel
costs
route
2
4
5
Except as noted, performance measures based on Northern Tier LPA alignment via Wellington Station, Wellington Circle, and Route 28.
EJ Population corresponds to the total residents within all traffic analysis zones that meet Boston Region MPO thresholds for environmental justice (median
income < 80% of regional median, minority population > regional average.
Preliminary engineering design plans required for detailed calculations.
Impediments addressed by alignment change to Route 99 corridor.
Urban Ring Phase 2 RDEIR Notice of Project Change
3
• CSX transaction, railyard
consolidation/ relocation
• Uncertainty about
Harvard Allston Initiative
schedule
• Local opposition to
Fenway/LMA surface
route
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
These potential implementation corridors all demonstrate positive transit service potential, with high levels
of ridership and good potential for economic development benefits. A critical differentiating factor among
these corridors is each one’s relative level of outstanding issues and impediments to implementation.
These issues and impediments relate primarily to right-of-way impacts and availability; railroad and
railyard operations; and financial capacity.
EOT has conducted this analysis in the context of the current and anticipated future financial
environment. Key elements of this financial environment include the following:
• The expected Boston Region Metropolitan Planning Organization (MPO) long-range Regional
Transportation Plan (RTP). This document, which is currently undergoing revision, establishes a
financially constrained long-term plan for spending federal funds on transportation improvements
in the Boston metropolitan region.
•
The Commonwealth’s long-term financial and revenue projections, which are a key input to the
Boston Region MPO’s RTP.
•
The FTA’s New Starts program, which EOT assumes will be a significant source of funding for the
Urban Ring Phase 2. A project must be included in the MPO RTP in order to qualify for New
Starts funding.
•
The pending federal multi-year transportation funding authorization. The current federal
transportation funding authorization, the Safe, Accountable, Flexible, Efficient Transportation
Equity Act: A Legacy for Users (SAFETEA-LU) expires on September 30, 2009. The replacement
authorization will include New Starts or a successor program, and could include changes to
program guidelines and requirements.
Funding for the Urban Ring Phase 2 through these sources is not certain. EOT believes that it is prudent
and responsible to develop an implementation plan that is based on realistic assumptions. Therefore, the
implementation plan below represents EOT’s preferred approach for prioritization and for pursuing
funding. Nevertheless, it is EOT’s intention to advance all elements of the project as financing, right-ofway, and abutter coordination allow, and to retain the unity of the project to the degree possible.
Based on these factors, the following is EOT’s proposed implementation approach:
6.2.1
Northern Tier: Logan Airport – Kendall Square – Initial BRT Corridor Stage
EOT has determined that the northern portion of the corridor, between Logan Airport and Kendall Square,
offers the best opportunity to implement a continuous BRT service that satisfies the criteria above,
including strong implementation potential. The Northern Tier is comprised of most of Sectors 1 through 5
of the LPA as described in the RDEIR in Chapter 2 starting on page 2-8. Northern Tier implementation
requires that the Commonwealth of Massachusetts complete its acquisition of the CSX Transportation
right-of-way in Everett, Chelsea, and East Boston. However, other major impediments are addressed by
changing the preferred alignment to the Route 99 corridor (which has the additional benefit of increasing
the alignment’s proportion of dedicated right-of-way). EOT intends to pursue full implementation of this
section of the project as the first stage of the Urban Ring Phase 2 project, and we request that EOEEA
scope work on a Final Environmental Impact Report/Final Environmental Impact Statement (FEIR/FEIS)
for the Northern Tier, as shown on the map provided in Attachment 3.
The following is a summary of the assessment of the Northern Tier relative to the evaluation criteria:
• Ridership. The Northern Tier includes two of the Urban Ring corridor’s three principal high-ridership
segments: Logan Airport – Wellington Station (which provides connections to and between the Blue
Line and Orange Line for environmental justice populations and commercial areas in Chelsea and
Everett that do not currently have rapid transit service) and Sullivan Square – Kendall Square (which
provides transit access from the Orange Line and commuter rail to and between the Green and Red
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Lines in East Cambridge and Kendall Square, satisfying key missing connections in the existing
transit system). The Northern Tier has a projected daily ridership of approximately 66,000 (year
2030), or about 36 percent of the LPA projected daily ridership of 184,000 (in 38 percent of the overall
corridor length). The third high-ridership segment is centered on the Longwood Medical and
Academic Area (LMA); this segment has the highest ridership, but also has major cost and
implementation and feasibility issues. The Northern Tier’s projected ridership makes it a good
candidate for FTA New Starts funding.
• Costs and cost-effectiveness. The Northern Tier is estimated to cost $486 million, or approximately
19 percent of the total LPA capital costs (2009 dollars). This cost would enable the Northern Tier to
leverage significant federal New Starts funding, while requiring a much lower non-federal share of
capital costs than the LPA. It also has strong cost-effectiveness relative to FTA New Starts Program
criteria: $8 – 11 per user benefit hour, which would receive a New Starts rating of “High” based on
current program guidelines.
• Local support. The Northern Tier connects to all four rail rapid transit lines (Blue, Orange, Green,
and Red) plus two commuter rail lines and multiple local bus routes, and provides service in Boston,
Chelsea, Everett, Somerville and Cambridge (all of the Urban Ring Compact municipalities except for
Brookline). There is general support for this alignment.
• Economic development benefits. The Northern Tier includes significant economic target and
economic opportunity areas, vacant or under-utilized land, and industrial land with uses that are
vacating or consolidating.
• Environmental justice benefits. While other segments of the LPA pass through and serve
environmental justice communities, the Northern Tier includes significant environmental justice
populations that currently do not have rapid transit service, notably Chelsea and Everett.
• Proportion of dedicated right-of-way. The LPA alignment for the Northern Tier included
approximately 55 percent dedicated right-of-way, which is in excess of the federal guideline for
minimum 50 percent dedicated right-of-way in a BRT project. The recommended alignment change to
the Route 99 corridor would further increase the proportion of dedicated right-of-way to approximately
65 percent.
• Contiguity. The Northern Tier is a contiguous segment that would be well-suited to establishing and
operating a new rapid transit service.
• Feasibility/right-of-way and abutter issues. The Commonwealth of Massachusetts has negotiated
an agreement with CSX Transportation to purchase a number of CSX-owned railroad rights-of-way,
including the Grand Junction Railroad (GJRR), which connects from Beacon Park Yard in Allston
through Cambridge, East Somerville, Everett, Chelsea and East Boston. This GJRR transaction will
be included in the first phase of the property transfer from CSX to the Commonwealth, which is
currently under active negotiation. This purchase will help to facilitate implementation of the Urban
Ring Phase 2 in the Northern Tier because the East Boston Haul Road and the Chelsea – Everett
BRT busway use abandoned GJRR right-of-way. The City of Boston is also coordinating with Urban
Ring Phase 2 routing and alignment as the City develops plans for reconstructing and improving
Sullivan Square.
6.2.2 Southern Tier: Kendall Square – Logan Airport/Allston Connection/Massachusetts
Avenue – JFK/ UMass Connection
This portion of the project corridor, which includes everything outside of the Northern Tier, is composed of
a wide range of different infrastructure elements that cover a diversity of conditions and issues. The
Southern Tier is essentially comprised of Sectors 6 through 11 of the LPA as described in the RDEIR
Chapter 2 starting on page 2-19. This segment of the corridor includes a number of major infrastructure
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
elements that are very costly and/or have external impediments that are expected to delay
implementation. These components (the Fenway/LMA tunnel, the Charles River crossing, and the Allston
connection) were identified through the RDEIR planning process as the most advantageous means of
providing dedicated right-of-way and improving speed and reliability for Urban Ring Phase 2 buses in
congested areas of the corridor. Because these elements cannot be implemented at this time, achieving
continuous, high-functioning BRT service in the Southern Tier is more difficult.
However, there are elements in the Southern Tier that could be implemented in a nearer time frame.
These potential “early actions” include infrastructure investments that entail low costs and minimal
environmental impacts, and that could offer potential independent benefits, including Albany Street bus
lanes in Cambridge; Mountfort Street corridor improvements in Brookline and Boston; Ruggles Station
improvements; Melnea Cass Boulevard center median busway; bus lanes on Albany Street,
Massachusetts Avenue, and potentially on Columbia Point in Boston; and interim surface improvements
in the Fenway/LMA section of the corridor). Other potential “early actions” include transit service
improvements in the Southern Tier. Early actions and major infrastructure elements in the Southern Tier
are described below and summarized in Table 2.
Table 2: Summary Evaluation Matrix for Potential Implementation – Southern Tier
Project Element
Cost
Outstanding Issues
Potential Early Action Elements
Albany Street bus lanes
Mountfort Street corridor
improvements
Interim surface improvements in
the Fenway/LMA
$1 M • Coordination with City of Cambridge on roadway layout
$14 M • Coordination with City of Boston/Boston University on roadway layout,
circulation, and other issues
TBD Coordination with City of Boston and LMA institutions on roadway layout,
circulation, and other issues
Ruggles Station improvements
$33 M
Melnea Cass Boulevard
reconstruction; center median
busway
$27 M
Albany Street bus lanes
$2 M • Coordination with City of Boston on roadway layout, circulation, other issues
Massachusetts Avenue, potential
Columbia Point bus lanes
$2 M • Coordination with City of Boston, UMass Boston on roadway layout,
circulation, other issues
Major Infrastructure Elements
Fenway/LMA Tunnel
Charles River Crossing/Grand
Junction Railroad
$1.8 B • Financially infeasible in current planning horizon
• Environmental, engineering, design, construction, and abutter impact issues
• Alignment issues
$130 M • Use of active Grand Junction Railway for frequent BRT operations
• New tunnel beneath BU Bridge
• Availability of connection through the BU Academy site
• Environmental issues
Allston Connection
$82 M • Coordination with CSX and Harvard University (property owners)
• Consolidation/relocation of railyard operations
• Railroad grade crossings
• Environmental issues
Costs are in 2009 dollars and include costs for accompanying stations based on the RDEIR/DEIS. M = Million; B = Billion.
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Southern Tier – Potential “Early Actions.” EOT intends to pursue early actions that can improve transit
service in the Southern Tier, despite the financial constraints, railroad issues, property challenges, and
other impediments that prevent implementation of the major infrastructure elements. These early actions
are expected to include enhanced transit service in the corridor, along with implementation of certain low
cost infrastructure elements. EOT intends to work with the MBTA, corridor municipalities, Urban Ring
Citizens Advisory Committee (CAC) members, and other stakeholders on a planning process to evaluate
and recommend early actions to improve transit service in the Southern Tier. This planning process would
address both service and infrastructure improvements, and consider issues that include existing and
potential new bus routes, operating plans, vehicle procurement, maintenance requirements, and costs.
EOT expects that these service and infrastructure improvements will not have significant environmental
impacts. Based on the recommendations of the planning process, EOT expects to file a subsequent
Notice of Project Change that will request that EOEEA exempt these early actions in the Southern Tier
from further environmental review. This would enable implementation as soon as transit need, local
conditions and financing allow.
Transit Service Improvements in the Urban Ring Corridor. Through the early action planning
process, EOT will identify opportunities for improving bus service and implementing transportation
system management (TSM) measures in the Southern Tier. These service improvements will
build upon the existing Crosstown (CT) bus services, and will be based on a review of existing
bus service and evolving transit demand in the Urban Ring corridor. EOT will also work with the
MBTA, corridor municipalities, and stakeholders to implement supporting improvements, including
upgraded traffic signals capable of transit signal priority; transit signal priority in major bus
corridors including Urban Ring corridor routes; and amenities such as upgraded bus shelters and
the provision of real-time traveler information.
Southern Tier – Low Cost and Low Impact Infrastructure Improvements. In addition to the
costly and high-impact major infrastructure elements, there are a number of other infrastructure
investments in the Southern Tier that have low much lower costs, lesser impediments to
implementation, and minimal environmental impacts. Most of these improvements entail
reallocation of roadway space within existing roadway layout, with some intersection redesign
and/or minor widening. Many of these improvements could offer independent utility for existing
transit services and potential transit service improvements in the Urban Ring corridor. EOT
recognizes that further coordination with the corridor municipalities, neighborhoods, abutting
institutions, and other stakeholders will be necessary for all of these infrastructure improvements.
The potential early actions are depicted in Figure 1.
•
Albany Street Bus Lanes, Cambridge. Cost = $1 million (2009 dollars). Alternating bus
lanes on Albany Street between Main Street and Fort Washington Park (bus lanes split
between eastbound and westbound to provide dedicated bus lane on intersection
approaches). There is currently no bus service on Albany Street, so this improvement should
be implemented at such time that bus service is provided on Albany Street.
•
Mountfort Street Corridor Improvements, Brookline and Boston. Cost = $14 million
(2009 dollars). Bus lanes in Carlton Street (northbound Carlton Street Bridge in bus lane) and
Mountfort Street (between Park Drive and Beacon Street). Bus connections would be
facilitated by reconfiguring the Mountfort Street/Carlton Street intersection to allow westbound
Mountfort Street traffic to continue straight to the BU Bridge. Roadway reconfiguration could
be accommodated mostly within the existing roadway layout. The 47 and CT2 bus routes
currently use this corridor.
•
Ruggles Station Improvements, Boston. Cost = $33 million (2009 dollars). New inbound
commuter rail platform and associated station modifications at Ruggles Station.
•
Melnea Cass Boulevard Reconstruction, Center Median Busway, Boston. Cost = $27
million (2009 dollars). Center median busway along Melnea Cass Boulevard from Ruggles
Station to Albany Street. This is an important improvement since its implementation is
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
necessary for achieving the planned roadway layout that will define the edges of
development parcels, and to facilitate the creation of a planned shared-use path, the South
Bay Harbor Trail. There is a $6 million SAFETEA-LU earmark for this improvement.
Figure 1: Potential Early Actions – Infrastructure Improvements
Bo st o n
C am b r i d g e
Albany Street
Buslanes
Alls to n
Mountfort Street
Corridor
Improvements
Melnea Cass Blvd.
Busway
Br o o kl i n e
Interim Surface
Improvements
Fenway/LMA
So ut h B o s t o n
Albany Street
Buslanes
Ruggles Station
Improvements
Southern Tier Potential Early Actions
Mixed Traffic
Ro x b u r y
Buslane
Busway (Surface)
LMA Surface Routing
(ongoing coordination with City of Boston
and area stakeholders)
Massachusetts
Avenue
Buslanes
D o r ch e s t e r
•
Albany Street Bus Lanes, Boston. Cost = $2 million (2009 dollars). Bus lanes in Albany
Street from Crosstown Center to Boston University Medical Center. Coordination will continue
with the City of Boston regarding the removal of on-street parking on Albany Street to provide
bus lanes in both directions.
•
Massachusetts Avenue and Columbia Point Bus Lanes, Boston. Cost = $2 million (2009
dollars). Bus lanes in Massachusetts Avenue from Melnea Cass Boulevard to Columbia Road
and on Columbia Point roadways. Coordination will continue with the City of Boston and
UMass Boston regarding potential roadway layout and circulation changes to facilitate bus
lanes and improved bus service in these corridors.
•
Interim Surface Improvements in the Fenway/Longwood Medical and Academic Area,
Boston. During the RDEIR/DEIS process, EOT investigated a range of potential surface
alignments in the Fenway/LMA portion of the corridor. The options that were evaluated
included a wide range of routes (limited use of the Fenway segment of the Emerald Necklace
Parkway system), bus lanes/queue jump lanes (some with minor roadway widening),
circulation changes, and transit signal priority. However, all surface routing proposals were
strongly opposed by area stakeholders, and a consensus surface routing option was not
developed for the RDEIR. Nonetheless, given the Fenway/LMA’s limited roadway network,
high levels of congestion, and extremely dense (and ongoing) development patterns, the
Urban Ring Phase 2 RDEIR Notice of Project Change
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Fenway/LMA has major transit demand and a need for measures to improve transit mobility.
EOT will continue to work with the City of Boston and area stakeholders to develop surface
routing options that can enable improved transit service for the Fenway/LMA.
Southern Tier – Major Infrastructure Elements. The vast majority of the Southern Tier’s capital costs,
environmental impacts, and abutter impacts are concentrated in three major project elements – the
Fenway/LMA Tunnel, the Charles River crossing, and the Allston connection. These project components
all have significant barriers to implementation that prevent EOT from providing contiguous Urban Ring
BRT service in the Southern Tier.
Resolution of these impediments will depend to a large degree on processes external to the Urban Ring
Phase 2 project planning and environmental review process, as described below. While there are
significant environmental impacts associated with these proposals that will need to be addressed prior to
implementation, EOT requests that EOEEA refrain from issuing a scope of work for final environmental
review on these infrastructure elements at this time. EOT will submit further Notice(s) of Project Change
when it intends to initiate final environmental review for any of these infrastructure elements.
The following is a summary of the major outstanding issues and impediments to implementation
associated with the Fenway/LMA tunnel, the Charles River crossing, and the Allston connection. It does
not include a discussion of the outstanding environmental issues that EOT recognizes are significant, and
will need to be addressed at such time as EOT undertakes final environmental review of these
investments. The general location of these major infrastructure elements is shown in Figure 2.
Figure 2: Major Infrastructure Elements
Bo st o n
C am b r i d g e
Charles River
Crossing/GJRR
Alls to n
Allston
Connection
Br o o kl i n e
So ut h B o s t o n
Fenway/LMA
Tunnel
Southern Tier
Major Infrastructure Elements
Mixed Traffic
Ro x b u r y
Buslane
Busway (Surface)
Busway (Tunnel)
D o r ch e s t e r
Busway (Tunnel) Alignment Options
Fenway/LMA Tunnel. The Urban Ring Phase 2 alignment through the Fenway/LMA area
proposed in the RDEIR entails a new bus tunnel between the vicinity of the Landmark Center and
Ruggles Station. The proposed tunnel is a complex infrastructure project, and it faces major
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
environmental, engineering, design, construction, and abutter impact issues. Aside from these
issues, however, the tunnel faces financial obstacles that prevent EOT from pursuing it at this
point.
The tunnel is an extremely expensive component of the project; with an estimated cost of $1.8
billion (2009 dollars), the 1.5-mile tunnel would account for approximately two-thirds of the
project’s $2.6 billion capital cost. This cost cannot be accommodated in the Boston Region
MPO’s Regional Transportation Plan (RTP). Inclusion in the RTP is a prerequisite for the project
to qualify for federal funding through FTA’s New Starts program. EOT will request that the New
Starts program recognize the full Urban Ring Phase 2 as a single project, but EOT cannot pursue
federal funding for the tunnel until it is included in a future RTP.
EOT recognizes that in addition to the tunnel financing issues, there are outstanding issues
related to tunnel alignment, engineering, and construction. These issues are greatest as they
relate to the alternative tunnel alignments proposed in the RDEIR, and the areas around portals
at either end of the tunnel, where construction impacts are greatest. The complexity of the tunnel
engineering and uncertainty surrounding geotechnical conditions in the Fenway/LMA mean that
final alignment and tunneling method (i.e. tunnel boring machine versus sequential excavation
method) would need to be evaluated in the preliminary engineering and final environmental
phases. However, the lack of a schedule for future tunnel construction prevent EOT from
completing further tunnel engineering, design and construction planning until tunnel funding and
implementation schedule have been identified. Nevertheless, EOT completed significant
conceptual tunnel engineering in the RDEIR process, and EOT will continue to coordinate with
the City of Boston, neighborhood residents, area institutions, and other stakeholders to review the
findings of this conceptual engineering and the implications for future tunnel implementation.
The RDEIR in Chapter 2 starting on page 2-29 included three different tunnel alignment options
between the Fenway Station and the intersection of Longwood Avenue and Brookline Avenue.
The tunnel alignment and options are also depicted and evaluated in RDEIR Chapter 3 and
supporting technical documents. In summary, the options, and the key issues related to them,
are:
•
Western Tunnel Alignment. This option entails a wide tunnel curve that remains beneath
the Emerald Necklace park system until it curves beneath Longwood Avenue. This option has
the advantages of remaining principally beneath public right-of-way; consistency with
construction using either tunnel boring machine or sequential excavation method; and
consistency with future conversion to either light rail or heavy rail technology. The principal
disadvantage of this alignment is that it is the longest route, which results in higher capital
cost.
•
Central Tunnel Alignment. This option entails a tunnel alignment that passes beneath the
Winsor School athletic fields between Fenway Station and the intersection of Longwood
Avenue/Brookline Avenue. This option has the advantages of a shorter tunnel length and
lower cost; consistency with construction using either tunnel boring machine or sequential
excavation method; and consistency with future conversion to either light rail or heavy rail
technology. The principal disadvantage of this alignment is that it passes beneath the Winsor
School property. While construction using a tunnel boring machine would enable construction
with minimal or no surface disruption on Winsor School property, the Winsor School has been
developing a master plan that includes the potential for subsurface construction on the
property beneath the athletic fields.
•
Eastern Tunnel Alignment. The eastern tunnel alignment option entails a tunnel path that
passes beneath the Sears Rotary, Brookline Avenue, and Longwood Avenue. This option has
the advantages of remaining principally beneath public right-of-way and a shorter tunnel
length. However, this tunnel alignment requires very tight curves, which have several
disadvantages: construction limited to sequential excavation method (which could result in
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
high costs and delays depending upon soil condition); substandard tunnel design parameters
that would result in low vehicle speeds and potential vehicle equipment impacts from the tight
curves; and the potential future conversion to rail transit would be limited to light rail
technology.
In addition to the potential impacts of the alternative tunnel alignments, the areas around the
proposed tunnel portals (near the Fenway Station on the D Branch of the Green Line in the north
and in the MBTA-owned transit right-of-way adjacent to Northeastern University near Ruggles
Station in the southeast) would be affected by tunnel construction. Depending on the construction
methodology, one or both of these portal areas could be affected by construction laydown, tunnel
excavate removal, and tunnel boring machine assembly or disassembly. Parcels of land that are
currently available for these temporary functions may not be available at a future time when
tunnel funding and construction may be feasible.
Given the anticipated property and construction impacts of the tunnel, EOT recognizes that the
uncertainty about future tunnel implementation is an issue for property owners who would be
affected by the tunnel portals and the alternative tunnel alignments proposed in the RDEIR.
Therefore, EOT is willing to work with these property owners to minimize the constraints posed by
undefined long-term tunnel needs. These property owners should coordinate with EOT and the
City of Boston on development plans to ensure that they do not preclude future tunnel
construction.
Charles River Crossing/Grand Junction Railroad. The RDEIR proposal for the Urban Ring
Phase 2 alignment between Fort Washington Park in Cambridgeport and Commonwealth Avenue
in Boston would entail a two-way busway in the Grand Junction Railroad alignment from Fort
Washington Park across the Charles River, and a tunnel connection beneath the Boston
University Bridge through the current Boston University Academy site. RDEIR Chapter 2
contains a description of this area of the LPA starting on page 2-19. There are a number of issues
and impediments with this proposal, principally use of the Grand Junction Railroad right-of-way
for frequent BRT operations and availability of the connection through the BU Academy site.
The Commonwealth of Massachusetts’s purchase of the Grand Junction Railroad (GJRR) from
CSX would also help to facilitate implementation of this segment of the Urban Ring Phase 2, as
well as the Northern Tier. However, the Cambridgeport and Charles River crossing proposals
would create BRT busway adjacent to active CSX rail operations. Even though rail traffic on the
Cambridgeport – Charles River crossing segment of the GJRR is quite low, and the
Commonwealth of Massachusetts is expected to own this segment of the GJRR, CSX will still
retain operating rights and EOT would need to negotiate an operating agreement to operate
buses in the right-of-way.
Another critical dependency for the Charles River crossing segment of the Urban Ring Phase 2 is
the connection from the GJRR alignment through a new tunnel beneath the Boston University
Bridge and then through the site currently occupied by the Boston University Academy. The BU
Academy is a private high school owned and operated by Boston University. Boston University
has undertaken a master planning for its campus, with a focus on the central campus area
around the BU Bridge. Through this master planning, BU has indicated an intention to relocate
BU Academy and pursue the creation of a publicly-accessible park space, with connections to the
Charles River Esplanade, on that site. EOT has worked with BU to develop a preferred alignment
for the Urban Ring Phase 2 that is consistent with this master planning; However, implementation
of this connection is dependent upon BU relocating the BU Academy, and the subsequent
provision of Urban Ring Phase 2 access through the site. EOT will continue to work with BU, as
well as other parties that would be involved in developing long-range plans for a park space at the
current BU Academy site, including the City of Boston, Town of Brookline, Department of
Conservation and Recreation (DCR), and others. EOT will also continue to work with these
parties and other stakeholders, including the City of Cambridge and Massachusetts Institute of
Technology, on the Charles River crossing and its approaches.
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Allston Connection. The alignment recommended in the RDEIR for this segment passes in
busway beneath the Massachusetts Turnpike viaduct, through the Beacon Park Yard rail
property, and along the southern edge of Cambridge Street, then connects to the proposed
Stadium Way, Western Avenue, and North Harvard Street. This was one of the options included
in the RDEIR LPA described in Chapter 2 starting on page 2-22
Implementation of this connection is highly dependent upon actions by CSX and Harvard
University, the owner of the property underlying Beacon Park Yard. To get from the BU Bridge
area to the railyard, the busway would need railroad grade crossings of two rail lines, the GJRR
rail line and the active railroad track that accommodates train operations and provides access to
the “teardrop parcel” to the northeast of the main railyard. The GJRR line in this area, as in
Cambridge, is an active line that has relatively low rail traffic, and it may be able to support a
limited use rail grade crossing, subject to coordination with CSX and the Federal Railroad
Administration. However, the lead track for the teardrop parcel has frequent rail movements that
could make a grade crossing difficult to achieve. A busway connection in this alignment
connection, combined with the need for space to create a busway through the main railyard,
would require consolidation and/or relocation of many or all of the various CSX railyard
operations. This consolidation and/or relocation is dependent upon actions by CSX and Harvard
University, as well as actions related to the Commonwealth of Massachusetts’ transaction with
CSX. EOT will continue to coordinate with CSX and Harvard University in order to resolve these
issues.
To the north of Beacon Park Yard, the preferred Urban Ring Phase 2 alignment entails bus lanes
that Harvard University has proposed to provide as part of its Harvard Allston Initiative. This
would include bus lanes in the proposed new “Stadium Way” roadway and along portions of North
Harvard Street. EOT is appreciative of these proposed bus lanes, and will continue to work with
Harvard University, the City of Boston, and neighborhood stakeholders as planning for the
Harvard Allston Initiative progresses.
EOT is committed to advancing Urban Ring Phase 2 Southern Tier project implementation, but must
address the outstanding issues and impediments in the corridor’s Southern Tier. EOT intends to file a
New Starts application with the Federal Transit Administration (FTA) in order to qualify for federal funding
for the Urban Ring Phase 2 project. The implementation proposal in the New Starts application will
depend upon the outcome of the Boston Region MPO RTP and on the financial capacity of the
Commonwealth and the MBTA to fund capital investment and ongoing operations. Nevertheless, EOT will
work with FTA to gain recognition of the full Urban Ring Phase 2 BRT project in the New Starts program.
6.3
Special Review Procedure
The Executive Office of Transportation has undertaken extensive planning and environmental review for
the Urban Ring project, and is pursuing implementation of the project as aggressively as possible, given
the Commonwealth’s financial constraints and its other investment priorities. EOT has also operated
under the terms of the Executive Office of Energy and Environmental Affairs MEPA Special Review
Procedure (SRP), including the deadlines for environmental filings on the Urban Ring Phase 2 and Phase
3.
With the filing of the Urban Ring Phase 2 RDEIR/DEIS, EOT has satisfied the terms of the original
Administrative Consent Order and its subsequent amendments, the documents that established the
requirement for the Urban Ring SRP. Furthermore, the Commonwealth expects to be able to fund only an
initial implementation stage of the Urban Ring Phase 2. As a result, the SRP’s current deadlines for EOT
to file the Urban Ring Phase 2 FEIR/S, as well as the Urban Ring Phase 3 environmental documents, are
infeasible. Therefore, EOT requests that EOEEA provide relief from any further deadlines for filing
environmental documents as required in the MEPA SRP.
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Administrative Consent Order
The Administrative Consent Order (ACO) was signed by the Department of Environmental Protection
(DEP) and the Executive Office of Transportation and Construction (EOTC) on September 1, 2000. The
purpose of the ACO was to formalize the Central Artery Tunnel (CA/T) project’s transit commitments.
These included requirements for planning and environmental review for the Urban Ring, though no
requirements for project implementation. The original ACO established the following requirements for the
Urban Ring project:
1. Complete a Major Investment Study (MIS) and file an Environmental Notification Form (ENF) for
the Urban Ring by June 30, 2001.
2. File the FEIR within three years of the ACO, OR file an Expanded ENF based upon the
recommendations of the MIS and request a Special Review Procedure, with the first phased
review document to be filed within three years of the ACO [by September 1, 2003].
3. In either case, the ENF shall identify a list of the low-cost measures as Phase 1 of the project,
and that list and a schedule for implementation shall be submitted to DEP following the
completion of MEPA review of Phase 1.
The ACO was subsequently amended three times; these amendments clarified the requirements of the
original ACO for the Urban Ring project and updated deadlines, but they did not change the substance of
the original ACO requirements. ACO Amendment #1, issued on May 17, 2002, identified the DEIR/DEIS
as the first phased review document (per requirement #2 above), and extended the deadline for filing it to
November 30, 2004. ACO Amendment #2, issued on January 26, 2005 (after the filing of the Urban Ring
Phase 2 DEIR) required that the MBTA file a DEIS for Urban Ring Phase 2 (to supplement the DEIR),
and extended the DEIS deadline to October 31, 2005. The third and final ACO amendment did not
include any provisions relevant to the Urban Ring project.
EOT’s Compliance with ACO Requirements
In accordance with requirement #1 above, in July 2001, the MBTA completed its MIS on Circumferential
Transportation Improvements in the Urban Ring Corridor and submitted an Expanded Environmental
Notification Form (EENF) to MEPA.
In accordance with requirement #2 above, the MBTA requested in the July 2001 EENF that MEPA
establish a Special Review Procedure.
In accordance with requirement #3 above, the EENF identified low-cost measures from Phase 1 of the
project and a schedule for their implementation. The EENF also noted that “the proposed Phase 1 action
does not require further MEPA review since it is below ENF and EIR thresholds and can be implemented
independently from Phases 2 and 3.”
With the completion of the MIS and EENF in 2001; its identification of low-cost Phase 1 measures and
their proposed implementation schedule; and the EENF’s request for a Special Review Procedure, the
only remaining ACO requirement with regard to the Urban Ring project as of the close of 2001 was the
filing of the first phased review document (identified by MEPA in the SRP as the Phase 2 DEIR/S). The
filing of the Phase 2 RDEIR/S in November 2008 was in compliance with the deadline established
through various ACO amendments and NPCs (see table below). With the March 6, 2009 Certificate,
which stated that the Phase 2 RDEIR/S “adequately and properly complies with MEPA,” EOT has
satisfied all requirements established by the 2000 ACO and its amendments.
As shown in Table 3, EOT (or the MBTA) has met each of the ACO requirements, and the terms in the
subsequent ACO amendments. Table 3 summarizes the progress in meeting the requirements
established through the 2000 ACO and the ACO amendments, as well as the terms of the MEPA Special
Review Procedure.
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Table 3: Administrative Consent Order and MEPA Special Review Procedure History
MEPA/ACO
Document
Original ACO
Urban Ring
MIS/EENF
Certificate
Establishing
Special Review
Procedure
Certificate on
EENF
Date
9/1/2000
New/Changed Urban Ring Filing Requirements
Requirements Addressed
• Complete an MIS and file ENF for Urban Ring by 6/30/2001.
• ENF to identify a list of low cost Phase 1 measures and that list
and a schedule for implementation shall be submitted to DEP
following the completion of MEPA review of Phase 1.
• File FEIR *OR* EENF and request a SRP with the first phased
review document filed by 9/1/2003
7/2001
• Phase 2 DEIR/S to be filed by 8/31/2003 as required by the
9/1/2000 ACO. The scope for the EIR is detailed in the
Certificate on the EENF referenced below.
• Phase 2 FEIR/S, to be filed by 10/31/2005.
• Phase 3 DEIR/S, to be filed by 10/31/2007. The scope for this
filing to be determined.
• Phase 3 FEIR/S, with deadline to be determined.
11/16/2001 • Prepare an EIR consistent with the schedule outlined in the
11/9/2001 Certificate.
11/9/2001
ACO
Amendment #1
5/17/2002
Urban Ring
Phase 2 DEIR
ACO
Amendment #2
11/30/2004
MBTA Letter to
EOEEA
Certificate on
DEIR
5/18/2005
NPC on
modifying the
SRP
EOT Letter to
EOEEA
8/31/2005
1/26/2005
5/20/2005
9/8/2005
ACO requirement that an SRP
be established is met.
ACO requirement that an ENF be
filed is met.
ACO requirement that a list of
low cost Phase 1 measures be
included in the ENF is met.
No environmental review of
Phase 1 is required.
• After public comment on the Amendment, DEP approved an
extension to the Phase 2 DEIR/S deadline. This deadline was
subsequently extended to 11/30/2004.
• EOT must submit status reports by 3/1/2005 containing detailed
project schedules, benchmarks and milestones, and appropriate
documentation to demonstrate that the DEIS will be completed
by 10/31/2005.
• Pending acceptance by FTA of its draft modeling proposal, the
DEIS will be submitted by 10/31/2005, provided the
Commonwealth has identified the source of the 50% non-federal
share as required by FTA
• MBTA informs EOEEA of intent to re-link MEPA and NEPA with
submittal of RDEIR/DEIS
• Require MBTA submission of an NPC by 9/1/2005 describing
proposed changes to the SRP established in 11/9/2001
Certificate with the intent of reestablishing coordinated review
under both MEPA and NEPA.
• NPC should propose new filing dates for the RDEIR/DEIS (scope
provided in Certificate) and the FEIR/FEIS for Phase 2, as well
as the DEIR/SEIS for Phase 3.
• NPC should describe proposed changes to membership of CAC.
DEIR Certificate requirement to
submit NPC which proposes new
filing dates by 9/1/2005 is met.
• RDEIR/DEIS will be directed by EOT/OTP.
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NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
Table 3: Administrative Consent Order and MEPA Special Review Procedure History (cont’d)
MEPA/ACO
Date
New/Changed Urban Ring Filing Requirements
Document
Certificate on NPC 11/17/2005 • RDEIR/DEIS for Phase 2 by 11/30/2007
modifying SRP
• FEIR/S for Phase 2 by 12/31/2008
• DEIR/S for Phase 3 by 12/31/2010
• FEIR/S for Phase 3 by deadline to be determined jointly by
EOEA and FTA.
• Require that any extension to established deadlines be the
subject of a separate NPC.
• Require the submission of twice yearly progress reports: 9/30
2006, and 3/31 and 9/30 of 2007, 2008, 2009, and 2010.
Progress report deadlines beyond 2010 to be determined in
Phase 2 DEIR/DEIS Certificate.
ACO Amendment 12/13/2006 (Nothing on Urban Ring)
#3
NPC on modifying 6/11/2007
the SRP
Certificate on NPC 7/11/2007 • RDEIR/S for Phase 2 by 5/31/2008
modifying SRP
• FEIR/S for Phase 2 by 6/30/2009
• DEIR/S for Phase 3 by 6/30/2011
• FEIR/S for Phase 3 by deadline to be determined jointly by
EOEA and FTA.
• Require that any extension to established deadlines be the
subject of a separate NPC.
• Require the submission of twice yearly progress reports: 9/30
2007, and 3/31 and 9/30 of 2008, 2009, 2010, and 2011.
Progress report deadlines beyond 2011 to be determined in
Phase 2 DEIR/DEIS Certificate.
NPC on modifying 4/23/2008
the SRP
Certificate on NPC 5/30/2008 • RDEIR/S for Phase 2 by 11/30/2008
modifying SRP
• FEIR/S for Phase 2 by 12/31/2009
• DEIR/S for Phase 3 by 12/31/2011
• FEIR/S for Phase 3 by deadline to be determined jointly by
EOEA and FTA.
• Strongly suggest that EOT submit its New Starts application
early in 2009.
• Require that any extension to established deadlines be the
subject of a separate NPC.
• Require a project schedule for remainder of 2008 by 6/30/2008.
• Require the submission of twice yearly progress reports: 9/30
2008, and 3/31 and 9/30 of 2009, 2010, and 2011. Progress
report deadlines beyond 2011 to be determined in Phase 2
DEIR/DEIS Certificate.
Urban Ring Phase 11/2008
2 RDEIR/DEIS
Certificate on
3/6/2009
• Requires NPC by 6/30/2009 that identifies early action items,
RDEIR/DEIS
address status of measures that can be undertaken in near term
to advance early action items, overview of overall project
phasing.
• Waived 3/31/2009 progress report requirement.
Urban Ring Phase 2 RDEIR Notice of Project Change
Requirements Addressed
ACO requirement for the first
phased review document
(RDEIR/DEIS) and SRP
deadline for RDEIR/DEIS are
met.
Page 33
June 2009
NOTICE OF PROJECT CHANGE FORM AND ATTACHMENTS
MEPA Special Review Procedure
On November 9, 2001, in response to the request in the July 2001 EENF, the Secretary of EOEA issued
a “Certificate Establishing a Special Review Procedure.” The Certificate included deadlines for
compliance with the ACO requirements in addition to subsequent filings. The initial schedule (as
amended in subsequent NPCs as shown in the table above) directed the MBTA to prepare the following
four phased review documents:
•
•
•
•
Phase 2 DEIR/S to be filed by 8/31/2003 as required by the 9/1/2000 ACO. The scope for the EIR
is detailed in the Certificate on the EENF referenced below.
Phase 2 FEIR/S, to be filed by 10/31/2005.
Phase 3 DEIR/S, to be filed by 10/31/2007. The scope for this filing will be defined through a
future coordinated MEPA/FTA process.
Phase 3 FEIR/S, to be filed on a subsequent date, yet to be determined.
On November 16, 2001, the Secretary issued a Certificate on the EENF that determined the Urban Ring
project required the preparation of an EIR, as defined in the November 9, 2001 Certificate on the SRP.
The SRP was modified by three subsequent Certificates. None of the Certificates changed the program of
environmental review filings, but only the deadlines associated with those filings. The Certificate of
November 17, 2005 extended the RDEIR/DEIS deadline to November 30, 2007. The Certificate of July
11, 2007 extended the RDEIR/DEIS deadline to May 31, 2008. The Certificate of May 30, 2008 extended
the RDEIR/DEIS deadline to November 30, 2008. Details on other deadline changes from these
Certificates are available in the table above.
Therefore, EOT has satisfied the ACO commitments for the Urban Ring project. Because the outstanding
deadlines are those established by the MEPA SRP, they can be revised through the MEPA SRP.
Conclusion
The Boston Region MPO RTP, to be finalized during the summer of 2009, is not expected to include
either the full Urban Ring Phase 2 LPA or Phase 3. EOT intends to pursue funding through the Boston
MPO RTP process for partial implementation of Urban Ring Phase 2, in accordance with the
implementation plan described above. Furthermore, the Commonwealth of Massachusetts and the MBTA
face significant financial challenges to operating the existing transit system and funding transit expansion
projects whose implementation (rather than environmental filings) are requirements of the ACO and the
State Implementation Plan (SIP). Despite these other major commitments, EOT has continued to
aggressively pursue the Urban Ring Phase 2 project in order to define the best possible transit system
improvement program within the current financial environment.
To advance the full Urban Ring Phase 2 FEIR or any Urban Ring Phase 3 planning or environmental
review documents in the current funding context would be of no utility. With this NPC, EOT is indicating its
intention to pursue final environmental review on the Urban Ring Phase 2 – Northern Tier, and to pursue
final environmental review of major elements in the Southern Tier when outstanding issues have been
resolved and funding is available. No schedule can currently be given for planning and environmental
review for Urban Ring Phase 3 that would allow these environmental review filings to remain relevant.
Therefore, given the lack of funding certainty even for the advancement of the full Urban Ring Phase 2,
and EOT’s compliance with all mitigation requirements of the 2000 ACO and its amendments, EOT
respectfully requests that MEPA alter the SRP to eliminate all future deadlines. EOT intends to continue
working with the Boston Region MPO, FTA, the Urban Ring Citizens Advisory Committee, and other
stakeholders to further the implementation of the Urban Ring Phase 2, in accordance with the above
implementation plan, based on good planning and transportation finance practice.
Urban Ring Phase 2 RDEIR Notice of Project Change
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June 2009
RESPONSE TO COMMENTS ON RDEIR 6.4 Response to Comments
Urban Ring Phase 2 RDEIR Notice of Project Change
Page 35 June 2009
RESPONSE TO COMMENTS ON RDEIR 6.4
Response to Comments on RDEIR
The March 6, 2009 EEA Certificate on the RDEIR states “…the NPC should include a copy of each
comment letter (with the exception of the many form letters received on behalf of the Winsor School) and
thoroughly respond to each substantive comment received.” Because the RDEIR was part of a joint
RDEIR/DEIS document, the comments and responses include those of the federal EPA. For purposes of
the NPC all references to the document are to the RDEIR.
Comment letters and e-mail printouts were assigned an identification letter based on the type of
organization submitting the comment, and then arranged in alphabetical order within each category.
Copies of the original letters are provided along with the responses. Substantive comments are
reproduced below with corresponding responses. Some comments have been paraphrased to save
space and those that are reproduced verbatim are shown in quotation marks
The comments and responses are organized into the following categories:
Category
A
B
C
D
E
F
G
H
I
Description
Certificate on the RDEIR
Federal Agencies
State Agencies
Regional Agencies and Authorities
Municipal
Community Advocacy Organizations
Institutions
Elected Officials
Individuals
ID#
A
Comment or document
Page
Certificate of the Commonwealth of Massachusetts Secretary of
Energy and Environmental Affairs………………………………………………….... 4
A-1
Certificate on the Revised Draft Environmental Impact Report (RDEIR)
B
B-1
Response to Federal Agency Comments
United States Environmental Protection Agency ……………………………………….. 8
C
C-1
C-2
C-3
C-4
C-5
C-6
Response to State Agency Comments
Massachusetts Department of Conservation and Recreation……………………….....11
Massachusetts Department of Environmental Protection Northeast Regional
Office………………………………………………………………………………… ……...14
Massachusetts Department of Public Health, Bureau of Environmental Health.……..15
Massachusetts Historical Commission………………..………………..…………….…...16
Massachusetts Office of Coastal Zone Management………………..………….. ……...17
Citizens Advisory Committee……………………………………………………………….18
D
D-1
D-2
D-3
Response to Regional Agency and Authority Comments
Metropolitan Area Planning Council……………………………………………………….19
Massachusetts Port Authority………………………………………………………………22
Massachusetts Water Resources Authority………………………………………………28
E
E-1
E-2
E-3
Response to Municipal Comments
Boston Environmental Department……………………………………………………… 29
Boston Redevelopment Authority……………………………………………………….. 31
Boston Parks and Recreation Department……………………………………………. 36
Introduction and Group A
Page 1
RESPONSE TO COMMENTS ON RDEIR E-4
E-5
E-6
E-7
E-8
E-9
Brookline Board of Selectmen…………………………………………………………… 45 Brookline Preservation Commission……………………………………………………. 48 City of Cambridge, Executive Department……………………………………………… 49 Cambridge Redevelopment Department………………………………………………. 52 City of Chelsea, Department of Planning and Development………………………… 53 City of Somerville, Office of Mayor……………………………………………………… 54 F
F-1
F-2
F-3
F-4
F-5
F-6
Response to Community Advocacy and Organization Comments
A Better City…………..……………………………………………………………………. 57 Alternatives for Community and Environment………………………………………...…58 Association for Public Transportation …………………………………………………… 62 Audubon Circle Neighborhood Association …………………………………………….. 65 Bike to the Sea, Inc…………………………………………………………………………66 Charles River Watershed Association…………………………………………………… 68 F-7
F-8
F-9
F-10
F-11
F-12
Emerald Necklace Citizens Advisory Committee……………………………………… 69 Fenway Civic Association………………………………………………………………… 71 Fenway Community Development Corporation………………………………………... 72 Sierra Club………………………………………………………………………………..... 73 The Fenway Alliance……………………………………………………………………… 78 Walk Boston…………………………..……………………………………………........... 80 G
G-1
G-2
G-3
G-4
G-5
G-6
G-7
G-8
G-9
G-10
G-11
G-12
Response to Institution Comments
Beth Israel Deaconess Medical Center……………………………………………….. 81 Boston University………………………………………………………………………… 84 Children’s Hospital Boston………………………………………………………………. 85 Harvard University……………………………………………………………………….. 87
Isabella Stewart Gardner Museum…………………………………………………….. 90 Massachusetts Institute of Technology, Department of Facilities………………….. 91 Medical Academic and Scientific Community Organization………………………….. 96 Partners HealthCare System…………………………………………………………… 103 University of Massachusetts Boston…………………………………………………… 109 Wentworth Institute of Technology…………………………………………………….. 110 Wheelock College……………………………………………………………………….. 115
Winsor School……………………………………………………………………………. 118 H
H-1
H-2
H-3
Response to Public Official Comments
Representative Frank I. Smizik ………………………………………………………… 122 Senator Anthony D. Galluccio ………………………………………………………….. 124 Senator Anthony Petruccelli …………………………………………………………… 125 I
I-1
I-2
I-3
I-4
I-5
I-6
I-7
I-8
I-9
I-10
I-11
I-12
I-13
I-14
Response to Individual Comments
Alan Moore
……………………………………………………………………………126 Arshag A. Mazmanian…………………………………………………………………….128 Arshag A. Mazmanian…………………………………………………………………….134 Arshag A. Mazmanian…………………………………………………………………….135 Christiana Fischer……………………………………………………………………….. 136 Craig A. Kelley…………………………………………………………………………… 137 Ellen Reisner, PhD………………………………………………………………………. 139 Fred Salvucci…………………………………………………………………………….. 141 Joel N. Weber II ………………………………………………………………………… 142 John F. Burckardt, PE…………………………………………………………………… 144 Karen Wepsic…………………………………………………………………………….. 150
Kenneth J. Krause……………………………………………………………………….. 155 Mark Sutherland………………………………………………………………………….. 156 Marilyn Wellons………………………………………………………………………….. 159 Introduction and Group A
Page 2 RESPONSE TO COMMENTS ON RDEIR I-15
Michael S. Dukakis………………………………………………………………………. 161 I-16
Rob Kassel…….…………………………………………………………………………. 162 I-17
Robert J. La Tremouille ………………………………………………………………... 163 I-18
Shirley Kressel…………………………………………………………………………… 174 I-19
Wig Zamore……………………………………………………………………………… 175 I-20-1 through I-20-6 Form letters in support of Winsor School…………………………………..177 An annotated copy of the RDEIR Certificate (A-1) and comment letters B-1 through I-20 are
provided starting after the Response to Comments
Introduction and Group A
Page 3 RESPONSE TO COMMENTS ON RDEIR Letter ID No.: A-1.1
Received from: MEPA Certificate
March 6, 2009
Comment No.
A-1.1 Comment
“I am directing the proponent (EOT) to submit a Notice of Project Change to identify
early action items and address issues pertaining to the phasing, financing, timing of
construction, and implementation of the overall project.”
Response
The June 30, 2009 Notice of Project Change (NPC) identifies and addresses the listed
items and issues.
A-1.2 Comment
“The RDEIR laid out an approximate timeframe for advancement of Phase 2, with
commencement of construction anticipated around 2015. The RDEIR did not propose
a completion date for Phase 2, nor did it anticipate when construction would
commence on Phase 3, in which rail service would be implemented along the most
heavily traveled portions of the Urban Ring corridor.”
Response
As described in Attachment 6, Sections 6.2 of the NPC, EOT intends to implement the
Urban Ring Phase 2 in stages, the first of which is recommended to be the “Northern
Tier” between Logan Airport and Kendall Square serving Boston, Chelsea, Everett,
Somerville, and Cambridge. In the Southern Tier (the project alignment outside of the
Northern Tier) of the corridor, potential early actions have been identified. The NPC
also identifies major infrastructure elements of Urban Ring Phase 2 in the Southern
Tier that cannot be implemented until significant impediments and outstanding issues
can be addressed. The schedule for Urban Ring Phase 3 is uncertain due to the
extremely high capital costs that would be associated with that phase, and the
Commonwealth of Massachusetts’ inability to identify resources to implement such a
project within a reasonable planning horizon.
A-1.3 Comment
“The RDEIR did not resolve all routing issues and identifies three alternative
alignments for the tunnel and a series of alternative routes through the City of
Cambridge to Boston University and Allston.
“The lack of a preferred alignment for these important segments raises the question of
whether EOT can adhere to the schedule for the environmental review of the project as
a whole, as currently prescribed in SRP. I note that under NEPA, the Federal Transit
Administration (FTA) requires that the Final Environmental Impact Statement (FEIS)
reflect preliminary engineering for the project. Because federal and state
environmental review are coordinated under the SRP – meaning that the FEIS and
FEIR documents are the same – the requirement for the FEIS would extend to the
FEIR to be reviewed under MEPA. Given that the SRP currently requires the
submission of the FEIR/FIES by December 31, 2009, this would appear to dictate that
EOT undertake and complete the work necessary to select preferred alignments as
soon as practicable during 2009.”
Introduction and Group A Page 4
RESPONSE TO COMMENTS ON RDEIR Response
Refer to the NPC Attachment 6, Section 6.3, which proposes changes to the MEPA
Special Review Procedure (SRP) that has established deadlines for Urban Ring
environmental filings.
A-1.4 Comment
“The commencement of preliminary engineering will require approval from the FTA,
through the submission of a New Start application. In the Certificate on the NPC issued
on May 30, 2008, I strongly encouraged EOT to submit a New Start Application within
a time frame that would allow FTA to grant approval and then complete and submit an
FEIR/FEIS by December 1, 2009, that would be based on and informed by preliminary
engineering. Although FTA will accept 2009 New Start applications up to September of
this year, a fully reviewed FEIR/FEIS based on preliminary engineering would seem to
require that the New Start application be submitted well before that date.”
Response
EOT expects to submit an application to the FTA for the Urban Ring Phase 2 project
when financial and regulatory conditions allow. On September 30, 2009, the federal
Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users
(SAFETEA-LU) will expire, after which federal transportation funding is expected to
undergo a major restructuring as part of the new six-year federal transportation
authorization replacing it. Criteria and guidelines for the FTA New Starts program may
be more favorable to advancing and funding new transit projects than they are under
the current New Starts program.
A-1.5 Comment
“The New Start application must also include project funding and implementation
plans…. No significant progress was made on these plans during the development of
the RDEIR.”
Response
Any Urban Ring Phase 2 New Starts application will include identification of project
funding sources and implementation schedule in accordance with applicable New
Starts program guidelines in effect at that time.
A-1.6 Comment
“EOT should identify early action items that could result in the implementation of some
components of the Urban Ring would yield tangible benefits to the entire transit
system. Once identified, EOT could initiate engineering studies and permitting
processes by taking advantage of resources in the recently enacted transportation
bond bills and anticipated federal surface transportation funding reauthorization.”
Response
Early action items are described in the NPC Attachment 6 (Section 6.2). A-1.7 Comment
“A realistic assessment of the schedule for both the remaining environmental review
and implementation of the Urban Ring is in order.”
Response
Refer to the NPC Attachment 6 (Section 6.2). Introduction and Group A Page 5
RESPONSE TO COMMENTS ON RDEIR A-1.8 Comment
“Several key elements of the project remain in flux and would likely be refined as
planning for the project proceeds. Recognizing that the full build-out of the project
could take many years, with some components likely to commence construction well
after 2015, I do not believe that it is possible to issue a meaningful scope at his time. In
fact, to do so would undermine the express requirements of the MEPA regulations
mandating that environmental review occurs within a timeframe that is proximate to the
commencement of construction of a project…. I believe it would be more constructive
to advance those components of the project that could be implemented in the short
term, especially those elements that could proceed prior to the anticipated 2015
commencement for the entire project.”
Response
The recommended Phase 2, Stage 1 Northern Tier represents a major portion of the
overall project that has independent utility and would yield substantial transportation
benefits. Moreover, the alignment is clearly defined and the key engineering and
environmental issues are known and described in the RDEIR/DEIS. Additionally,
targeted infrastructure investments have been identified in other areas of the corridor
that have the potential to move forward in the short-term and provide benefits. Refer to
Attachment 6 (Section 6.2) of the NPC for additional details.
A-1.9 Comment
“It is imperative that EOT identify these early action items and provide some specificity
regarding their financing, construction schedule, and implementation….because the
monitoring reports would not be subject to a full public review under MEPA, but rather
published in the Environmental Monitor for informational purposes only, I am directing
EOT to submit a NPC by June 30, 2009….These early action items could entail actual
implementation of BRT service along a section of the Urban Ring corridor, or
operational improvements to existing bus routes that would advance the goals of the
project, such as those listed on page 1-16 of the RDEIR. Additionally, the NPC should
also address the status of measures that can be undertaken in the near term to lay the
groundwork for the project, with the acquisition of the CSX right-of-way in Chelsea and
Everett as but one notable example identified by A Better City (ABC) in its comments.
“….I strongly encourage EOT to identify engineering tasks that can be accomplished in
the near term to advance these early action items…. ABC states that it is preparing a
report that will suggest how to use funds made available for the Urban Ring and
related projects funding reauthorization for design, phased construction, and
operations. I encourage EOT to consider the recommendations in this report, which
may provide realistic timelines and costs to plan, design, permit, implement and
operate the Urban Ring Phase 2 project in manageable stages.”
Response
EOT has reviewed the report materials prepared by ABC and considered them in
development of the NPC implementation plan contained in Attachment 6 (Section 6.2).
EOT’s intended approach is to focus on full implementation of the substantial Northern
Tier between Logan Airport and Kendall Square as the first stage of Urban Ring Phase
2 implementation. The NPC implementation plan also identifies a number of potential
early actions in the Southern Tier. These potential “early actions” include infrastructure
investments that entail low costs and minimal environmental impacts, and that could
offer potential independent benefits.
Introduction and Group A Page 6
RESPONSE TO COMMENTS ON RDEIR A-1.10
Comment
“I do not wish to minimize the importance of maintaining progress in resolving the
remaining issues related to the larger project…. The NPC should also provide an
overview of overall project phasing and implementation, including a schedule for
resolving the key remaining technical, routing and implementation issues. This will
facilitate the establishment of a realistic schedule for the remaining environmental
review.”
Response
Refer to NPC Attachment 6 (Section 6.2). A-1.11
Comment
“The information presented in the NPC should be based on a comprehensive
assessment of the comments submitted in response to the RDEIR, as well as
continued consensus-building with the CAC.”
Response
All comments submitted in response to the RDEIR were reviewed and considered, and
EOT met with the CAC in April and June of 2009; the CAC Alternatives Subcommittee
in May 2009; and with various project stakeholders, to resolve issues and build
consensus on the project implementation plan.
A-1.12
Comment
“The NPC should include a copy of each comment letter (with the exception of the
many form letters received on behalf of the Winsor School) and thoroughly respond to
each substantive comment received.”
Response
This Attachment 6 (Section 6.4) of the NPC includes a copy of each comment letter
and responses.
A-1.13
Comment
“I expect EOT to continue working with the CAC and other stakeholders to resolve
outstanding issues related to the final identification of a locally preferred alternative for
the entire project corridor. This is particularly important in areas of the corridor, such as
Melnea Cass Boulevard in Boston, where the City is engaged in redevelopment efforts
that presume the right-of-way modifications presented as part of the locally preferred
alternative in the RDEIR.”
Response
EOT met with the CAC in April and June of 2009; the CAC Alternatives Subcommittee
in May 2009; and with various project stakeholders, to resolve issues and build
consensus on the project implementation plan. Melnea Cass Boulevard is identified in
Attachment 6 (Section 6.2) as a potential early action in the Southern Tier of the
corridor.
A-1.14
Comment
[I] “urge EOT to complete the work required in order to submit the NPC in a timely
fashion, which shall be no later than June 30, 2009.”
Response
EOT has completed and filed the NPC in accordance with the Certificate. Introduction and Group A
Page 7
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: B-1
Received from: United States Environmental Protection Agency
February 9, 2009 Comment No.
B-1.1 Comment
“The Urban Ring Phase 2 transit project is included in Boston Metropolitan Planning
Organization’s conforming Long Range Transportation Plan (TP). As construction is
proposed to start between May 2015 and May 2016, (page ES-43, November 2008
plus 6.5 to 7.5 years), this project is not within the timeframe of the current Boston
Transportation Improvement Program.”
Response
The approach recommended by EOT, which is described in Attachment 6 (Section 6.2) of the June 30, 2009 NPC, is to focus first on implementation of the substantial Northern Tier between Logan Airport and Kendall Square as the first stage of Phase 2. As discussed in Attachment 6 (Section 6.2) of the NPC, EOT is committed to
advancing Urban Ring Phase 2 Southern Tier project implementation, including early
actions on service and infrastructure improvements, but EOT first must address the
outstanding issues and impediments related to several major infrastructure elements in
this section of the corridor. EOT intends to file a New Starts application with the
Federal Transit Administration (FTA) in order to qualify for federal funding for the
Urban Ring Phase 2 project. The implementation proposal in the New Starts
application will depend upon the outcome of the Boston Region MPO RTP and on the
financial capacity of the Commonwealth and the MBTA to fund capital investment and
ongoing operations. Nevertheless, EOT will work with FTA to gain recognition of the
full Urban Ring Phase 2 BRT project in the New Starts program.
B-1.2 Comment
“The FEIS should clearly identify the length of the Urban Ring Phase 2 construction
period, indicating when this transit project would be completed, and predicting when
transportation benefits from this phase can be assumed…. On page 6-4, the DEIS
indicates an assumption that construction would start in 2015 with an opening year
2020. The DEIS air quality analysis, however, examines the horizon year 2030, but
fails to address any intermediate years. Depending on the length of the construction
period, we believe it may be appropriate to evaluate an interim year between the end
of construction and the 2030 horizon year. Also, as this transit project is located within
the Boston Carbon Monoxide Attainment Area with a maintenance plan, a project level
conformity determination will require a hot-spot carbon monoxide microscale air quality
analysis to evaluate current year (baseline), operational year(s), and design (horizon)
year. The DEIS currently evaluates only the current year 2000/2006 and a horizon year
2030.”
Response
See Response to ABC Comment F-1.3 regarding schedule and phasing to be
identified in the FEIR/FEIS.
The analysis year of 2030 was selected to be consistent with the MPOs’ travel demand
model projections, which did not include interim year traffic projections. The need to
perform hot-spot carbon monoxide microscale air quality analysis will be considered
and addressed in the FEIR/FEIS.
Group B - Response to Federal Agency Comments on RDEIR/DEIS Page 8
RESPONSE TO COMMENTS ON RDEIR B-1.3 Comment
“We commend the EOT commitment to retrofit off-road diesel construction equipment
and to use low-sulfur diesel fuel (DEIS page ES-33) and recommend that this
commitment be included as a requirement in the FTA Record of Decision for the
project. The commitment is consistent with the Administrative Consent Order (ACO­
BO-00-7001) entered into by the Massachusetts Department of Environmental
Protection and the Massachusetts Executive Office of Transportation on January 26,
2005 (and its Amendments). The Consent Order requires EOT to implement a
construction equipment retrofit program and retrofit equipment with emission control
technologies such as oxidation catalysts and particulate filters for large Massachusetts
Highway Department and Massachusetts Bay Transportation Authority funded
projects.
“EOT should make a commitment to use state-of-art buses in the BRT system. In addition to the use of hybrid electric propulsion systems for BRT buses, we also
encourage EOT to investigate additional energy can be saved through the use of energy saving regenerative braking systems.” Response
Comment noted. EOT will comply with the construction equipment retrofit program. EOT will consider all state-of-the-art technology for BRT buses as the project
advances, including regenerative braking systems.
B-1.4 Comment
“We recommend that the FEIS include a quantification/discussion of the existing
carbon/greenhouse gas footprint of the project area to be served by the Urban Ring
project and estimate how the footprint may change as a result of the proposed BRT
system. We also encourage FTA to develop a FEIS that includes a discussion of
measures that can be incorporated in the project to avoid, minimize and mitigate for
greenhouse gas emissions associated with secondary development that may follow
the implementation of the various transportation options.”
Response
As the project will reduce vehicle trips in the region it is expected that the
carbon/greenhouse gas footprint impacts will be positive. This issue as well as
secondary development impacts will be considered and addressed in the FEIR/FEIS.
B-1.5 Comment
“We also suggest that the FTA consider standards and guidelines for the project that
promote “green building” strategies and goals consistent with the Leadership in Energy
and Environmental Design (LEED) Green Building Rating System for proposed
stations associated with the alternatives. These standards would provide requirements
for building designs that conserve energy, use recycled materials and include BMPs
such as green roofs, rain gardens, and cisterns for capturing rain for potential reuse or
delaying its release as storm water runoff. The use of energy efficient “dark skies”
complaint lighting fixtures should also be required for the project where lighting is
anticipated.”
Response
EOT will seek to utilize LEED and other best practices in green building strategies as
the project advances.
Group B - Response to Federal Agency Comments on RDEIR/DEIS Page 9
RESPONSE TO COMMENTS ON RDEIR B-1.6 Comment
“The EIS should also describe whether opportunities exist for clean and renewable
energy generation in association with the project. At a minimum, the discussion should
explain how the proposed project will not preclude future development of renewables
in the project corridor.”
Response
Comment noted. B-1.7 Comment
“Although we strongly agree with the conclusion in Sections 5.1.2.2 and 7.2.1 that the
Urban Ring Phase 2 project is consistent with state and regional smart growth goals by
better serving existing communities with transportation infrastructure, the FEIS should
be expanded to include an analysis of secondary and cumulative effects of the
alternatives. We encourage FTA and EOT to work closely with us to develop an
appropriate scope for this analysis to correct this deficiency in the DEIS.”
Response
EOT will coordinate with FTA, USEPA, and relevant state agencies to address
secondary and cumulative effects in the FEIR/FEIS.
B-1.8 Comment
“We continue to recommend that meeting announcements be communicated via ethnic
media (radio, websites, newspapers) to enhance future public participation in the
affected communities and that all documents be translated in appropriate language(s),
and copies made available via public libraries and community centers.”
Response
EOT distributes meeting announcements widely, using the following tools:
•
•
•
•
media advisories to all regional media in the Metropolitan Area, including
WUNR and La Semana, among other popular non-English media;
emails to the entire project database, which includes community groups,
elected and municipal officials, libraries, neighborhood organizations and
interested members of the public;
translations of the project fact sheet into Spanish;
postal notices to several hundred individuals and to the organizations, groups
and entities listed above, including a recommendation/provision to request a
translation of the notice or a document in Spanish and Portuguese, for project
milestone meetings.
The team will continue to seek other ethnic media to distribute project information and
announce meetings.
Group B - Response to Federal Agency Comments on RDEIR/DEIS Page 10
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-1
Received from: Massachusetts Department of Conservation and Recreation
February 10, 2009
Comment No.
C-1.1 Comment
“While permanent impacts are addressed, DCR notes that interim and temporary
construction impacts are not. The undefined interim impacts are of particular concern
because they have the potential to persist for undefined periods of time.
“…the LPA assumes that there is a newly constructed underpass at Wellington Circle
providing a through movement for east-west traffic. DCR notes this major infrastructure
project is not currently designed, permitted or funded, yet the effective functioning of the
BRT is dependent upon it. The FEIR needs to address the impact if the underpass is not
constructed in time, or not at all, to meet the Urban Ring time frame.”
Response
Refer to Chapter 5 page 5-65 and Chapter 3 page 3-103 of the RDEIR and background
technical reports referenced there for discussion of construction phase noise and
vibration throughout the corridor and construction phase impacts of the LPA tunnel.
Refer to NPC Attachment 6 (Section 6.1) regarding the recommended alignment change
to avoid Wellington Circle by using the Route 99 corridor.
C-1.2 Comment
“DCR notes that the tunnel costs could be problematic and may prevent completion of
the tunnel. As a result, if the tunnel is planned but not ultimately constructed, DCR is
concerned that surface routing of the BRT will occur on the Emerald Necklace Parkways
on a long term basis. A surface route that proposes use of the Emerald Necklace
Parkways would be a significant adverse impact on park and parkway resources…. DCR
strongly suggests that a full discussion of these interim impacts and alternatives needs to
be included as part of the LPA analysis during MEPA review.
“The phasing of the Urban Ring should include the tunnel as a priority phase, and
perhaps as the initial phase of the implementation program.”
Response
Potential interim surface alignments in the Fenway /Longwood Medical and Academic
Area were analyzed extensively and reviewed comprehensively with the City of Boston,
neighborhood residents, education, medical and cultural institutions, and other
stakeholders throughout development of the RDEIR. Allowing Urban Ring BRT buses on
Emerald Necklace Parkways was discussed in this process, but not included as a
recommendation in the RDEIR (see pages 4-94 and 4-95).
Refer to NPC Attachment 6 (Section 6.2.2) regarding the Fenway/LMA tunnel.
C-1.3 Comment
“The RDEIR also suggests that all park impacts are “de minimus” in nature. DCR does
not concur with that proposed finding set forth in the compliance/consistency chapter (pp
7-1 to 7-21). In addition, there is no draft Section 61 finding by DCR presented for
review. The FEIR should include a draft Section 61 finding by DCR.”
Group C - Response to State Agency Comments
Page 11
RESPONSE TO COMMENTS ON RDEIR Response
Draft Section 61 is contained in Chapter 7 of the RDEIR starting on page 7-22. Park impacts and related issues will be further reviewed in the FEIR and related
environmental filings as the project advances.
C-1.4 Comment
“Parkland replacement should be consistent with the EOEEA Land Disposition Policy
which has the stated goal of ensuring no-net-loss of Article 97 land under the care and
control of the Commonwealth. The policy requires that land of equal or greater value and
acreage is protected in exchange for public conservation land that is transferred to the
Proponent for transportation purposes. The proponent should consult with DCR on
appropriate mitigation in this that would be acceptable to DCR.”
Response
EOT will coordinate with DCR on appropriate mitigation as required for public
conservation land.
C-1.5 Comment
“Segment B includes Cambridge, Brookline and Roxbury and affects both park and
parkway resources. Discussion of the Charles River crossing impacts on the water sheet
of the river should be included on pp. 5-145 and 5-146, as this is both a temporary
construction impact and a permanent impact as the bridge doubles in width.
Alternatives to the route parallel to Soldiers Field Road west should also be further
explored.”
Response
The LPA Charles River crossing in the RDEIR/DEIS is described in Chapter 2 pages 2­
20 and 2-21and depicted in plan view on Sheet 25A of the supporting conceptual
drawing set. Conceptual engineering indicates the modified rail bridge, which would
include BRT and a pedestrian/bike path, would involve 40-50% widening of the existing
bridge, which is far less than doubling the width (i.e. 100% increase). Charles River
crossing impacts on the water sheet of the river will be defined in greater detail in the
FEIR.
Subsequent to the filing of the RDEIR/DEIS additional analysis of BRT routing options
west from the BU bridge to Allston has identified an alignment with little or no impact on
the narrow passive parkland adjacent to the south side of Soldiers Field Road. This
alignment, which was developed after exhaustive analysis of what EOT considers to be
all feasible alternatives, will be further developed and reviewed in subsequent
environmental filings.
C-1.6 Comment
“Segment C includes Roxbury, Dorchester and South Boston and affects both park and
parkway resources. The impact of the BRT on Columbia Road must be more fully
evaluated as the DCR portion of this roadway is now functionally one through lane and
one parking lane. The BRT route through Kosciuszko Circle and the use of sections of
Day Boulevard and Morrissey Boulevard is also problematic. The impact of this route
should be assessed in the light of current City of Boston (BRA) planning for Columbia
Point and the MBTA plans for transit-oriented development at JFK/UMASS station.”
Group C - Response to State Agency Comments
Page 12
RESPONSE TO COMMENTS ON RDEIR Response
Intersections along Columbia Road will be reviewed in future environmental review
documents for this project. Revisions to alignments in this area will be reviewed and
considered.
C-1.7 Comment
“DCR requests that general traffic parkways be referred to as such and not as “truck
routes” (see Table 5-43) to avoid confusion.
“DCR also requests that in the FEIR the EOEEA Land Policy for any conversion of
parklands to non-park use be more fully described or attached in full for clarity.”
Response
Comment noted. The FEIR and future environmental review documents for this project
will make the distinction between general traffic parkways and truck routes. These
documents will also clearly describe any conversion of parklands to non-park use.
Group C - Response to State Agency Comments
Page 13
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-2
Received from: Massachusetts Department of Environmental Protection Northeast Regional
Office
February 10, 2009
Comment No.
C-2.1 Comment
“The FEIR should affirm that direct impacts are negligible or identify the wetlands
resource types that would be impacted within the LPA corridor, show the general
locations of the impacts on plans, and demonstrate that the performance standards in
the wetlands regulations will be satisfied for each resource type to be impacted.”
Response
This information will be reviewed for the FEIR. C-2.2 Comment
“The Waterways regulation Program (WRP) recommends that the FEIR include an
overlay of the project and alternatives on areas of c. 91 jurisdiction, including filled and
flowed tidelands. The WRP can supply the proponent with a GIS data layer (shape file)
showing the historic high water mark upon request.
“The most significant project components with respect to c. 91 jurisdiction are the
crossings of the Malden and Charles Rivers…. The FEIR should address this issue
and provide any supporting analysis in order to allow the Secretary to make such a
finding.”
Response
The RDEIR Chapter 5, on page 5-79 and in Table 5-23 provides a preliminary
evaluation with estimated acreages of filled tideland impacts. Refer to the NPC
Attachment 6 (Section 6.1) regarding a recommended alignment change in the
Northern Tier of the Urban Ring which would avoid the Malden River crossing. Further
analysis including GIS overlay mapping will be provided in the FEIR.
C-2.3 Comment
“The FEIR also should provide more detail regarding the structural changes necessary
for each type of project improvement.”
Response
Structural evaluation will be provided as the project advances into preliminary
engineering.
C-2.4 Comment
“It is requested that the FEIR focus on the potential hazardous waste sites that will be
impacted within the LPA, by identifying and describing the contamination sites in
corridor areas that would be affected by the project, and explaining how EOT will
handle these sites.”
Response
This information will be reviewed for the FEIR/FEIS. Group C - Response to State Agency Comments
Page 14
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-3
Received from: Massachusetts Department of Public Health, Bureau of Environmental Health
February 10, 2009
Comment No.
C-3.1 Comment
“While we appreciate that high capacity, low emission buses are proposed to be used,
we believe that the information from these studies suggests that any potential impacts
related to air quality should be comprehensively evaluated to determine any possible
impact the proposed Project, including bus routes, bus stops, and vehicles used, may
have on nearby residents. To this end, you may want to recommend that the pediatric
asthma data for the neighborhoods that will be impacted be evaluated to determine
whether any additional modifications to the Project are necessary.”
Response
The air quality analysis provides information regarding existing air quality and future
year benefits associated with the project. Existing air quality data from the
Commonwealth’s air quality monitoring program indicates that the State and National
Ambient Air Quality Standards are maintained, except for the ozone 8-hour standard.
(Ozone is a pollutant that can affect lung function.) These standards are designed to
protect the public health with a margin of safety (to consider the more sensitive
population). Since the Commonwealth is classified as non-attainment for the ozone
standard, the air quality study evaluated the regional emissions of volatile organic
compounds (VOC) and oxides of nitrogen (NOx). These two pollutants are precursors
in the formation of ozone. Further, areawide emissions were considered due to the
regional nature of the ozone issue. The results indicate that the proposed project
alternatives are expected to result in lower regional emissions of both VOC and NOx.
Group C - Response to State Agency Comments
Page 15
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-4
Received from: Massachusetts Historical Commission
February 6, 2009
Comment No.
C-4.1 Comment
“The FTA will consult with the MHC and other consulting parties to complete the
Section 106 review.
“Under MHC’s state regulations, a Section 106 review automatically substitutes for a
state-level MHC review (see 950 CMR 71.04(2)). This provision acts as an important
streamlining process for federally-funded projects, without duplicating historic
preservation reviews as it goes to MEPA for MEPA review or to state agencies for
applicable state agency permits.”
Response
Comment noted. Group C - Response to State Agency Comments
Page 16
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-5
Received from: Massachusetts Office of Coastal Zone Management
February 2, 2009
Comment No.
C-5.1 Comment
“CZM recommends that as the project design progresses the proponent should
prepare and provide the Massachusetts Department of Environmental Protection with
additional information that will allow for an accurate determination of lands subject to
Chapter 91 licensing and those that are within a Designated Port Area.”
Response
Refer to the response to comment C-2.2 regarding Chapter 91. For navigable
waterways refer to the RDEIR Chapter 4, page 4-98.
C-5.2 Comment
“Since the project includes a new busway over the Malden River, the RDEIR indicates
that the proponent will coordinate with the Massachusetts Department of Conservation
and Recreation’s (DCR) planned replacement of the adjacent Route 16 bridge. CZM
recommends that both the proponent and DCR also coordinate with CZM as the
design and planning for the proposed busway progresses.
Response
EOT will coordinate with DCR and CZM as design and planning of the project
progresses. Also note the response to comment C-2.2 regarding the recommended
alignment change, which does not cross the Malden River.
C-5.3 Comment
“The proposed project may be subject to CZM federal consistency review, in which
case the project must be found to be consistent with CZM’s enforceable program
policies. Please contact CZM for further information.”
Response
EOT will contact CZM regarding the process. Group C - Response to State Agency Comments
Page 17
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: C-6
Received from: Urban Ring Phase 2 Citizens Advisory Committee
January 8, 2009
Comment No.
C-6.1 Comment
“Take immediate next steps to initiate any additional analysis and engineering,
including release of bond funding designated for these purposes that will identify and
advance the timely implementation of appropriate early actions that will provide
improved transit service in segments located throughout the corridor.
“Address the issues of funding sources for capital and operating costs.” Response
Refer to the NPC Attachment 6 (Section 6.2). C-6.2 Comment
“Address issues of pedestrian access, climate change, refinement of tunnel
engineering analysis, additional vibration/EMF/Moving Metal evaluation for tunnel
options, and completion of ongoing studies identified in the RDEIR/DEIS document.”
Response
These issues will be reviewed during future environmental review as each stage of the
project advances. Refer to the NPC Attachment 6 (Section 6.2.2 regarding major
infrastructure elements of the project and their status, including the Fenway/LMA
tunnel, the Charles River Crossing, and the Allston connection.
C-6.3 Comment
“Refine Urban Ring ridership modeling in the context of MBTA system capacity
constraints and other expansion projects being planned.”
Response
See response to Comment G-7.3 regarding ridership modeling with capacity
constraints.
Group C - Response to State Agency Comments
Page 18
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: D-1
Received from: Metropolitan Area Planning Council
February 10, 2009
Comment No.
D-1.1 Comment
”The RDEIR analysis has been done for 11 Urban Ring sectors, with different
ridership, costs, and environmental impacts for each. With that information at hand, we
believe that EOT can now address two of the policy issues we raised previously: timing
and funding. We recommend that the Commonwealth proceed with the conclusion to
be drawn from much of this information – that Phase 2 be broken into sectors for
implementation, and that the Commonwealth fund for early action those sectors with
significant benefits that could be implemented soon.
“Implementation of Phase 2 should begin in Sectors that are ready to proceed to final
design and procurement, which connect radial corridors and serve discreet markets. A
Better City has suggested defining the Urban Ring as a ’Program of Interrelated
Projects,’ with phased implementation of sections while continuing to balance the costs
versus benefits for the entire 25 mile Ring. We endorse that idea. Planning should
continue to resolve outstanding issues in other sectors where questions remain,
including the question of whether to proceed directly to the rail-based service (Phase
3) in those areas.
“Projects in the RDEIR show that pieces of the Urban Ring will make some existing
private bus routes redundant. In Table 4-9 it is estimated just under just 4,000 riders
on private buses would shift to Urban Ring. Five routes are identified with more than
50% of their riders likely to shift. Discontinuing some of these routes should free up
funds to help operate the Urban Ring.
“Under this recommendation to break up the Urban Ring into sectors for
implementation, some of the pieces will still require MEPA review. For those that do,
complete funding details should be included in the FEIR.”
Response
See Attachment 6 (Section 6.2) of the NPC for a description of phased
implementation, early action items, funding options, and a schedule for resolving key
remaining project issues.
See response to Comment F-2.1 regarding proceeding directly to Urban Ring Phase 3
(rail).
It is anticipated that the Urban Ring could enable the elimination of some redundant
private shuttle bus routes. This could be coordinated with the relevant institutions and
the MBTA as the project advances.
D-1.2 Comment
Environmental Justice: “In the interest of promoting Environmental Justice, we
recommend that all transfers from at least buses be free. At very least we request that
the FEIR include an analysis of fares to demonstrate whether or not Urban Ring fares
would be disproportionately expensive for EJ populations.”
Response
This issue will be considered in the FEIR in the context of MBTA system-wide fare
policy.
Group D - Response to Regional Agency and Authority Comments Page 19
RESPONSE TO COMMENTS ON RDEIR D-1.3 Comment
Bicycle connections: “All these paths will provide enhanced access to the Urban Ring,
and all will need to cross the Urban Ring at some point to enable connections to
neighborhoods and the regional bicycle network. Coordinated planning that respects
the rights of all users must take place as part of the Urban Ring’s design and
development process. Details on this coordinated planning should be reported in the
FEIR.
“There also seems to be an assumption that bicycles will be allowed in the bus lanes,
which will operate as bus/bike lanes (p.2-61). This does not seem to be consistent with
current MBTA policy, which prohibits bicycles from the Davis Square bus way, for
example, based on concerns about safety. We would support joint use lanes but
believe that the FEIR should cite examples from other parts of the United States to
allay the safety concerns.”
Response
As the project advances, bicycle and pedestrian path planning and coordination will
continue with agencies, cities, and towns. EOT is continuing to consider and evaluate
shared bus/bike lanes for certain limited areas of the Urban Ring alignment,
appropriate to local conditions.
D-1.4 Comment
Payment Options- “We do not believe the DEIR adequately addresses the degree to
which method of payment can impact operational issues…. The feasibility of station
designs which allow for pre-boarding payment should be investigated in the FEIR.”
Response
Alternative method of payment options were evaluated in the DEIR (Variant CW-4 and
CW-5, see Table 3-1). The method of payment affects passenger boarding times,
travel times, and ultimately ridership projections. The impact of alternative payment
methods were tested in the CTPS travel demand model. The FEIR will include a
review of the feasibility of pre-boarding payment stations (informed by local conditions
such as space constraints and anticipated demand) and potential use of a “proof of
payment” system (informed by state of the practice and MBTA system policies).
D-1.5 Comment
Sector 4 on-road routing – “Passengers transferring between the BRT routes and the
Orange Line will admittedly violate our preference for a single-seat ride when faced
with this Orange Line versus BRT choice. Our recommendation here is to drop the onstreet BRT route in this area, with the Orange Line between Wellington and Sullivan
becoming part of the Urban Ring.”
Response
See recommended modifications to the LPA alignment in the NPC Attachment 6
(Section 6.1).
D-1.6 Comment
Commuter rail stations – “New stations, and perhaps the improved stations as well
when they result in more use, could have impacts on the service provided in these
corridors. The FEIR should detail these potential impacts, along with plans to maintain
at least existing service levels with the new, better access.”
Group D - Response to Regional Agency and Authority Comments Page 20
RESPONSE TO COMMENTS ON RDEIR Response
The FEIR will further develop and evaluate station concepts and operating plans for
serving them
Group D - Response to Regional Agency and Authority Comments
Page 21
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: D-2
Received from: Massachusetts Port Authority
February 9, 2009
Comment No.
D-2.1 Comment
“However, upon review, Massport has found many of our previous comments have not
been addressed. Thus, Massport asks the Urban Ring planning team to review our
previously submitted comments and ensure that they have been properly addressed.”
Response
Between the DEIR and the RDEIR significant changes were made to the
recommended routing and station locations of the Phase 2 BRT service in both South
Boston and at Logan Airport and the Airport Blue Line station as a result of
coordination with and input from Massport. EOT will review previous comments and
address any outstanding issues in the FEIR.
D-2.2 Comment
“Given the importance and complexity of the project and the importance of close
coordination and consultation, Massport suggests the formation of an Urban Ring task
force or technical working group. The group would be tasked with planning the BRT
connections at the airport, through East Boston, and through South Boston. As the
project progresses, Massport will need to be an integral part of the planning process as
it pertains to Massport-owned properties.”
Response
EOT will coordinate with representatives from various neighborhoods, agencies,
institutions, and other stakeholders when the project enters the preliminary engineering
phase, and will consider formation of an ad hoc technical working group or groups to
address local design and engineering issues.
D-2.3 Comment
“However, Massport remains concerned whether there will be adequate capacity on
the Chelsea Truck Route to accommodate the range of proposed uses. Therefore,
Massport believes that further analysis of the Chelsea Truck Route capacity and
analysis of surrounding intersections is imperative. Massport requests the opportunity
to be involved in developing assumptions for this analysis and to review and comment
on the results.
“Since EOT is depending on the use of the Chelsea Truck Route for the Urban Ring,
the appropriate metropolitan transportation planning and programming steps must be
taken to ensure timely implementation. The Chelsea Truck Route, which is in the longrange regional transportation plan, should advance early in the plan period and be
approved for funding in the Transportation Improvement Program (TIP). Delays to this
project could delay the implementation of the Urban Ring Phase 2.”
Response
Qualitative capacity evaluation of the Chelsea Truck Route (Listed in the TIP as the
East Boston Haul Road) and intersections in East Boston and East Chelsea were
conducted using available traffic volume projections. Existing truck volumes for the
South Boston Haul Road were used to simulate truck volumes on the East Boston
Haul Road. Based on this analysis, there appears to be adequate capacity on the
Group D - Response to Regional Agency and Authority Comments Page 22
RESPONSE TO COMMENTS ON RDEIR roadway and intersections, assuming some modifications to turn lanes and signal
control at some intersections. EOT will coordinate with MassPort to develop
assumptions and review results. EOT acknowledges that advancing the East Boston
Haul Road is a critical early action for the Urban Ring project.
D-2.4 Comment
“As proposed in the RDEIR/DEIS, the BRT route 7 northbound is shown to use I-90
eastbound to an off-ramp to Frankfort Street in order to reach Airport Station. However,
this off-ramp is only available to traffic on Route 1A northbound; I-90 eastbound traffic
must exit at Neptune Road. The Urban Ring planning team should revisit this routing
proposal.
Plan & Profile sheet 4, drawing 97713 – RDEIR SHT4:
“…Also, please note that the Route 1A off-ramp at Frankfort Street intersection is
signalized.”
Response
The BRT Route 7 routing will be revisited and revised as necessary in the FEIR. The
FEIR will also note that the Route 1A off-ramp at Frankfort Street is signalized.
D-2.5 Comment
“There are many complex issues to resolve regarding vertical clearances, garage
circulation, pedestrian circulation, and vehicles queuing space, among others.
Massport still supports a singular BRT station at the West Garage, but we need to work
more closely with the Urban Ring planning/project team in order to make sure that
Massport approves plans or proposals that are presented to the public.”
Response
EOT will continue to work with Massport on routing and design issues throughout
preliminary engineering and the FEIR.
D-2.6 Comment
“Massport believes that a potential passenger service enhancement at Logan Airport
might be to route all Urban Ring lines to both the Airport Station and the West Garage
Station. This will eliminate the need to transfer from an Urban Ring bus to access the
airport terminals and it will greatly reduce passenger confusion. However, an analysis
of the terminal area roadway system will need to be completed to ensure that this
change would not further congest traffic at the airport. Pending results of this analysis,
Massport reserves the right to further refine the acceptable routing options.”
Response
The option of routing all Urban Ring routes to both Airport Station and the West
Garage was evaluated during the variant and alternatives evaluation. The results
indicated that serving both stations with all routes would not significantly increase
ridership, but it would increase VMT and add more traffic to the terminal area as noted.
EOT will work with Massport to further refine airport routing during preliminary
engineering and the FEIR.
D-2.7 Comment
“The proposed headways for the BRT routes should be reconsidered in the context of
Logan Airport passenger and employee travel demand. Peak travel demand for these
travelers does not necessarily coincide with traditional home-based work commutes.”
Group D - Response to Regional Agency and Authority Comments Page 23
RESPONSE TO COMMENTS ON RDEIR Response
While peak travel for Logan airport may not coincide with the traditional commuter
peak periods, the RDEIR proposed three BRT routes (1, 2, and 7) that serve the
airport. The midday (15 minutes) and nighttime (20 minutes) BRT headways for each
route will overlap producing an overall effective headway of 5 minutes midday and 7
minutes nighttime. Refinements to headways in the airport will be discussed with
Massport and the MBTA as the project advances into preliminary engineering and
FEIR.
D-2.8 Comment
“Massport recommends that the Urban Ring planning team investigate combining the
BRT 1 and BRT 2 routes into a single route between the West Garage Station and
Kendall Square Station with a stop at Airport Station. This singular bus route could
provide headways as low as 5 minutes and greatly reduce passenger confusion about
routing, as the two routes overlap for much of their alignment. It would also allow riders
who board between Kendall Square and Sullivan Square a one-seat ride to Logan
Airport at the West Garage Station.”
Response
EOT will consider this recommendation and coordinate with Massport and the MBTA
on development of the BRT operating plan.
D-2.9 Comment
“Massport, as part of the technical working group mentioned above, would like to
coordinate with the Urban Ring planning team, the City of Boston, and other
stakeholders regarding the proposed A Street routing or any further alternative
analysis.”
Response
EOT will continue to coordinate with Massport and other appropriate stakeholders as
the project advances.
D-2.10
Comment
“Massport notes that the BRT 7 route is proposed to use the Masspike emergency
access on-ramp to enter the Ted Williams Tunnel from the Massport Haul Road.
Massport supports this idea as it would produce better travel times for transit
passengers. Because Silver Line buses used this ramp during the tunnel closures
following the ceiling collapse, there are some data available regarding buses on this
ramp.”
Response
Comment noted. EOT appreciates Massport offering to provide data regarding buses
using the emergency on-ramp.
D-2.11
Comment
“Massport requests that the Urban Ring planning team explore alternatives to the
proposed Congress Street routing in the South Boston waterfront.
“…Massport suggests a route that would use Seaport Boulevard/Northern Avenue and
provide important connections that the Congress Street route does not.”
Group D - Response to Regional Agency and Authority Comments Page 24
RESPONSE TO COMMENTS ON RDEIR Response
This route will be considered and coordinated with Massport. The Congress Street
routing would provide a direct connection between the Urban Ring and the Silver Line
in South Boston and EOT recommends that a Silver Line connection in South Boston
be part of any revised Urban Ring routing.
D-2.12
Comment
“Given the scale of this project, and its likely need to augment transportation capacity
to meet its projected transportation demands, the potential impacts and mitigation
contributions of this project should be assessed as part of the Urban Ring
environmental review process.”
Response
In keeping with federal guidelines, the land use and demographic projections that
underlie Urban Ring Phase 2 analysis and ridership projections are based on the land
use projections developed by the Metropolitan Area Planning Council and used by the
Central Transportation Planning Staff for travel demand modeling for the Boston
Region Metropolitan Planning Organization. The Urban Ring Phase 2 planning process
has and will continue to consider important travel demand nodes. The impacts and
mitigation required for Seaport Square and other projects will be addressed through
municipal and state development review processes.
D-2.13
Comment
“Current transit connections provide low levels of service between the South Boston
waterfront and inner core communities to the north (e.g. Chelsea and Everett) and the
BRT 7 route is not proposed to serve Everett. Massport urges project planners to
consider improving Urban Ring connectivity between the South Boston waterfront and
northern core neighborhoods.”
Response
The proposed BRT 7 route would provide 10 minute peak period headways with a
single seat ride between the South Boston waterfront and Chelsea. Everett is also
connected with high frequency BRT service to the South Boston waterfront via transfer
to BRT7 at any Chelsea or East Boston station. The purpose of the Urban Ring is to
provide circumferential transit through densely developed portions of seven
communities and connect with existing MBTA radial-oriented service. While the Urban
Ring serves many origins-destinations in the study area it is not feasible to meet every
transportation origin-destination pair with a single seat ride. Further operations
planning and ridership forecasting during preliminary engineering and FEIR will
determine how to best connect these communities to the South Boston waterfront.
D-2.14
Comment
Page 4-15:
“As of November 2008, Massport actually operated four express bus routes: Peabody
is missing from the description on p.4-15.
“Logan Express market areas serve passengers outside of the Urban Ring area
(unless they are originating their trips at Logan Airport). Thus, the description of the
Logan Express service does not seem to apply to this section. We recommend
deleting this text.”
Response
The text will be revised in the FEIR. Group D - Response to Regional Agency and Authority Comments Page 25
RESPONSE TO COMMENTS ON RDEIR D-2.15
Comment
Section 4.3.2.1, page 4-19, Silver Line discussion:
“The statement regarding Massport’s study regarding Silver Line service to the airport
seems out of place in this paragraph, which discusses the existing service. We
recommend deleting this sentence.”
Response
The text will be eliminated in the FEIR. D-2.16
Comment
Section 4.3.6.1, page 4-27:
“Massport’s Route 66 bus currently operates at 12-minute headways.”
Response
This will be revised in the FEIR. D-2.17
Comment
Sections 4.4.6.1 & 4.4.6.2 (2006 & Future Traffic Condition Capacity Analysis):
“Intersections 178 (Frankfort/Neptune) and 179 (Neptune/1A) have no LOS data for
2006. Intersection 178 is not really a significant one; could it possibly be mislabeled?
Response
Intersections 178 and 179 were under construction at the time the traffic counts were
taken in 2006. Consequently, analysis was not conducted for existing and future
conditions.
D-2.18
Comment
“There is no analysis for the two EB Haul Road endpoint intersections, at Chelsea
Street and at Frankfort Street.”
Section 4.8.3, page 4-97:
“The RDEIR does not appear to provide the capacity analysis to confirm the statement
that the Urban Ring will not impact the EB Haul Road. Therefore, we request the Final
EIR specifically address the 2030 year peak-hour level of service operations at both
the intersection at Chelsea Street and at Frankfort Street. EOT, MBTA, Massport, and
the City of Boston need to coordinate the development of the EB Haul Road project,
ensuring that the roadway can service transit, trucks, and other authorized vehicles.”
2.2.1, page 2-10
“The RDEIR is not clear in demonstrating the traffic demand on the EB Haul Road and
does not demonstrate that there will be ’no capacity issues.’ Even if this is true, the
document should reflect this in its analysis.”
Response
These intersections were not included as study intersections, but could be evaluated in
the FEIR. EOT will coordinate with MBTA, Massport, and the City of Boston for the
development of an East Boston Haul Road project that serves transit, trucks, and other
authorized vehicles.
Group D - Response to Regional Agency and Authority Comments Page 26
RESPONSE TO COMMENTS ON RDEIR D-2.19
Comment
2.2.1, page 2-11:
“Please clarify what is meant by ’Airport Service Road;’ the text may be referring to Frankfort Street at this location. Also, please clarify what is meant by ’busway‘ which presumably refers to the East Boston Haul Road.” Response
The discussion is referring to the where the proposed East Boston Haul Road passes beneath Route 1A. The proposed signal is at the intersection of Frankfort Street/ Vienna Street and the Haul Road. The busway is referring to the East Boston Haul Road. The FEIR will distinguish
between exclusive busways and limited use roadways where general traffic will be
prohibited, such as the East Boston Haul Road that are proposed to be shared by
buses and trucks.
D-2.20
Comment
5.4.1.1 Segment A, Sector 1 – East Boston, Page 5-28:
“(1) The construction at the airport related to the terminal roadways, Logan
Modernization, and the CA/T interchange has been completed since 2007. (2) The
East Boston neighborhood to the southwest of the airport is called Jeffries Point. (3)
Regarding landscaping, Logan Airport has many landscaped areas throughout its
property, including the 9/11 Memorial Park, which opened in 2008. (4) Furthermore,
Massport is working closely with the neighboring communities to complete additional
phases of its Edge Buffer program. The Urban Ring will interface with the Edge Buffer
in the North Service Area, where it also will also cross the East Boston Greenway as it
continues north of the Bremen Street Park.”
Response
These points will be noted in the FEIR. D-2.21
Comment
Page 5-35, Sector 11 – South Boston:
“This paragraph should be edited to reflect the LPA, which does not use the SB Haul
Road.”
Response
The text will be revised in the FEIR. D-2.22
Comment
Figure 5-34 Parks, Open Space, and Cultural Resources, Page 5-130:
“Missing from Figure 5-34 is the Airport Edge Buffer along the SW portion of Logan
Airport, the Bremen Street Park west of Route 1A, Navy Fuel Pier Park in Jeffries
Point, and the 9/11 Memorial Park near the Hilton Hotel at Logan Airport. Please
include these facilities.”
Response
These will be included in the FEIR. Group D - Response to Regional Agency and Authority Comments
Page 27
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: D-3
Received from: Massachusetts Water Resources Authority
February 10, 2009
Comment No.
D-3.1 Comment
“It is highly likely that EOTPW will need to apply for multiple MWRA Section 8 (M)
permits pursuant to Section 8 (M) of Chapter 372 of the Acts of 1984, MWRA’s
Enabling Legislation.
“…We encourage the Project Proponent and their consultants to meet with MWRA
staff when designs are at a level for interagency review. MWRA permitting staff will
need to review plans at an appropriate scale to better determine potential impacts.
Without design or engineering plans, it is difficult to predict exact impacts at this time.”
Response
EOT will coordinate with MWRA as the project advances and share plans as they are
developed in preliminary engineering and FEIR.
D-3.2 Comment
“If groundwater is encountered during the construction phase in Boston, Cambridge,
Chelsea, and Somerville, and MWRA Temporary Construction Dewatering Permit will
be required pursuant to 360 C.M.R. 10.091-10.094. MWRA regulations prohibit the
discharge of groundwater into a sanitary sewer system unless a permit is issued from
both the MWRA and the appropriate Municipality (BWSC, Cambridge, Chelsea, or
Somerville).
“…EOTPW will need to secure a USEPA-NPDES General Permit for Storm Water
Discharges from its construction activities in these Municipalities.”
Response
EOT will address required permitting as the project advances into preliminary
engineering and FEIR.
Group D - Response to Regional Agency and Authority Comments Page 28
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-1
Received from: Boston Environmental Department
February 10, 2009
Comment No.
E-1.1 Comment
“The Revised DEIR/DEIS indicates that sustainable technologies and practices will be
incorporated into the project. We request that the Final Environmental Impact
Report/Final Environmental Impact Statement (FEIR/FEIS) describe a plan that
includes energy generation and the potential for any site-based production at stations.
“Chapter 5, Environmental Impacts and Mitigation, describes a range of potential impacts but does not identify specific mitigation. The FEIS/FEIR should also describe measures to protect water resources, prevent/mitigate wetland impacts, and ensure compliance with MGL C.90, Section 16A and 310 CMR 7.11. (the Commonwealth’s five-minute idle law), minimize the effects of vibration on sensitive receptors and minimize noise impacts and the spread of light from stations and other associated
facilities.” Response
These points will be considered in preliminary engineering and FEIR. E-1.2 Comment
“We ask that the FEIR/DEIS discuss the following construction-period issues:
• re-use, recycling and donation of salvaged demolition and construction
materials;
• hours of work;
• establishment of efficient truck routes;
• delivery scheduling;
• enforcement of MGL C.90, Section 16A and 310 CMR 7.11;
• minimizing fugitive dust impacts;
• the connection of stationary equipment to the NSTAR grid where feasible;
• securing decking on roadways, adjusting back-up alarms, keeping engine
housing panels closed and shutting off equipment not in use;
• the proper storage and disposal of hazardous materials; and
• where feasible, building screening to provide light shielding for area
residents and other users.”
Response
A construction management plan will be developed when the project enters the
preliminary engineering phase.
E-1.3 Comment
“Best Available Control Technologies (BACT) and other best management practices
(BMP) should be employed to minimize noise impacts. Measures should include:
• using vehicles and equipment with either ambient-sensitive or manually
adjustable back-up alarms;
• the proper sizing of impact equipment such as hoe rams, pile drivers and
jackhammers and powering only to the degree needed to perform the
work;
• the installation of noise suppression enclosures on hoe rams;
Group E - Response to Municipal Comments Page 29
RESPONSE TO COMMENTS ON RDEIR • the placement of stationary noise producing equipment such as pumps
•
and generators as far away as possible from residential and sensitive
receptor locations; and
keeping engine housing panels on all equipment closed; and when not in
use, shutting off equipment.”
Response
A construction management plan will be developed when the project enters the
preliminary engineering phase.
E-1.4 Comment
“Construction methods creating minimal vibration should be employed to the greatest
extent possible. A monitoring program should be established to indicate if vibration,
soil displacement or dewatering impacts are resulting from construction activities. A
pre-construction survey of adjacent properties should be conducted so that steps can
be taken to secure structures at risk and so that project-related damage can be readily
distinguished from pre-existing conditions.
“…We ask that all pre-2007 diesel construction vehicles working on the project be
retrofitted using technologies approved by the United States Environmental Protection
Agency (EPA) and that all off-road construction equipment be operated on ultra-low
sulfur diesel (no more than 15 ppm).”
Response
Construction methods creating minimal vibration will be used where possible. A
construction management and monitoring plan will be developed for each stage of the
project during preliminary engineering. The plan will include measures to minimize and
mitigate construction impacts.
Group E - Response to Municipal Comments Page 30
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-2
Received from: Boston Redevelopment Authority
February 10, 2009
Comment No.
E-2.1 Comment
“The lack of resolution of these two segments raises important issues concerning the
project’s schedule…. If the project’s schedule is to be maintained, it will therefore be
necessary for EOT to carry out the work needed to select a preferred alignment in the
two unresolved segments at the earliest possible date. The urgency of this work is
underscored by the fact that the City expects soon to receive development proposals
in the Longwood and Fenway areas and an institutional master plan proposal in North
Allston that would impact the project. Without resolution of the Urban Ring’s alignment
in these segments, the BRA will not be able to insure through our development review
that these proposals support the project.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding the Fenway/LMA tunnel. EOT agrees that it is important to continue to address alignment issues in these areas and will work with stakeholders and the City of Boston during development review. E-2.2 Comment
“It should be noted that the initiation of preliminary engineering will require FTA’s
approval, which is obtained by submitting a New Start application…. As set forth in the
technical attachment to this letter, at least one other state has reached agreement with
FTA that resolve similar issues. We ask that you reinforce your May 2008
recommendation to submit a timely New Start application with the recommendation
that EOT work with the new federal administration to develop an approach to funding
and implementation that would permit early implementation of fundable priority project
elements in the swiftest possible time frame.
“…It should be noted that the early implementation of certain Urban Ring project elements is critical to a number of Boston’s development initiatives. Among them are Roxbury Parcels 8 and 9 at the corner of Melnea Cass Boulevard and Washington
Street. It should also be noted that early implementation of the busway across the Charles River would potentially be of great benefit to mitigating the impacts of DCR’s eight-year program to reconstruct the Charles River Basin bridges.” Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding early action items, implementation, and funding options. E-2.3 Comment
“In light of the project’s increasingly critical timing issues, we request that your
RDEIR/S certificate require EOT to work with you to establish a sufficiently detailed
schedule to insure that its environmental submission schedule remains on track and
that this schedule contains an approach to the early implementation of critical project
elements. Given the importance of the project’s progress to the City of Boston, we ask
that the MEPA office engage us in the preparation of this schedule. We also request
that you require EOT to report its progress under this schedule in the bi-annual
progress reports you required in your May 2008 certificate.”
Group E - Response to Municipal Comments Page 31
RESPONSE TO COMMENTS ON RDEIR Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding the approach to early actions
and major infrastructure elements.
E-2.4
Comment
2.1.1 Sector 1: East Boston/ Logan Airport
“The East Boston Haul Road may progress independently of the Urban Ring project.
EOT should be encouraged to work with the City and Massport on the evolution of this
project and its coordination with the East Boston Greenway.”
Response
EOT will coordinate with the City of Boston and Massport on these points as the East
Boston Haul Road project advances.
E-2.5
Comment
2.1.3 Sector 4: Wellington/Somerville/Charlestown
“Working with the neighborhood and the MBTA, the City of Boston is currently
designing the reconstruction of the Sullivan Square/Rutherford Avenue street system.
Our project schedule calls for the identification of the preferred roadway configuration
in March 2009… It is therefore important that EOT to retain the capacity to integrate its
planning for the project within our on-going design process.
“…It is important for EOT to focus on the project’s connections between Everett and
Sullivan Square, which the LPA proposes would pass through Wellington Circle....
Should this project not progress or should it fail to sufficiently reduce congestion, we
would be open to consideration of an alternative route between Everett and Sullivan
Square that by-passes Wellington Circle by shifting BRT routes 1 and 2 to the Route
99 Bridge. Recognizing the importance of Urban Ring service to the Assembly Square
project, should this diversion be warranted, BRT 5, which is currently proposed to
terminate at Sullivan Square, should be extended to the new Orange Line station at
Assembly Square. Just as the RDEIR/S proposes potential interim routes while the
more challenging elements of the Urban Ring are being undertaken, we would also
suggest that the routing discussed above could be a useful interim phase of the
project.”
Response
Refer to the NPC Attachment 6 (Section 6.1) which recommends alignment changes in
the area of Sullivan Square consistent with the suggestions listed above. The
recommended change includes extending the Urban Ring Phase 2 service to
Assembly Square in Somerville.
E-2.6
Comment
2.1.6 Sector 6: Cambridgeport/ Charles River Crossing
“The RDEIR/S notes that heavy traffic volumes and congestion make the use of the BU
Bridge undesirable as the project’s LPA, although the project may need to utilize the
bridge during the reconstruction of the Grand Junction Bridge, the preferred route. It
should be noted that current plans reduce the bridge to three lanes in a configuration
to be determined, potentially further limiting its use by buses.”
Response
Comment noted. Group E - Response to Municipal Comments
Page 32
RESPONSE TO COMMENTS ON RDEIR E-2.7
Comment
2.1.7 Sector 7: Allston/Harvard Square Cambridge
“We believe that Option A, a busway beneath the Mass Turnpike viaduct is the
preferred option and that Option C, Commonwealth Avenue to Brighton Avenue is at
best an interim route until the preferred option can be accomplished. Option B,
Commonwealth Ave./Malvern Street/viaduct to the rail level raises issues that should
eliminate it from consideration.
“…The Urban Ring’s alignment within the present rail yard will need to connect it to the
new Commuter Rail station that EOT is evaluating through a separate study. The
supplemental study called for here should integrate the planning for the two projects. In
this connection, the scope should require EOT to work with the BRA and BTD in
selecting a joint station location that gives the Allston community convenient, handicap
accessible access via Cambridge Street.”
Response
See response to Comment E-6.11 regarding the status of the Allston portion of the
LPA alignment.
E-2.8
Comment
2.1.7 Sector 7: Allston/Harvard Square Cambridge
“With regard to the alternative alignments between Cambridge Street and Harvard
Square, the City’s on-going North Allston community-wide planning program will
establish the infrastructure framework for the neighborhood, which will in turn become
the framework for Harvard’s Institutional Master Plan submission. It is our intent that
this framework include an Urban Ring station in or adjacent to Barry’s Corner rather
than in the LPA’s location, in order to optimize service to both residents and the
Harvard campus. To accommodate the station’s more westerly location near Barry’s
Corner, EOT should consider adding a station on Stadium Way serving Harvard’s
campus south of Western Avenue.
“…MEPA should therefore encourage EOT to continue its work with the City to select
an alignment that is integrated with the neighborhood plan.”
Response
See response to Comment E-6.11 regarding the status of the Allston portion of the
LPA alignment.
E-2.9
Comment
2.1.8 Sector 8: Boston/Fenway/Longwood
“The City is engaged in an extensive program known as the Fenway-LongwoodKenmore Transportation Action Plan that will utilize funds provided by the legislature’s
Economic Stimulus Bill to reconfigure Boylston Street and Audubon Circle, create a
new street network in the triangle between Boylston and Beacon Streets, and construct
a multi-use path between the D Line Fenway stop and Yawkey Station…. We therefore
request that EOT be encouraged to continue to work with the City to integrate the
Urban Ring project with the Transportation Action Plan.”
Response
Group E - Response to Municipal Comments
Page 33
RESPONSE TO COMMENTS ON RDEIR EOT will continue to work with the City so that the improvements being proposed as
part of the Transportation Action Plan will not conflict with the Urban Ring LPA, and will
also be integrated into preliminary engineering design of the LPA.
E-2.10
Comment
2.1.8 Sector 8: Boston/Fenway/Longwood
“EOT was unable to select a tunnel between Longwood and Yawkey stations within its
November 2008 deadline…. We therefore request that MEPA’s certificate on the
RDEIR/S require work necessary to resolve the alternatives to continue. The extended
study of tunnel options should not reopen the portal locations established in the
RDEIR/S, which connect the Urban Ring to transit service at Ruggles and Yawkey
stations. Treating these portals as fixed points, EOT should select a preferred
alternative after considering the following:
• Construction vibration. The Longwood medical institutions continue to
have questions about construction vibration from tunnel boring. While
continuing to address these questions, EOT should consider the feasibility
of introducing sequential excavation in the most sensitive tunnel segment
while constructing the more substantial balance of the project with tunnel
boring equipment.
• Maintaining the potential for a heavy rail Phase 3. Travel analysis of Phase
2 of the project confirms the enormous ridership demand in the corridor
between Sullivan Square and Ruggles Stations, demand that will grow as
development continues in this corridor beyond the projections permitted in
CTPS’s trip model and which heavy rail may be required to accommodate.
The geometrics of the adopted alignment should not preclude this
outcome.
• Because the turnouts included in the alignment alternative developed to
avoid the Winsor School campus would require cut-and-cover construction
that would seriously damage vehicular travel on Longwood Avenue, other
alternatives or their deletion as part of Phase 2 should be considered.
“As reported in Section 4.7.6, EOT should be prepared to continue its focused effort with the City and the Longwood institutions to develop an interim surface alignment to be used through the Longwood area until the tunnel is operational.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding the Fenway/LMA tunnel. The Phase 2 LPA will not preclude Phase 3 rail. The Fenway/LMA tunnel as defined in
the Phase 2 RDEIR was developed to be capable of being converted to Phase 3 rail
and extended at a later date.
EOT will continue to work with the City of Boston and area stakeholders to develop
surfacing routing options that can enable improved interim transit service for the
Fenway/LMA.
E-2.11
Comment
2.1.9 Sector 9: Roxbury/Boston Medical Center
“The Roxbury Oversight Committee, working in collaboration with the BRA, is
developing Requests for Proposals for Parcels 8 and 9 at the intersection of Melnea
Cass Boulevard and Washington Street…. EOT must therefore develop an early
Group E - Response to Municipal Comments Page 34
RESPONSE TO COMMENTS ON RDEIR implementation program for the boulevard that ensures these projects are not stranded
by the failure to reconstruct it.
“The South Bay Harbor Trail has entered preliminary engineering. In order to meet
EOT’s commitment to continued coordination of the Urban Ring with this project it will
have to integrate its own design work with this engineering.”
2.1.10 Sector 11: South Boston/ World Trade Center
“The 100 Acres of section of South Boston is the subject of active planning with
neighborhood stakeholders. As part of this effort, the City is refining a plan for A Street,
which the RDERI/S puts forward as a route for Urban Ring busways. Because there
are potential conflicts between the two initiatives, EOT should be encouraged to
engage with the City and Massport on their resolution.”
Response
The Melnea Cass Boulevard improvements are included among potential early action
items in the NPC. See Attachment 6 (Section 6.2.2) of the NPC for details.
The recommended center median busway along Melnea Cass Boulevard (MCB) was
coordinated with the Roxbury neighborhood and the City of Boston throughout the
RDEIR. The design includes space for the South Bay Harbor Trail, and has included
the trail as a central consideration throughout the planning and environmental review
process. EOT will continue this coordination so the preliminary plans for the South Bay
Harbor Trail are integrated into Urban Ring plans in this area.
EOT looks forward to coordinating with the City and Massport regarding planned
improvements for A Street that facilitate reliable BRT service.
E-2.12
Comment
6.2 Financial Framework
“We do not believe that the work done on project financing and phasing in the RDEIR/S process was sufficiently advanced to warrant these positions. Nor do we believe that this project should face financing requirements that differ in kind from
those of other large-scale transit initiatives whose benefits are to the region and state as a whole. While not precluding local funding sources, particularly from projects
whose permitting might result in joint construction commitments, we believe it is incumbent on EOT to develop a phase implementation strategy that will allow the project to proceed in useful increments that optimize federal and state funding sources. We therefore request that it immediately commence discussions with FTA to develop such as strategy.”
Response
Refer to the NPC Attachment 6 (Section 6.2) regarding the implementation approach. EOT has initiated discussions with FTA on this matter. Group E - Response to Municipal Comments
Page 35
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-3
Received from: Boston Parks and Recreation Department
February 10, 2009
Comment No. E-3.1
Comment
Chapter 2, LPA, Section 2.4.12, page 2-85, sixth bullet on the anticipated impact of the
proposed busway tunnel portal near Landmark Center, and Table 2-27 of page 2-86:
“The proponents should provide examples of recent tunneling projects and describe
the extent of areas used for mining and receiving operations. A two acre area will likely
impact the use of parkland in the Riverway park, affecting trees, lawn, and other
features. The staging area would also be in the flood plain and could thus affect the
capacity of the basin. Should this staging operation take 3 years or more, the
proponent will require Article 97 approval for this taking. Any permanent easement
would also require legislation and appropriate provision of parkland of equal value,
extent, and utility. This potential impact will need to be factored into the construction
process and timeline.
“Further, the berm in the Riverway and the wall edge of the Back Bay Yard are flood
control structures which should not be altered during tunnel staging or construction.
Depending on the tunnel construction method, we are concerned about the effect on
the structural integrity of the buildings and structures at the Back Bay Yard, and on the
ecological integrity of the trees, shrubs, and other features, all of which are part of an
historic park.
“At this point, we wish to note that the Riverway and the Back Bay Fens are historic
properties registered with federal, state, and local authorities.”
Response
Examples of tunnel projects with constrained worksites are shown on page 3-30 in the
Technical Tunnel Alternatives Summary Report available on the project website at
www.theurbanring.com. The extent of temporary and permanent impacts and
mitigation in areas such as Riverway Park, the Riverway, Back Bay Yard, and the Back
Bay Fens will be further developed and analyzed during future environmental review of
this portion of the project at such time as it advances. Refer to the NPC Attachment 6
(Section 6.2.2) regarding the Fenway/LMA tunnel.
EOT acknowledges that the Riverway and the Back Bay Fens are registered historic
properties.
E-3.2 Comment
Chapter 4, Transportation, Section 4.7.6, Fenway/Back Bay/Longwood Medical Area,
page 4-94 and 4-95:
“We welcome the opportunity to discuss with EOT and the other stakeholders the
choice of tunnel alignment and the construction staging process for the LMA tunnel
alternative. We urge careful consideration to the design of the tunnel entrance near the
Riverway park, given the proximity to the Muddy River, and the flooding of Kenmore
Station in the mid-1990s. We also urge careful thought and full consultation with the
Parks Department on the location and design of vent buildings, escape, hatches, or
other accessory tunnel structures as they may be visual intrusions that would create
negative impacts to the Riverway, a highly sensitive historic/cultural/recreational
resource.”
Group E - Response to Municipal Comments Page 36
RESPONSE TO COMMENTS ON RDEIR Response
Comment noted. Also, see response to E-3.1 above.
E-3.3 Comment
Chapter 4, Transportation, Section 4.7.6, Fenway/Back Bay/Longwood Medical Area,
page 4-94 and 4-95:
“We also welcome the opportunity to discuss with EOT and the other stakeholders the
interim surface alignment mentioned here; as the RDEIR/S states on page 3-12, one of
the objectives of the tunnel is to
• Avoid surface routes near the historic and environmentally sensitive
Emerald Necklace and over the Muddy River.
“While the tunnel will eliminate any surface takings, the interim surface alignment may
involve a taking of parkland on the surface for bus turning. We will work with EOT and
the other stakeholders to minimize or eliminate impacts from the tunnel and interim
surface alternatives on parks in this section of the Urban Ring corridor.”
Response
Comment noted. EOT will continue to work with the City of Boston Parks and
Recreation Department, other City departments, and other stakeholders to minimize
park and open space impacts during development of any interim surface routing.
E-3.4 Comment
Chapter 4, Transportation, Section 4.7.7, Melnea Cass Boulevard and Boston Medical
Center, page 4-95:
“The city’s current Open Space Plan (2008-2012) urges the development of the South Bay Harbor Trail Project, part of which will rejuvenate and integrate the Melnea Cass Boulevard bicycle path. This path is a link in a corridor from Boston Harbor and Fort Point Channel to the Southwest Corridor Park to the Emerald Necklace (via the proposed “Linking the Corridors” project). We welcome being part of the City of Boston team that will work on the busway design in the Melnea Cass Boulevard corridor so as to integrate the busway with the by-then newly constructed South Bay Harbor Trail. We urge that EOT see this valuable cross-town corridor as a multi-modal gem, with bus rapid transit (BRT), motor vehicles, pedestrians, and bicyclists sharing the public realm here, thereby creating a powerful engine for development of the underutilized parcels found in this area.” Response
See response to BRA Comment E-2.11 regarding the South Bay Harbor Trail.
E-3.5 Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.1, Statutory and
Regulatory Considerations, pages 5-124 et al.:
“This section should also add discussion of Section 1010 of the federal Urban Park
and Recreation Recovery Act (UPARR), which prohibits conversion without the
permission of the Secretary of the Interior for parks improved with funds from this grant
program; the Urban Self-Help (USH) grant program (now known as the Parkland
Acquisitions and Renovations for Communities (PARC) grant program), which similarly
obligates the park receiving its assistance to not be converted without permission of
Group E - Response to Municipal Comments Page 37
RESPONSE TO COMMENTS ON RDEIR EOEEA, and requires replacement in kind near the same location; and other state
grant programs such as the Town Common grant program which was the likely source
for the state funds that created the Dudley Town Commons. Section 5.15.1.2 notes
that several parks near the UR corridor have received LWCF monies and cites the
National Park Service website. We recommend the report writers contact the affected
park agencies, as the names of parks receiving LWCF, UPARR, USH, or PARC grants
can change over time; it is best to use information from local sources as well as the
federal sources to insure accuracy.”
Response
This information will be provided in future environmental review documents for this
project.
E-3.6 Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.1, Statutory and
Regulatory Considerations, Table 5-42, Parklands and Open Spaces, pages 5-125 to
5-128:
“There are several errors in this table; for example, the Riverway is shown only as a
DCR parkway, when it is also a park with portions under the jurisdiction of either the
Boston Parks and Recreation Department or the Brookline Recreation and Public
Works Departments. It will be best for the project team to contact the Boston Parks
Department in order to correct these errors. Further, MassGIS has recently received a
more up-to-date version of our city-wide open space data layer, which will also help
EOT in its future planning efforts.”
Response
The project team will coordinate with the Boston Parks Department and this
information will be updated in the FEIR.
E-3.7 Comment
Chapter 5, Environmental Impacts and Mitigation, Figure 5-33 DCR Parkway
Segments Used in Urban Ring, pages 5-129:
“Part of the scope for the final environmental impact documents should be a resolution
of the use, during the pre-tunnel interim condition, of DCR parkways by the Urban Ring
Phase 2. Additionally, institutions in the vicinity of the Back Bay Fens and Riverway
have concerns about the increase in traffic and vibration form heavy vehicles that the
Urban Ring Phase 2 interim condition would produce.
“Further, there are other parkways that are not held by DCR. One of them is the
Commonwealth Avenue Mall, a City of Boston Parks and Recreation Department
parkway. This is shown on Figure 5-38, page 5-134.”
Response
No interim surface alignment has been finalized at this time. EOT will continue to
coordinate with DCR, BTD, BRA, and area stakeholders regarding interim surface
Urban Ring alignments as the project advances.
Figure 5-38 will be revised in the FEIR to clarify all parkways.
Group E - Response to Municipal Comments Page 38
RESPONSE TO COMMENTS ON RDEIR E-3.8 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-34 & 5-35 Parks, Open
Spaces and Cultural Resources (Sheet 1 & 2 of 8), pages 130-131:
“Here our concern is with the routing of the Urban Ring and its effect on existing or
proposed parklands. The existing parklands in question are East Boston Memorial
Park (shown here as East Boston Memorial Stadium) and Bremen Street Park. The
proposed parkland in question is the extension of the East Boston Greenway northeast
toward its destination at Belle isle Marsh Reservation, and its complementary
extension northwestward to Chelsea Creek via the abandoned rail corridor that is
contemplated for use by the Urban Ring.
“We look forward to working with EOT and others on how the route layout in East
Boston can minimize negative effects on existing and proposed parklands, and
hopefully assist in achieving both open space and transportation goals through shareduse of the abandoned rail corridor. We also look forward to engaging EOT on the
design on the Urban Ring transit stop near the Bremen Street Park.”
Response
The LPA alignment has been developed to minimize impacts to parkland and open
space. The intersection of the Greenway and the East Boston Haul Road is proposed
to be a controlled traffic-pedestrian signal, and the design will address needs for a
shared-use path connection through the intersection. The Urban Ring station stop
closest to the Bremen Street Park is at the Airport Blue Line Station, which is
immediately adjacent to the park with direct pedestrian access; EOT does not
anticipate any park impacts associated with this station. EOT will coordinate with the
Parks Department and BTD as the project advances.
E-3.9 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-36 & 5-37 Parks, Open
Spaces and Cultural Resources (Sheet 3 & 4 of 8), pages 132-133:
“Here our concern is with the routing of the Urban Ring and its effect on existing or
proposed parkland. The existing parklands in question are Ryan Playground and
Caldwell Street Play Area. The proposed parklands in question are ones that may
emerge from the Rutherford Avenue/Sullivan Square Study being conducted currently
by the Boston Transportation Department in conjunction with the Boston
Redevelopment Authority. Further, a regional – interstate, that is – greenway that
begins in Maine and extends to Florida, the East Coast Greenway, has a route
proposal from Everett to Boston through Charlestown via Alford Street.
“We look forward to working with EOT and others on how the route layout in
Charlestown can minimize negative effects on existing and proposed parklands and
bikeways, and hopefully assist in achieving both open space and transportation goals.”
Response
Refer to the NPC Attachment 6 (Section 6.1 regarding the proposed alignment change
in the vicinity of Sullivan Square. EOT has coordinated with the City of Boston
Rutherford Avenue/Sullivan Square Study on this alignment. The LPA alignment has
been developed to avoid or minimize impacts to parkland and open space. EOT will
continue to coordinate with Boston Parks and Recreation Department and other
stakeholders as the project design progresses to minimize impacts to existing and
future park areas.
Group E - Response to Municipal Comments Page 39
RESPONSE TO COMMENTS ON RDEIR E-3.10 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-38 Parks, Open Spaces
and Cultural Resources (Sheet 5 of 8), page 134:
“Here our concern is with the routing of the Urban Ring and its effect on existing
parkland. The existing parklands in question are the Commonwealth Avenue Mall and
Charlesgate. These are two of the nine parks in the Emerald Necklace (not four as
stated elsewhere in the RDEIR/S). We also welcome the opportunity to discuss with
EOT and the other stakeholders the interim surface alignment mentioned here; as the
RDEIR/S states on page 3-12, one of the objectives of the tunnel is to
• Avoid surface routes near the historic and environmentally sensitive
Emerald Necklace and over the Muddy River.
“We look forward to working with EOT and others on how the route layout in The Back
Bay and Kenmore areas can minimize negative effects on existing parklands and
bikeways, and hopefully assist in achieving both open space and transportation goals.
“We are also urging EOT to consider the ’Fenway Connector‘ pedestrian/bicycle multi­
use path as it works with the City on the Fenway Action Plan.”
Response
The recommended LPA defined in the RDEIR is located entirely west of Kenmore
Square and does not approach the existing Commonwealth Avenue Mall or
Charlesgate.
EOT will work with the City of Boston and other agencies and stakeholders to identify
an improved surface alignment through the Fenway/LMA portion of the corridor as the
project progresses.
EOT has coordinated with the City of Boston regarding the proposed ‘Fenway
Connector’ shared-use path, and will continue to integrate the proposal into Urban
Ring Phase 2 project planning.
E-3.11 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-39 Parks, Open Spaces
and Cultural Resources (Sheet 6 of 8), page 135:
“The location of the LMA tunnel portal at its southeastern terminus was described as
’west of Ruggles Station.’ We certainly urge EOT to avoid disruption to the Southwest
Corridor Park, and the Linking the Corridors proposal when siting this tunnel portal.
The City has stated its support for a multi-modal transportation system, so any new
project should accommodate the needs of bicycling public.
“We also look forward to engaging EOT on the design of the Urban Ring transit stops
at Park Drive near the Riverway, and on Massachusetts Avenue near Clifford
Playground.”
Response
EOT will coordinate with Boston Parks and Recreation regarding tunnel portals and
station locations. Refer to the NPC Attachment 6 (Section 6.2.2) regarding the
Fenway/LMA tunnel implementation status.
As described in RDEIR/DEIS Section 4.6, the LPA is consistent with the City of
Boston’s new Complete Streets initiative that considers equal treatment for all modes:
Group E - Response to Municipal Comments Page 40
RESPONSE TO COMMENTS ON RDEIR pedestrians, bicycles, transit, motorists, and greenspace. The busways and bus lanes
in the LPA have been coordinated with existing and planned bicycle and pedestrian
networks located around the corridor based on information provided by the
municipalities. As part of intersection improvements that will be necessary with the
Urban Ring project, pedestrian/bicycle safety and access will be upgraded to reflect
current best practices, given site-specific constraints. Thus, further coordination
between EOT and municipalities will be required as the project progresses.
EOT will continue to coordinate with Boston Parks and Recreation Department and
other stakeholders as the project design progresses.
E-3.12 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-40 Parks, Open Spaces
and Cultural Resources (Sheet 7 of 8), page 136:
“Here our concern is with the routing of the Urban Ring and its effect on existing parklands. The existing parklands in question are Dudley Town Commons, Dorchester North Burying Ground and Joe Moakley Park (formerly Columbus Park). Urban Ring transit stations may be located near or adjacent to these parks. We look forward to engaging EOT on the design of the Urban Ring transit stops near these parks.” Response
EOT will continue to coordinate with Boston Parks and Recreation Department, BTD, and other stakeholders as the project design progresses to minimize impacts to existing and future park and open space areas. E-3.13 Comment
Chapter 5, Environmental Impacts and Mitigation, Figures 5-41 Parks, Open Spaces
and Cultural Resources (Sheet 8 of 8), page 137:
“Several open spaces in the South Boston seaport district are either privately held or
held by quasi governmental entities like Massport. These should be depicted on this
map so that routing and transit station location decisions can be made with the fullest
information at hand.”
Response
EOT will coordinate with Massport to identify ownership of open space locations in the
vicinity of the South Boston waterfront.
E-3.14 Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.2 Segment A, Section
5.15.2.1 Affected Environment, page 138:
“Part of the scope for the next phase of design and environmental review of this project
should be discussing how the Bremen Street-East Boston Greenway system interacts
with the Urban Ring. As the abandoned rail corridor is sought after for the Urban Ring
and for a greenway connection to Chelsea Creek, we look forward to working with
EOT, BTD, and others on achieving both open space and transportation goals.”
Response
The FEIR will document how the Bremen Street-East Boston Greenway system
interacts with the Urban Ring. EOT will continue to coordinate with Boston Parks and
Recreation Department and other stakeholders as the project design progresses.
Group E - Response to Municipal Comments Page 41
RESPONSE TO COMMENTS ON RDEIR E-3.15
Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.3 Segment B, Section
5.15.3.1 Affected Environment, page 5-144:
“According to a Boston Parks and Recreation Department brochure (A Guide to the 9
Parks of the Emerald Necklace), there are nine parks, not four, in the Emerald
Necklace, as the Necklace extends from Boston Common to Franklin Park….
Therefore, the error in the paragraph on the Back Bay Fens should be appropriately
revised.”
Response
Future environmental review documents for this project will reflect the correct number
of parks in the Emerald Necklace.
E-3.16
Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.3 Segment B, Section
5.15.3.1 Affected Environment, page 5-145:
“Under the heading ’DCR Parkways in Segment B,’ the document states that nearly 1000 square feet of parkland will be taken for Alternative A to allow for a contra-flow bus lane. The parkland is incorrectly referred to as the Fenway; it is called the Back Bay Fens.” Response
Future environmental review documents for the project will reflect the correct name. E-3.17
Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.3 Segment B, Section
5.15.3.2 Environment Consequences, Table 5-45 Areas of Moderate to Significant
Impact in Segment B, page 5-146:
“The relocation of the Back Bay Yard to other locations in the Riverway park as
contemplated in Alternative 3B is difficult to reconcile with the historic/cultural
significance of the design of this park. We hope further discussions with EOT and
others will yield alternatives that avoid this action.”
Response
Temporary relocation of some Back Bay Yard functions is indicated during construction
of the tunnel identified in the RDEIR LPA.. EOT will coordinate with Boston Parks and
Recreation Department and other stakeholders to discuss other options at such time
as the tunnel portion of the project advances.
E-3.18
Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.3 Segment B, Section
5.15.3.2 Environment Consequences, Table 5-45 Areas of Moderate to Significant
Impact in Segment B, page 5-146:
“While Wentworth Institute of Technology is not a City-sponsored institution, its fields
play an important role in the scheme of recreation provision in the city. These fields
provide for the needs of its students, thereby reducing their demand for fields from the
city’s own supply. Further, the City and Wentworth have an agreement that allows
community-based recreation programs to use these fields. Therefore, the use of their
Group E - Response to Municipal Comments
Page 42
RESPONSE TO COMMENTS ON RDEIR fields for a tunnel portal will have an impact on recreation provision in a part of the city
where open space is limited. We hope further discussions with EOT and others will
yield alternatives that avoid this action.”
Response
The LPA alignment in the RDEIR does not include a tunnel portal at the Wentworth
athletic fields on Ruggles Street at Huntington Avenue. EOT will continue to coordinate
with local agencies and stakeholders at such time as the tunnel portion of the project
advances.
E-3.19 Comment
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.4 Segment C, Section
5.15.4.1 Affected Environment, page 5-147:
“In the third paragraph, Melnea Cass Boulevard is simply described as a state
roadway. It should say that sidewalks and a bicycle path are now located in its right-of­
way. It should also mention that it is currently the subject of a design process led by
the Boston Transportation Department to rehabilitate this bicycle path as part of the
South Bay Harbor Trail.”
Response
Refer to the response to comment E-2.11. E-3.20 Comment
Chapter 7, Compliance/Consistency With Massachusetts and Federal Environmental
Laws, Regulations and Programs, Section 7.1, Section 7.1.1, pages 7-7 to 7-8:
Construction of a busway tunnel portal at the Landmark Center will require
heavy construction adjacent to the north and west sides of the Back Bay Yard
building, and temporary relocation of a segment of the proposed multi-use
path. Impacts in the park portion of the project area will be temporary and
construction related, and existing conditions will be restored once the tunnel
is completed and the surface areas above it restored. No significant
permanent adverse impacts to parks and open spaces are anticipated from
this project element, although it will result in a change in use of existing
parkland. During construction, 0.12 acres of parkland may be converted
temporarily and existing conditions will be restored once construction is
completed. None of the parkland will be permanently converted to
transportation use.
“As you can see from the bolded language in the original passage, the reader would likely be confused – a change of use (unspecified) will result, but there is no adverse effect or permanent conversion to a transportation use. The final EIR/S must clarify this statement. Further, the Parks Department must be a party to all discussions on the location and operations of the proposed portal, as it is responsible for the operation and maintenance of a nationally recognized historic and cultural resource, the Riverway, of which the Back Bay Yard is a part.” Response
The change in use refers to the temporary use of the 0.12 acres during construction. After construction, the land would be restored to park use. As the project progresses, EOT will coordinate with the Boston Parks and Recreation Department regarding the location and operations of the proposed portal. Group E - Response to Municipal Comments Page 43
RESPONSE TO COMMENTS ON RDEIR E-3.21 Comment
Chapter 7, Compliance/Consistency With Massachusetts and Federal Environmental
Laws, Regulations and Programs, Section 7.1, Section 7.1.1, pages 7-7 to 7-8:
Avoidance Alternatives
There is no feasible alternative to avoid impacts to the Landmark Center and
the proposed multi-use path other than the proposed LPA.
Measures to Minimize Harm
Because of the de minimis size of the impact, the dense commercial nature of
the area, and the lack of feasible alternative locations for the proposed tunnel
portal that would avoid impacts to the Landmark Center building and
proposed multi-use path, there is no feasible alternative to minimize harm to
the resource other than the proposed LPA.
“Under Avoidance Alternatives and Measures to Minimize Harm, after “…impacts to…” the phrase “the Riverway park and its associated Back Bay Yard” should be added.” Response
This text will be added to future environmental review documents for this project. E-3.22 Comment
Volume II, Response to Comments, Letter ID No. D-5, Received from the Boston Parks
Department dated April 7, 2005, pages 9-52 to 9-53:
“Several responses posit the construction of the tunnel making the particular
comments about taking parklands and wetlands moot. However, as noted above in
Chapter 5, Environmental Impacts and Mitigation, Section 5.15.3 Segment B, Section
5.15.3.1 Affected Environment, page 5-145: Under the heading ’DCR Parkways in
Segment B,’ the document states that nearly 1000 square feet of parkland will be
taken for Alternative A to allow for a contra-flow bus lane.
“Please explain this apparent contradiction in the presentation of the project.”
Response
The 980 square feet of possible taking was associated with the surface routing
identified in the DEIR which was called Alternative 1 in the RDEIR. The reference to
Alternative A is a typo and should be Alternative 1. This alternative and the taking of
parkland in the Back Bay Fens were eliminated through the RDEIR alternatives
analysis process; they are not part of the RDEIR LPA or any interim surface routing
being considered.
Group E - Response to Municipal Comments Page 44
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-4
Received from: Brookline Board of Selectmen
February 3, 2009
Comment No. E-4.1
Comment
Mountfort Street
“The Urban Ring RDEIR/DEIS continues to rely on Mountfort Street in Brookline to
carry two BRT lines from the Longwood Medical Area to the Charles River. During the
development of the RDEIR/DEIS a number of proposed changes to Mountfort Street
were discussed. The current proposal includes a bus lane that travels over the
Turnpike at Carlton Street and a revision of general traffic circulation to permit travel
west on Mountfort Street to continue straight and turn north directly across the BU
Bridge.
“These changes seem less harmful to the Cottage Farm neighborhood than many of
the earlier proposals discussed. However, the Board of Selectmen continues to have
concerns about the impact of the Urban Ring Phase 2 on the Cottage Farm
neighborhood.
“…In particular, the use of 60’ articulated busses along a relatively narrow right-of-way
may have impacts on the character of the area. Noise, vibrations and emissions from
these busses are all of concern to the Town.
“As noted below, the possibility of extending the LMA tunnel across the Turnpike
should be examined further. An extended tunnel could eliminate many of the impacts
to the Cottage Farm neighborhood and possibly improve travel times for the Urban
Ring.
“In the end, any plans for changes to Mountfort Street would have to be approved by
the Town’s Transportation Board. We trust that the state will keep that fact in mind as
changes are planned for the corridor.”
Response
Minimizing impacts to Brookline and the Cottage Farm neighborhood have been major
objectives of the RDEIR planning process that produced the LPA proposal for the
Mountfort Street corridor.
Emissions, noise, and vibration impacts of the Urban Ring buses are discussed in
Sections 5.6 and 5.6 of the RDEIR/DEIS and will be revisited for any locations with
significant changes in the proposed alignment.
Extending the Fenway/LMA BRT tunnel further north under the Mass Turnpike was
evaluated in the RDEIR and found to have significantly higher capital costs and be less
cost effective than the recommended LPA. Given the Commonwealth’s current inability
to fund the LPA tunnel (refer to the NPC Attachment 6, Section 6.2.2), EOT is unable
to recommend an alternative with higher tunnel costs.
The proposed modifications to Mountfort Street are expected to improve transit access
as well as improve general traffic flow and pedestrian safety. EOT will coordinate with
both the Town of Brookline and the City of Boston, as well as other stakeholders, as
this important element of the Urban Ring advances.
Group E - Response to Municipal Comments Page 45
RESPONSE TO COMMENTS ON RDEIR E-4.2
Comment
Roadway Operations and changes
“Both Boston University and residents within the Cottage Farm neighborhoods have expressed concerns regarding the proposed Phase 2 BRT routes and the potential impacts on traffic congestion and safety. Existing and projected traffic conditions along Mountfort Street are constrained at best. We are very pleased to see the RDEIR/DEIS changing the routing of the Urban Ring Phase 2 from the BU Bridge onto the Grand Junction Railroad Bridge. We are similarly pleased to see the RDEIR/DEIS including a Longwood Medical Area tunnel rather than surface routing. We would like to see
further study of the portal location of the tunnel to see if the portal location could be moved from its currently proposed location to a location just before the Grand Junction railroad bridge. Such a change would remove the BRT operations from Mountfort Street.” Response
Refer to the response to comment E-4.1 above. E-4.3
Comment
Relationship to other Plans
“The area around the Turnpike, the BU Bridge, and Commonwealth Avenue is the
subject of several planning efforts…. Clearly all of these plans need to be coordinated
with the Urban Ring Phase 2.
“In most immediate need of coordination are the Boston University plans for the area,
the Town’s interest in the corridor, and the Urban Ring RDEIR/DEIS. Boston University
calls for the most sweeping changes to this corridor. As the planning process for the
Urban Ring moves forward we expect that the Urban Ring and Boston University will
both continue to work with the Town in making sure that common goals can be
implemented in this area through common plans.”
Response
EOT will continue to coordinate with all municipalities, agencies, institutions, and
stakeholders as the project progresses. EOT notes the importance of continuing to
work closely with the Town and BU, in particular, to ensure that all local and regional
goals and needs are considered.
E-4.4
Comment
Protecting the Muddy River
“Since signing an intergovernmental MOA in 1996 the Town has been engaged in an
extensive process with the Commonwealth of Massachusetts, City of Boston, and the
Army Corps of Engineers to make improvements to the Muddy River for both flood
control and environmental purposes. The Town expects that any plans for the Urban
Ring provide adequate safeguards for this important regional asset.”
Response
EOT has coordinated with all of the agencies and stakeholders listed above during
development of the LPA and will continue to do so as work progresses on potential
early actions and major infrastructure elements in this area of the corridor.
E-4.5
Comment
Impact on Transit Service
“While the Board supports transit improvements within the Urban Ring Corridor, the
Board notes that the Urban Ring project, as currently planned, will add little direct
transit service enhancements to the Town. However, the RDEIR/DEIS does estimate a
Group E - Response to Municipal Comments
Page 46
RESPONSE TO COMMENTS ON RDEIR reduction in use of the Green Line central tunnel by 20% from a no-build condition.
Given the crowded condition of the Green Line, which is the primary rapid transit
service serving the Town, this reduction would be an overall benefit to Brookline.”
Response
Comment noted. E-4.6
Comment
Financing
“The issue of how to fund the Urban Ring project remains a significant obstacle to its
implementation. While a great deal of work has been done on the issue of financing,
both by EOT and by the CAC’s finance committee, many questions remain
unanswered. We anticipate that the Town of Brookline will continue to be at the table
as these discussions unfold. In particular, the Town of Brookline is unlikely to support
any effort to seek direct local financing of the project, whether through special
assessment, fees on local parking or other approaches that directly compete with the
Town’s ability to fund its capital and operational needs.”
Response
Refer to the NPC Attachment 6 (Sections 6.2 and 6.3) regarding EOT’s recommended
approach to implementation of the project.
E-4.7
Comment
Interest in Phase 3 of the Urban Ring
“The Brookline Comprehensive Plan supports transit improvements within the Urban
Ring Corridor and notes that Phase 3, which may ultimately involve light rail and/or
heavy rail improvements, will provide the most significant transit service and benefits to
the Town and the region. The Town urges the Commonwealth and the MBTA to jointly
develop a regional transportation plan that provides for short and long term funding
mechanisms which adequately support whatever proposed transit improvements that
might emerge.”
Response
Refer to the NPC Attachment 6 (Sections 6.2 and 6.3) regarding EOT’s recommended
approach to implementation of the project.
Group E - Response to Municipal Comments
Page 47
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-5
Received from: Brookline Preservation Commission
February 4, 2009
Comment No.
E-5.1 Comment
“The Commission is especially concerned about the areas closest to Boston University
and the Longwood Medical area. Cottage Farm and Longwood districts were
developed in the 1840s and 1850s by David Sears and Amos Lawrence. An integral
part of their historic significance is the layout of the streets. Any changes to street
layout, changes to, or the relocation of, structures, as well as all changes of grade
within the Cottage Farm Local Historic District are subject to design review and
approval by the Brookline Preservation Commission.”
Response
EOT will continue to coordinate with municipalities, agencies, and other stakeholders
as the project progresses. It is recognized that any changes to the street layouts,
structures, or grades in the Cottage Farm area will be subject to review by the
Brookline Preservation Commission.
Group E - Response to Municipal Comments Page 48
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-6
Received from: City of Cambridge, Executive Department
February 12, 2009
Comment No. E-6.1
Comment
Financing
“Significant additional work is required to develop a robust and realistic financing
strategy for the project. The work to date to advance a financing and implementation
strategy has been limited, EOT should carefully examine the revenue generation
potential of a range of strategies for generating capital as well as operating funds for
the project. Further, while the City of Cambridge is willing to explore a financing
strategy that includes the potential for some revenues being raised locally, as a first
step, a strategy that relies on a phased implementation plan and traditional sources for
transit funding should be fully investigated as we believe such a strategy is a realistic
goal to pursue.”
Response
Refer to the NPC Attachment 6 (Sections 6.2 and 6.3) regarding EOT’s recommended
approach to implementation of the project. EOT will also coordinate with the City of
Cambridge regarding local funding options.
E-6.2 Comment
Grand Junction path
“Cambridge is very encouraged by the recent acquisition of the Grand Junction rail
right-of-way by EOT…. The City of Cambridge requests that EOT, in conjunction with
Cambridge, Boston and BU officials, act immediately to explore ways to expedite the
reconstruction of the Grand Junction rail bridge as part of the Accelerated Bridge
Program.”
Response
Refer to the NPC Attachment 6 (Sections 6.2 and 6.3) regarding EOT’s recommended
approach to implementation of the project. EOT will coordinate with the City of
Cambridge, Boston, DCR, BU, and other stakeholders to advance the planning of this
major infrastructure element.
E-6.3 Comment
Growth forecasts and ridership projections
“The ridership projections in the RDEIR/S reflect a growth forecast model that has
been updated during this process, and show robust ridership numbers. However, we
believe that the ridership numbers will in fact be even greater for two reasons: First, the
travel model treats future ridership on the existing transit lines as unconstrained by
their very real capacity limitations which. Second, the same land use is assumed for
modeling ridership for the “no-build” and “build” scenarios. In reality, there will likely be
new concentrated transit-oriented-development around the Urban Ring nodes as a
result of Phase 2 resulting in additional ridership.”
Response
See response to Comment G-7.3 regarding ridership projections with capacity
constraints. The ridership projections are from the 2030 CTPS regional transportation
demand model, which uses the MPO’s adopted regional land use forecast to 2030.
Consistent with current FTA guidelines, the ridership projections do not include any
induced demand resulting from implementation of Urban Ring Phase 2.
Group E - Response to Municipal Comments Page 49
RESPONSE TO COMMENTS ON RDEIR E-6.4
Comment
Phase 3
“While this is addressed in the RDEIR/S, we emphasize the critical importance of
ensuring that certain Phase 3 alignments or services not be precluded because of a
project component selected in Phase 2. We recognize that components of Phase 3 will
require substantial reanalysis in the future based on land use and transportation
developments that will occur in conjunction with the implementation of Phase 2, and
urge EOT to continue planning for Phase 3.”
Response
The Phase 2 LPA does not preclude Urban Ring Phase 3, nor does it preclude
converting some portions of the Phase 2 alignment to rail transit technology in the
future.
E-6.5
Comment
Physical separation
“Cambridge is aware that it is EOT’s intention to reserve any exclusive rights-of-way for
BRT vehicles. But, in an effort to allay any concerns that other vehicles might over time
be allowed to access this right-of-way, work should be done immediately to more
carefully analyze ways of physically preventing or otherwise discouraging unauthorized
vehicles from accessing the rights-of-way, including, but not limited, physical
separation, signs, automated gates, cameras, and police enforcement.”
Response
Ways of physically preventing or otherwise discouraging unauthorized vehicles from
accessing the exclusive bus rights-of-way will be further considered and defined during
preliminary engineering and final environmental.
E-6.6
Comment
Cambridgeport station
“Cambridge recognizes that further work is needed in collaboration with MIT and the
neighborhood in finalizing the Cambridgeport Urban Ring station, and the access to
and from the Grand Junction corridor.”
Response
EOT will collaborate with MIT and the City of Cambridge to finalize the Cambridgeport
Urban Ring station location and access to and from the Grand Junction corridor.
E-6.7
Comment
Lechmere station
“Cambridge is pleased that, with the current absence of a developer for North Point,
EOT is working to advance the planning for high quality pedestrian access to both the
future Green Line and Urban Ring stations across Msg. O’Brien Highway from East
Cambridge.”
Response
Comment noted. E-6.8
Comment
Kendall Square bus cut-through
“The LPA alignment includes a bus cut-through that will require modification of the
current Broadway/Main Street/Third Street roadway intersection. The details for such a
Group E - Response to Municipal Comments
Page 50
RESPONSE TO COMMENTS ON RDEIR configuration still need to be worked out with the City of Cambridge and other stakeholders, including the Cambridge Redevelopment Authority, to minimize impacts.” Response
The details of modifications to the Broadway/Main Street/Third Street intersection will be worked out with the City of Cambridge, the Cambridge Redevelopment Authority, and other stakeholders during preliminary engineering and final environmental. E-6.9
Comment
LPA and Longwood tunnel
“The RDEIR/S has established a Locally Preferred Alternative that resolves many of
the issues raised in the DEIR/S. Specifically, the recommended tunnel between
Ruggles Station and Yawkey Station is the preferred way to achieve reliable service
and minimize environmental impacts in the highest ridership segment of the project.”
Response
Comment noted. E-6.10
Comment
Bicycle/Pedestrian access to stations
“The discussion in Section 4.6 only discusses the potentially negative impacts of the
Urban Ring on bicycle and pedestrian travel. The EIR should also include a significant
analysis of how bicycle and pedestrian access to and from the Urban Ring stations can
be enhanced.”
Response
The FEIR will provide additional information regarding the benefits of the Urban Ring
project on bicycle and pedestrian access.
E-6.11
Comment
Allston/Harvard Square alignment
“The LPA includes service to through Allston and on to Harvard Square. While many
questions remain to be addressed before a specific alignment is chosen, this segment
has the potential for high ridership and EOT should take immediate steps to advance
the process for selecting a final alignment.”
Response
Since publication of the RDEIR/DEIS, EOT has advanced the BRT alignment and
configuration through Allston Landing and North Allston. See Attachment 6 (Section
6.2.2) of the NPC document for a description of the alignment and future
environmental review for this portion of the project. EOT will continue to coordinate
with other projects and work with the City Boston (BRA and BTD) and City of
Cambridge to finalize an optimal alignment and station locations in the Allston
neighborhood of Boston and Harvard Square in Cambridge.
Group E - Response to Municipal Comments
Page 51
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-7
Received from: Cambridge Redevelopment Department
February 9, 2009
Comment No.
E-7.1 Comment
“Historically (since December, 2001), the Cambridge Redevelopment Authority has
clearly noted its objection to certain proposed Urban Ring bus routes through the
Kendall Square Urban Renewal Project Area because they require takings of
dedicated open space (Galaxy Park). Those BRT routes include BRT1 and BRT 5.
That history is described in the attached letter, dated October 24, 2008 to the
Executive Office of Transportation (EOT).
“As the supervising public agency for the Kendall Square Urban Renewal Project, we have been requesting to be involved prior to the identification and implementation of any bus routes in the Kendall Square area in order to ensure that any potential adverse impact is minimized. We have cited that – in our opinion – the potential impact of the proposed routes constitutes a fundamental change to the federally-funded Kendall Square Urban Renewal Project. Both the Department of Housing and Urban Development (HUD) and the Commonwealth have approved this project. “Further, we believe that the routes require Section 4(f) evaluation and a two-thirds majority vote of the Massachusetts legislature in order to remove this dedicated open space from our already limited inventory.” Response
See response to Comment G-6.2 regarding Galaxy Park impacts.
EOT will coordinate with the Cambridge Redevelopment Authority and the City of
Cambridge regarding bus routes in the Kendall Square area and endeavor to minimize
potential impacts and minimize changes to the Kendall Square Urban Renewal Project.
Group E - Response to Municipal Comments Page 52
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-8
Received from: City of Chelsea, Department of Planning and Development
February 10, 2009
Comment No.
E-8.1 Comment
“I would like to stress the importance of the need to preserve opportunities for
development of the Urban Ring in Chelsea by securing the abandoned CSX ROW.
The CSX ROW provides an opportunity to create a BRT route separate from other
traffic, to improve headways, and to keep travel time to a minimum. It also establishes
a key link between the City’s residential neighborhoods, its Central Business District,
and the industrial and commercial business areas at Everett Avenue. Multi-use of the
ROW for the Urban Ring as well as pedestrian and bicycle trails is also a possibility
and would increase ridership on the proposed BRT route. Acquisition of the entire
ROW is imperative if we are to assure development of the Urban Ring as envisioned in
the RDEIR.”
Response
As noted in the RDEIR/DEIS (Section 2.1.2) and in this NPC, the principle outstanding
issue in this portion of the alignment is acquisition of the CSX-controlled abandoned
rail corridor. Protecting the integrity of this abandoned rail corridor was identified in the
2001 MIS and the 2004 DEIR as a high priority to facilitate its acquisition and
conversion to transit use for the Urban Ring. Acquisition of the abandoned rail corridor
in this area continues to be an important priority for this project, which EOT is actively
pursuing.
Group E - Response to Municipal Comments Page 53
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: E-9
Received from: City of Somerville, Office of Mayor
January 23, 2009
Comment No. E-9.1
Comment
Somerville Locally Preferred Alternative (LPA):
“The Executive Summary describes a different alignment than the Somerville LPA map
as shown on Sheet 3 of 8, while the report correctly follows the alignment that we
prefer which runs along Middlesex and Mystic Avenues. We appreciate EOT staff’s
willingness to include the Middlesex/Mystic Avenue/Foley Street alternative in the plan
and believe it will provide the best access for the new development anticipated in this
area.”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended alignment
change, which will continue to include service to Assembly Square. The proposed
routing will be clarified in the FEIR to eliminate this inconsistency.
E-9.2 Comment
Proposed BRT 5:
“The terminus of BRT 5, which is currently planned for Sullivan Square, should be
moved north to Assembly Square to provide a one-seat ride from Assembly Square to
the Longwood Medical Area (LMA). As you know, Assembly Square will soon be home
to 2,100 new housing units and nearly 3 million s.f. of office and retail development.
Potential riders who would likely embark the Urban Ring at Assembly Square will be
less likely to do so if they need to change seats at Sullivan Square, less than 0.5 miles
away.”
Response
Extending the northern terminus of BRT5 (or comparable Urban Ring service,
depending upon implementation of early actions) from Sullivan Square to Assembly
Square is a feature of the recommended alignment change described in the NPC
Attachment 6 (Section 6.1).
E-9.3 Comment
Proposed BRT 2:
“Chapter 2 of the Report and ES-9/ES-14 describe two different termini: Wellington and Sullivan Square, also shown on ES sheet 3 of 8.” Response
Refer to the NPC Attachment 6 (Section 6.1) and responses to E-9.1 and E-9.2 above. E-9.4 Comment
Proposed BRT 6:
“If possible, we encourage that BRT 6 be extended from Harvard Square to Sullivan
Square via Union Square to provide additional access from Somerville to Harvard at
Allston and eventually LMA.”
Response
The existing MBTA #86 bus route connects Harvard Square with Sullivan Square via
Union Square. Roadways in this corridor are not compatible with BRT operations, and
Group E - Response to Municipal Comments Page 54
RESPONSE TO COMMENTS ON RDEIR service improvements on the #86 bus, if necessary, should be pursued through the
MBTA service planning process.
E-9.5
Comment
Existing bus routes:
“With the addition of the Urban Ring bus lines, it appears the current CT buses will
cease (CT data removed from Report tables). The CT-2 currently passes through
Somerville (starting at Sullivan Station) with connection to Union Square, however, as
planned the Urban Ring lines will not pass through Union Square. We would
encourage that this be reconsidered – given the new development anticipated for the
area (Union Square Rezoning Plan 2008), it seems pertinent to keep the connections
in Union Square. Assessing whether a route can pass through Union Square, one of
Somerville’s major centers, is desired.”
Response
See response to Comment E-9.4 regarding project alignment through Union Square.
Most of the existing CT routes become redundant when Urban Ring Phase 2 BRT
routes are implemented. In some areas, such as Union Square, the need to continue
portions of an existing CT route will be reconsidered in the FEIR.
E-9.6
Comment
Speed of service:
“The Somerville segment is comprised of mainly medium speed, while much of the
overall system is faster (Page ES -18). Why?”
Response
Speed calculations are based on average speed between Urban Ring Phase 2 BRT
stations. The LPA Urban Ring Phase 2 alignment through Somerville is in mixed traffic
between Sullivan Square and Wellington Station. Speeds increase for the alignment to
the south of Sullivan Square where bus lanes or busways would be provided, such as
along portions of Washington Street and Inner Belt.
E-9.7
Comment
Signal Technology :
“For the portions of the corridor that are in mixed traffic and not on reserved busways
(totaling 47% of the 25 mile corridor, or 11.75 miles), signal prioritization for the buses
should be a high priority to ensure timely passage of these vehicles.”
Response
Comment noted. Bus Signal Priority is proposed for many intersections where buses
are operating in mixed traffic.
E-9.8
Comment
Traveler information:
“Inclusion of real time traveler information at every station would provide riders
accurate information of when the next bus will arrive. This technology can be found in
other urban areas, such as San Francisco, today. We would hope that it would soon
arrive in the Boston Metro region.”
Response
Comment noted. Real time traveler information will be considered for Urban Ring BRT
stations.
Group E - Response to Municipal Comments
Page 55
RESPONSE TO COMMENTS ON RDEIR E-9.9
Comment
Ticketing mechanism:
“Tickets should be purchased before boarding the bus and entrance into the station
should be controlled so that only ticket holders are allowed in, allowing for efficient,
quick boarding when the bus stops at the station.”
Response
Fare collection options which speed boarding will be further evaluated during
preliminary engineering and final environmental. Pre-paid boarding and “Proof of
Payment” are two approaches that will be considered in the context of local conditions,
space availability, travel demand, and MBTA fare policies and practices.
E-9.10
Comment
Vehicle daily trips:
“Where are the majority of the road trips being reduced? Somerville has its share of
auto traffic on I-93, Route 28 and other major roadways – are these poised to see a
reduction in daily trips?”
Response
Some auto trip reduction occurs throughout the corridor with the LPA compared to the
No-Build, including areas in Somerville. Table 4-27 of the RDEIR/DEIS summarizes
changes in roadway traffic volumes between the No-Build and Build LPA alternatives.
E-9.11
Comment
Pedestrian trips:
“Number of daily walk trips are supposed to decrease with the LPA (Page ES-16), but
environmental benefits (Page ES-21) say that greater reliance on pedestrian oriented
movement would occur – how do these two relate to one another?”
Response
The travel model forecasts show that the number of walk-only trips would decrease as
a result of the LPA. This is due to better availability of transit service that would attract
some commuters who make their trips only by walking. That is, walk-only trips are
expected to be replaced by walk-access transit trips. The new LPA service would
provide new connections to neighborhoods and short headways that would provide a
faster commute alternative for many people compared to existing transit services or
driving. The new service would promote walking directly to Urban Ring stations. The
proposed LPA will support TOD development and Smart Growth developments that will
be located in established and emerging neighborhoods which are more conducive to
walking and are less reliant on single-occupant automobiles.
Group E - Response to Municipal Comments
Page 56
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-1
Received from: A Better City
February 10, 2009
Comment No.
F-1.1 F-1.2 Comment
“The Final EIR/EIS should include a more detailed phasing and implementation plan
that identifies specific early action items and provides schedules for their
implementation.”
Response
Refer to the NPC Attachment 6 (Section 6.2), for the proposed implementation plan
and proposed early action items.
Comment
“Immediate next steps should be taken to initiate any additional analysis and
engineering, including release of bond funding designated for these purposes, that will
advance the Urban Ring tunnel design, and the timely implementation of early actions
that will provide improved transit service in segments located throughout the corridor,
with an emphasis on segments where the need for transportation improvements is
greatest.
“Issues of funding sources for capital and operating costs needs to be more fully
explored and documented in greater detail.”
Response
Refer to the NPC Attachment 6 (Section 6.2), for the proposed implementation plan
and proposed early action items
The Urban Ring Phase 2 project implementation plan has been developed, and will
continue to be informed by, the financial environment, including the Boston Region
MPO RTP, Commonwealth of Massachusetts revenues, and federal funding sources,
including the FTA New Starts program and the upcoming new federal transportation
authorization.
F-1.3 Comment
“EOT should move toward adopting a final Locally Preferred Alternative by laying out a
schedule for resolving the key remaining issues.”
Response
A Locally Preferred Alternative was identified in the RDEIR/DEIS. Since the
submission of the RDEIR/DEIS, EOT has advanced the BRT alignment and
configuration in the area of North Allston, Suggested alignment changes since
publication of the RDEIR/DEIS are described in Section 6.1 of the June 30, 2009 NPC
document.
Section 6.2 of the NPC discusses the implementation plan and scheduling issues. As
noted in Section 6.3 of the NPC (special review procedures), EOT intends to pursue
final environmental review on the Urban Ring Phase 2 – Northern Tier and early
actions (both service and infrastructure improvements) in the Southern Tier. EOT will
pursue final environmental review of major elements in the Southern Tier when
outstanding issues have been resolved and funding is available. No schedule can
currently be given for planning and environmental review for Urban Ring Phase 3 that
would allow these environmental review filings to remain relevant.
Group F - Response to Community Advocacy and Organization Comments
Page 57
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-2
Received from: Alternatives for Community and Environment
February 10, 2009
Comment No. F-2.1
Comment
An essential feasibility alternative has not been described or analyzed:
“Our central concern is that the RDEIR/DEIS fails to comply with the Massachusetts
Environmental Policy Act (MEPA) because all the alternatives presented are buses in
various routes and combinations. A central requirement of MEPA is a full description
and analysis of all feasible alternatives to the proposed project, including but not
limited to those indicated in the scope. 301 CMR 11.07 (6)(f). The rail alternative, a key
feasible alternative to the proposed project, is neither described nor analyzed.
“We fully understand that the Executive Office of Transportation (EOT), the project
proponent, has conceived the Urban Ring with Phase 2 as buses and a later Phase 3
to include rail transit but because EOT has conceived the project in those phases does
not mean EOT is not required to compare bus to rail alternatives at his juncture of
environmental review. The Urban Ring is not a bus project. It is a circumferential
transportation improvement project that is intended to improve mobility in parts of the
Boston metropolitan area. Rail is a feasible alternative to bus to accomplish those
goals and thus must be analyzed and compared to the proposed bus alternative. EOT
must compare implementing phase 2 to eliminating phase 2 and going directly to
phase 3.
“EOT’s current proposal is overly expensive because it would first create a bus
infrastructure and require the purchase of buses, and then later convert that
infrastructure to rail, with many costs and environmental burdens that would be
avoided by going directly to rail. The impacts of that additional expense are not
described or analyzed. Further, there is no guarantee that EOT would ever proceed to
rail if it implements the bus alternative. Thus, EOT would never describe and analyze a
feasible alternative that we believe is superior to the proposed alternative.”
Response
The Major Investment Study (MIS) evaluated and compared a wide range of transit
modes, including rail, and recommended a three phase approach to transit
improvements in the circumferential corridor. The phased approach was approved in
the November 16, 2001 Expanded ENF Certificate consisting of improved bus service
in Phase 1; Bus Rapid Transit (BRT) with new and improved commuter rail
connections in Phase 2; and rail transit in only the densest portion of the corridor in
Phase 3. In accordance with this and subsequent Certificates, Phase 2 planning was
conducted with full consideration of future Phase 3 requirements. Phase 2 as defined
in the RDEIR will not preclude the development of Phase 3. Refer to the NPC Section
6.2 and 6.3 regarding the Phase 2 Fenway/LMA tunnel and the status of Phase 3.
F-2.2 Comment
Center Busway on Melnea Cass Blvd. (pp. 2-33 and 4-95):
“The RDEIR/DEIS indicates that plans for the center busway on Melnea Cass Blvd.
were created in coordination with various groups, including a “Roxbury neighborhood
group” but that group is not named. The only Roxbury neighborhood group recognized
by state statute governing zoning and development in Roxbury and given advisory
status for development in Roxbury, is the Roxbury Neighborhood Council. Article 50 of
the Boston Zoning Code. There is no indication that EOT coordinated with the Roxbury
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR Neighborhood Council and should be required to do so for all parts of the Urban Ring
that pass through Roxbury.
“The description of the proposed center busway on Melnea Cass Blvd. is markedly
inadequate. It fails to describe the existing environment or the impacts of the busway,
even though required by CMR 11.07 96) (f-g)…. We could find nothing in the
RDEIR/DEIS about the impact of a center bus lane on traffic, traffic congestion, air
emissions from traffic, or pedestrian issues (other than it would help facilitate
development of a proposed South Bay Harbor Trail, but there is no information on how
it would facilitate that development). Further, there is no indication of whether any land
taking would be required even though adding two lanes for the center busway would
appear to require more roadway space than currently exists.
“We have not had the opportunity to compare the claims in the RDEIR/DEIS to the
facts on the ground on portions of the Urban Ring other than Melnea Cass Blvd., but
the omissions and inadequate information provided about the route on Melnea Cass
Blvd. should raise serious concerns about the accuracy and completeness of other
portions of the RDEIR/DEIS.”
Response
The Urban Ring CAC membership appointed by the EOEEA Secretary includes
Charlotte Nelson of the Roxbury Strategic Master Plan Oversight Committee who has
participated throughout development of the RDEIR, including the alignment
alternatives considered along Melnea Cass Boulevard. Throughout the RDEIR the
project team coordinated closely with the Roxbury neighborhood through its
designated representatives and with BRA and BTD at the City of Boston. Additionally,
several public meetings were held in Dudley Square to present project concepts,
answer questions, and obtain neighborhood input. Traffic and environmental impacts
of the project were evaluated and are summarized in the RDEIR in Chapters 4 and 5
respectively. Additionally, the project website contains the supporting technical reports
related to the RDEIR.
F-2.3
Comment
Silver Line and bus rapid transit (p. 4-19):
“The RDEIR/DEIS description of the existing Silver Line is incorrect in many aspects,
which is important because the RDEIR/DEIS likens Urban Ring Phase 2 to the Silver
Line.
“Silver Line Phase 1 is not bus rapid transit. The Silver Line between Dudley Square
and Downtown Crossing has few of the indicia of bus rapid transit. There is no
separated bus only lane, no bus priority at the traffic signals, no preboarding
payments, no rapidity…. There is no reason to believe that most of the Urban Ring bus
network would fare any better.
“The RDEIR/DEIS incorrectly claims that the Silver Line operates in a bus only lane on
portions of Washington St. The lane is legally used not only by the bus but also for
right turns by all vehicles, for entering and leaving parking spaces, for cars dropping off
and picking up passengers, and for trucks making deliveries. The lane is regularly
used for illegal double parking. It does not work on Washington St., and by extension
will not work for much of the Urban Ring bus routes. The description in the
RDEIR/DEIS of Urban Ring Phase 2 as bus rapid is incorrect.
“At public meetings, EOT staff have explained that the Urban Ring buses would
average about 10 miles per hour. That is not bus rapid transit.”
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RESPONSE TO COMMENTS ON RDEIR Response
The Silver Line service has several bus rapid transit elements including tunnel in the
convention center area, bus lanes and bus signal priority along Washington Street, and
high capacity buses. Signalized intersections along the Washington Street corridor
operate with bus signal priority control under control of the Boston Transportation
Department, in coordination with MBTA bus operations. A key issue for Silver Line
operations on Washington Street is that it is located adjacent to a parking lane, which
introduces conflict from parking operations and double-parked vehicles; the Urban
Ring Phase 2 includes no bus lanes adjacent to on-street parking lanes. Unlike the
Silver Line on Washington Street, the proposed Urban Ring on Melnea Cass
Boulevard would utilize a center median busway that avoids these conflicts. Another
issue on Washington Street is bus lane enforcement. EOT and the MBTA recognize
this and work together to develop enforcement policies and implementation that can be
used for the Urban Ring.
Average travel speeds were calculated for segments and sectors of the LPA (see
Tables 2-2 through 2-13 of the RDEIR/DEIS). Average overall speed for the segments
range between 11 and 18 MPH. The average speed for Washington Street at Dudley
Square is 10 MPH. However, the average speed on Melnea Cass Boulevard is 17
MPH. It is noted that the average travel speeds include all stopped time at station
stops, intersections, etc. These speeds are generally higher than for general traffic
under future conditions.
F-2.4
Comment
Environmental Justice (pp.5-8 – 5-25):
“The section on environmental justice, a half-page of text and a few pages of tables
and a figure showing where the Urban Ring is compared to environmental justice
populations, is significantly inadequate. It fails to define environmental justice
populations appropriately or provide any analysis of the project’s impact on those
populations. Simply noting the proximity of the project to environmental justice
populations is not an environmental justice analysis.
“First, the RDEIR/DEIS does not use the Massachusetts definition of an environmental
justice neighborhood…. Notwithstanding, the RDEIR/DEIS uses a different definition
based on traffic analysis zones and different minority and income percentages. Yet,
the RDEIR/DEIS provides no explanation of why it chose those criteria and why it did
not apply the criteria used by EEA. It should be required to include the EEA criteria for
environmental justice neighborhoods.
“Second, the RDEIR/DEIS asserts that none of the bus alternatives would have
disproportionately high and adverse impact on low income or minority populations in
the corridor but provides absolutely no information or data to support that assertion…
“Third, showing that the urban ring corridor passes through environmental justice
neighborhoods does not automatically lead to the conclusion set forth in the
RDEIR/DEIS that the residents of the neighborhoods would have improved access to
transit, transit travel time savings, and other benefits…. The urban ring buses would
follow the existing 1, 8, 19, and 47 routes from Dudley Sq., for part of the route, but the
RDEIR/DEIS contains no description or analysis of whether those trips would be faster,
slower, or not significantly different than current transit options.
“Fourth, and perhaps most telling, the proposed bus tunnel stops at Ruggles Station,
rather than extending into Roxbury, thus relegating the many transit users in Roxbury
to surface transit in often gridlocked traffic. An environmental justice alternative that
should have been described and analyzed was connecting the tunnel into Dudley Sq.,
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR the most highly used bus station in Boston, so that riders there would have a direct
underground route to Ruggles Station and the Longwood Medical Area.”
Response
The level of Environmental Justice (EJ) analysis provided in Section 5.3.2.4 (beginning
on page 5-18) in the RDEIR/DEIS is reasonable given the size and scope of the
project. The analysis in the RDEIR/DEIS shows that the proposed Urban Ring LPA
provides new or improved service to a significant number of existing EJ neighborhoods
and populations (218,600 residents in year 2000). This represents a major
improvement in transit access and mobility for EJ populations compared to the NoBuild. Use of ½ mile station catchment areas for quantifying the number of residents
and jobs within reasonable walk distance of a new service is an accepted measure
used by the Federal Transit Administration for its New Starts funding program.
As stated in the response to F-2.3 the proposed center median surface busway along
Melnea Cass Boulevard will provide higher travel speed and reliability compared to
existing bus service.
Extending the LPA BRT tunnel south of Ruggles station to Dudley Square would
require an underground station deep beneath the existing Southwest Corridor which is
already below grade, while increasing the cost and complexity of the project in an area
which has sufficient right of way on the surface, including the existing Ruggles Station
bus loop, to accommodate additional dedicated busways or buslanes.
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-3
Received from: Association for Public Transportation
February 9, 2008
Comment No.
F-3.1 Comment
“The challenges for this project are many. One could start with the tremendous
expense of the wide tunnels through which the buses will crawl, or the curly-cues and
switch backs in the routing which has give the project the nickname of ’Urban Pretzel.’”
Response
The proposed LPA provides service which will be significantly faster and more reliable
than existing buses in mixed traffic, while balancing regional transportation goals with
the needs of local stakeholders.
F-3.2 Comment
“Another concern is the manner whereby the Bus Rapid Transit (BRT) right-of-way
(ROW) will segregate neighborhoods and make commuting difficult. There are also the
unsoundly designed choke points in the ’BRT-in-mixed-traffic‘ segments of the route. In
these segments, the Commonwealth’s Executive Office of Transportation (EOT) is
projecting bus speeds in the 5 to 9 mph. This begs the question as to why the
Commonwealth is spending billions of scarce capital dollars on a project with such
poor performance, as these designed-in choke-points will adversely impact vehicle
availability and timeliness throughout the line.”
Response
Only one short section of the LPA is estimated to operate with average speeds below
10 MPH: Columbia Road between JFK/UMass and Edward Everett Square. Dedicated
right of way for busways and bus lanes on roadways will be implemented where
possible and enforced. For areas where preserving dedicated running ways for buses
does not currently appear feasible, other measures to improve travel time and reliability
will be provided. EOT will continue to work with agencies and municipalities to advance
these measures and evaluate additional technologies and systems to improve
reliability and travel speed as the project advances to preliminary engineering.
F-3.3 Comment
“APT is primarily concerned with the sheer numbers of projected riders, and the
assumptions underlying those numbers. It is not believable that commuters will willingly
detrain from comfortable commuter rail coaches by the hundreds, in the heat of the
summer and bitter cold of winter, to stand in line at an exposed bus stop for a BRT
bus. Studies on commuter behavior have established this fact. Instead, these
commuter rail riders will continue on their trains into Boston and take the subway out to
their destination. This disputes the EOT assessment that the Urban Ring will relieve
central subway congestion.”
Response
Ridership projections were developed using the CTPS regional travel demand model. The model is used to estimate travel mode and route between commuter origins and destinations. The model ultimately predicts ridership patterns based on travel time. Therefore, the model will predict shifts in ridership patterns based on travel time savings comparisons. Group F - Response to Community Advocacy and Organization Comments
Page 62
RESPONSE TO COMMENTS ON RDEIR At a minimum, all BRT stations will provide some weather protection. Many Urban Ring
stations are co-located within existing multimodal stations where such transfers already
occur, such as at Sullivan Square Station and at Ruggles Station. The design of new
stand-alone stations will consider weather protection needs and apply context sensitive
design principles during preliminary engineering and final environmental.
F-3.4 Comment
“Let us assume the EOT ridership projections of nearly 200,000 riders a day are
accurate. EOT has chosen BRT as the locally preferred alternative mode for this line –
how many busloads would be required to transport 200,000 riders? An airport – style
BRT bus seats 38; a standard configuration bus seats 47. Bottom line – it would take in
the range of 2,500 busloads to carry 200,000 passengers. Each bus is 60 feet long, so
if 2,500 buses were placed front to back in a row, they would extend for over 28 miles.
The entire Urban Ring ROW is 25 miles in one direction. How can this work? If the
mode for the Urban Ring were Orange Line or Red Line class rail, with 700 to 1,000
riders on a train, this line would be operationally feasible, but the idea of sending 2,500
busloads over Greater Boston’s already congestion streets just does not make sense.
“The congestion problem in the Fenway area, and its effect on bus service, can be
experienced today by investigating the performance of the CT1 (Cross Town 1) bus.
This service, sometimes referred to as Urban Ring Phase 1 is severely impacted by
rush hour traffic. Its performance degradation is most pronounced during evening rush
hour, especially when the Red Sox have a home baseball game…. It should be noted
that the Red Sox have, at minimum, 81 home games a year.
“Greater Boston’s experience with BRT has not been a success. BRT Silver Line
service replaced the elevated Orange Line in the Washington Street corridor from
downtown Boston to Dudley Square…. How can the MBTA and EOT possibly claim
that his project and technology is a winner? To the contrary, APT would state that BRT
and the Silver Line are a dismal, disappointing failure.”
Response
The assumptions about vehicle capacity and loading are incorrect. Based on various
industry standard bus configurations, the RDEIR/DEIS assumes that a 60-foot
articulated bus has seating capacity for 47 plus 19 standees; overall peak loading
capacity would be higher (approximately 80-90 passengers). In addition, the projected
184,000 daily passengers would not ride at the same time nor ride the entire 25 miles
of the corridor. The Urban Ring by its design is expected to largely attract relatively
short transit trips between proximate radial lines in the MBTA system, with frequent
passenger turnover for a given transit vehicle as it progresses along the route. Table 4­
20 of the RDEIR summarizes peak load points for the BRT in the AM peak hour. EOT
will further evaluate the issue of accommodating peak demand as the project
progresses and the operating plans and ridership forecasts are updated.
Improvements such as bus lanes and bus signal priority will be used to improve bus
travel times in this area as part of the early action items discussed in the NPC.
See response to Comment F-2.3 regarding the existing Silver Line.
F-3.5 Comment
“APT final objection concerns the impact of 2,500 busloads of commuters will have on
Greater Boston air quality as well as greenhouse gas emissions. In light of concerns
about climate change, it is both counter-productive and counter-intuitive to be using a
mode that will exhaust greenhouse gasses created by either diesel or CNG
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR (compressed natural gas) buses when a green alternative, electrified rail, is readily
available.”
Response
The project is committed to providing low emissions vehicle technology such as
electric, hybrid or dual-fuel buses. Section 3-3 of the RDEIR/DEIS reviewed four
specific options for bus propulsion technology, including dual mode, hybrid electric,
emission controlled diesel (ECD), and compressed natural gas (CNG). The
recommended bus vehicle technology for Urban Ring Phase 2 identified in the RDEIR
for hybrid electric. Vehicle technology is advancing rapidly and the choice of vehicle
technology will be further reviewed in preliminary engineering and final environmental.
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-4
Received from: Audubon Circle Neighborhood Association
February 11, 2009
Comment No.
F-4.1 Comment
“In the Urban Ring Phase 2 Fact Sheet, the area listed as the Medical/Academic area
neglects to acknowledge the existence of a residential neighborhood, Audubon Circle,
lying between these two districts.”
Response
Comment noted. Subsequent environmental review publications will note the existence
of the Audubon Circle neighborhood.
F-4.2 Comment
“The disparity between what the Fact Sheet discloses about the future plans for our
neighborhood and the plans laid before us at the presentation that the Urban Ring
representatives made at a board meeting in October 2008 is substantial. In the current
report Audubon Circle and the adjacent area are designated as still under analysis.
None of the changes from the original plan, which the ACNA Board of Directors
thought had been effectively mediated may or may not be carried out. Any of the many
proposed alternatives may be chosen, and/or any other solutions may be sought
without consulting Audubon Circle representatives.”
Response
The fact sheet was published in January 2009, approximately three months after the
October 2008 presentation. Some facets of the project may have changed during this
time period as a result of additional analysis and/or public input. EOT will coordinate
with the ACNA board of directors and other stakeholders as the project progresses to
minimize potential impacts in this area.
F-4.3 Comment
“The report fails to take into consideration that in this designated area, namely the part
adjacent to the Landmark Center, the Army Corps of Engineers are redefining the
course of the Muddy River and will ‘daylight’ it as it passes under or crosses over Park
Drive. Also, the Boston Transportation Department is planning to reconfigure Park
Drive and its tangential streets. And still other changes will occur relative to
Rosenthal’s Project 7.”
Response
The LPA will not conflict with any of the proposed changes by the ACOE or BTD. EOT
has coordinated with BRA and the Parcel 7 developers to accommodate the needs of
both projects.
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-5
Received from: Bike to the Sea, Inc.
(No date listed)
Comment No.
F-5.1 Comment
“Bus Rapid Transit (BRT) Vehicles should be designed to allow some bicycles on each
vehicle at all times including commute hours. This can readily be achieved by including
bicycle hooks as is done on new light rail vehicles in many communities across the
country including Portland Oregon, as well as MBTA buses.”
Response
Bike racks on BRT buses will be considered during preliminary engineering and the
FEIR.
F-5.2 Comment
“All stations should be made accessible to bicycles and pedestrians and include safe
and secure bicycle parking.”
Response
Prototypical BRT stations depicted in the DEIR on pages 3-28 and 3-29 show bicycle
parking at bike racks, and all stations will be fully accessible to pedestrians and meet
ADA accessibility requirements. The specific layout and capacity of bicycle parking at
each station will be addressed during preliminary engineering and final environmental.
F-5.3 Comment
“The Urban Ring project should be required to construct a connection from West and
Wellington Street to the new station in Everett. As a trail terminus station, this station
should be designed to have significant bicycle parking; at least 100 spaces should be
included based on use at Malden and Oak Grove Stations.”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended alignment
change in this area. EOT will continue to work with the City of Everett to define
pedestrian connections between the planned Everett Station and the neighborhoods to
the north. Refer to response to Comment F-5.2 regarding bicycle parking.
F-5.4 Comment
“The Urban Ring Route must be designed so that the Northern Strand Community Trail
can have a safe and continuous off-road connection through Everett…. The Urban
Ring route must be designed to allow these connections to be maintained and built…”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended alignment
change in this area.
Bicycle/pedestrian accommodations, including those suggested in this comment will be
considered, as applicable, during preliminary engineering and final environmental.
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR F-5.5 Comment
“The BRT plans call for a tunnel under the Eastern Branch Railroad to connect the
Chelsea ROW to the Everett Station. This should also incorporate a pedestrian under
pass so that the residents of Everett who live in the neighborhood south of Route 99
can access the Everett Stations.”
Response
The proposed BRT tunnel is in an area of active passenger and freight railroads not
amenable to safe pedestrian access. Pedestrian access will utilize sidewalks on the
existing Route 99 overpass with other surface sidewalks and pedestrian bridge access
considered appropriate to the final location chosen for the Everett BRT station.
F-5.6 Comment
“The loss of open space in Everett should be mitigated as close as possible to the
location of the loss. The Northern Strand and the Malden River Park are perfect
projects to replicate the lost open space.”
Response
Refer to the response to Comment F-5.3 above. Group F - Response to Community Advocacy and Organization Comments
Page 67
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-6
Received from: Charles River Watershed Association
February 10, 2009
Comment No.
F-6.1 Comment
“We support many of the revisions presented in this filing; we also believe the lack of
planning for stormwater management at this stage of the project is a serious problem,
and that the MEPA process requires that stormwater management planning be
addressed.
“We urge you to scope the FEIR to require a significant and meaningful discussion of
stormwater management design and alternatives, including infrastructure and
operations and maintenance, and to require at a minimum that the project be designed
to meet the requirements of any TMDLs that have been completed in any of the
receiving waters into which stormwater runoff from the Urban Ring will discharge,
including project areas where runoff will discharged into existing drainage
infrastructure.
“…The RDEIR does not even discuss stormwater impacts in its discussion of the
impacts of the preferred alternative.
“Of particular importance in the Charles River, conventional ’gray pipe‘ infrastructure is
very ineffective at reducing nutrient loads in stormwater. It is unlikely that infrastructure
designs that rely on conventional piped infrastructure for managing stormwater will
achieve the requirements of the Charles River Nutrient TMDL.
“Decisions about the types and locations of stormwater management BMPs should be
made early on in the design process, following context-sensitive design guidelines, and
using integrated planning approaches. Bridge and tunnel stormwater management
designs are of particular importance as they can have direct and significant impacts on
groundwater, wetland resources and receiving water quality. Materials such as open
course asphalt should be considered to reduce pavement pending, splashing and
erosion of vegetated areas alongside the roadways.
“The Urban Ring presents many opportunities to develop improved stormwater
management approaches, and we believe these opportunities need to be examined
fully in the process leading to the development of the FEIR.”
Response
Future environmental review documents for this project will provide an expanded
discussion of stormwater management design and alternatives. The project will be
designed to meet the requirements of TMDLs for any of the receiving waters into which
stormwater runoff from the Urban Ring discharge.
Integrated planning approaches will be used for bridge and tunnel stormwater
management designs. Materials such as open course asphalt will be considered.
Opportunities to develop improved stormwater management approaches will be
implemented where viable.
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-7
Received from: Emerald Necklace Citizens Advisory Committee
February 10, 2009
Comment No.
F-7.1 Comment
“We are concerned about any interim temporary buses that would run on The Fenway
adjacent to the Parklands…. Decades ago our park commissions determined that
allowing large vehicles on them would compromise both the physical environment and
the quality of the park experience. As a result, travel upon them was officially limited to
’pleasure vehicles‘ only with large buses and trucks prohibited. By enacting this
measure of protection, the Commonwealth reinforced the public’s right to safety in,
access to, and enjoyment of their parks.”
Response
See response to Comment E-3.7 regarding the status of interim routing in the
Fenway/LMA.
F-7.2 Comment
“We ask that if temporary interim bus service is to be considered, that the existing bus
services be carefully evaluated to ensure that they are running at optimal efficiency for
the ridership demand, before any additional services would be considered, and that the
public be engaged to evaluate any proposed interim bus service.”
Response
Comment noted. See response to Comment E-3.7 regarding the status of interim
routing in the Fenway/LMA.
F-7.3 Comment
“The FEIR/S should include projected noise and vibration levels and to the parkway
abutters, the Park, and the parkway itself. We believe the optimal short-and long-term
solution to these problems is the tunnel concept.”
Response
Any recommended interim surface routing in the Fenway/LMA will consider noise and
vibration levels.
See response to Comment C-1.2 regarding implementation in the Fenway/LMA.
F-7.4 Comment
“Following the conclusion of the environmental review process, we request that EOT
and the MBTA continue to meet regularly with the CAC and abutters. A regular agenda
item should be an update on cost estimates. We encourage the state to focus on
engineering design solutions for the proposed tunnel technology and routing options,
so that future decisions will be based on better cost estimates and viable alignment
options.
“The FEIR/FEIS should include more detail on the technology that will be used to
tunnel under the Muddy River and any impacts that might have on the parkland.”
Response
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RESPONSE TO COMMENTS ON RDEIR See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. For additional detail on the tunneling technology and related issues
considered in the RDEIR refer to the Technical Tunnel Alternatives Summary Report
available on the project website at www.theurbanring.com.
See response to Comment E-4.4 regarding LPA alignment in the vicinity of the Muddy
River.
F-7.5 Comment
“The FEIR/FEIS should include details on how the bike path adjacent to the Landmark
Center and the Fenway portal for the Urban Ring tunnel will be laid out to work
together.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. The LPA tunnel defined in the RDEIR was coordinated with the
City of Boston proposed path in this area. The path would be located over the tunnel
west of Miner Street and adjacent to the tunnel portal east of Miner Street. Future
environmental review documents for this project will update and further clarify how the
path will work with the proposed Urban Ring portal.
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-8
Received from: Fenway Civic Association
January 26, 2009
Comment No.
F-8.1 Comment
“The preferred alternative in the DEIR, while greatly improved from the original design,
continues to rely upon buses traversing The Fenway parkway. If allowed to proceed,
the result would be to sacrifice people’s safety in the enjoyment of and access to their
parks, residences, and institutions that surround the parks, under the MBTA’s
presumption that the buses will 1) be effective in improving public transit and 2) be a
temporary event until an underground or surface rail option is built. Given the failures
of surface transportation and the likelihood that once allowed, buses would never leave
our parkways, it is our conviction that this part of the plan would be a greater detraction
than contributor to our public transportation needs.
“We recommend instead that the ’temporary‘ phase be skipped for this section of the Urban Ring, that existing bus and E line transit service be greatly improved, along with area-wide pedestrian circulation (some of which will be accomplished with the Muddy River restoration), and that the MBTA proceed with a full rail scenario to realistically improve public transportation to and within the Fenway/Longwood area.” Response
See responses to C-1.2 and E-3.7 regarding interim surface routes. Existing E line bus and area-wide pedestrian improvements will be considered in
tandem with any interim surface routing.
Group F - Response to Community Advocacy and Organization Comments
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RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-9
Received from: Fenway Community Development Corporation
February 9, 2009
Comment No.
F-9.1 Comment
“The LPA fails to connect to Kenmore Station on the Green Line’s main trunk. Green
Line passengers traveling from points east would have to exit Kenmore Station and
walk to Yawkey to board Urban Ring buses. The LPA also fails to specify a station at
the intersection of Ruggles Street and Huntington Avenue, where the Heath Street
branch of the Green Line already stops. We urge EOT to give serious consideration to
connecting the two networks at this location. By definition, BRT should have limited
stops, but if one goal of the Urban Ring is to reduce stress on the Green and the other
radial transit lines, then connectivity is key.”
Response
The LPA in the RDEIR proposes a tunnel with an underground station adjacent to the
Green Line D Branch at Fenway, with walk connection to the C Branch at St. Mary’s.
Urban Ring connection with the E Branch is via a walking connection to the new LMA
station.
F-9.2 Comment
“The Urban Ring segment that would cross Allston is also of interest to Fenway
residents, because so much commuter traffic comes to our neighborhood from that
direction. The best route would be one that minimizes time spent in mixed traffic, at
traffic signals, and making turns. With this in mind, the Allston segment south of
Cambridge Street offers a superior route option that would assure fast, direct service
between Harvard and Allston/Brighton and the Yawkey-LMA areas. Option (a), running
beneath the Massachusetts Turnpike and along the Beacon Park Yards, is by far the
best choice. Option (b), along part of the Commonwealth Avenue, would be less
favorable, while Option (c), entailing travel in mixed traffic along Brighton Avenue,
makes little sense and should not advance to the next planning stage. Similarly,
among the options north of Cambridge Street, option (c), on Lincoln Street and
Western Avenue, should be eliminated…”
Response
The LPA alignment in the Allston segment has undergone refinement since publication
of the RDEIR/DEIS. Refer to the NPC Attachment 6 (Section 6.1), which recommends
Option (a) listed in the comment above.
F-9.3 Comment
“Urban Ring buses should operate entirely free of interference from other vehicles
(except at intersections). If there is any possibility that buses will mix with regular
traffic, we strongly urge the use of automated enforcement technology that penalizes
drivers who interfere with bus operations. Buses should follow the shortest possible
route, with limited stops. Ticketing should take place at the stops (not on board),
boarding should take place at grade, and the route should incorporate preferred
signalization (transit signal priority).“
Response
See response F-3.2 regarding use of Bus Signal Priority and other improvements for
Urban Ring buses in mixed traffic.
Group F - Response to Community Advocacy and Organization Comments
Page 72
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-10
Received from: Sierra Club
February 10, 2009
Comment No.
F-10.1 Comment
“Our specific comment is that the Urban Ring project, like its bus rapid transit cousin
the Silver Line, is, again, a large expenditure of public money which will disrupt the
urban fabric by building new roads through communities in a bid to transfer thousands
of existing public transportation users to buses going, in good sections of the Ring, 10
miles per hour or stuck in traffic.”
Response
The vast majority of the LPA will utilize existing right-of-way and roadways. Well over
50% of the alignment will be in dedicated travel ways with other areas given travel
advantages including bus signal priority and queue-jump lanes.
See response to Comment F-3.2 regarding improvements to increase BRT bus travel
speeds in mixed traffic.
F-10.2 Comment
“The current Urban Ring proposal has winnowed the “Ring” down to one option from
several unsatisfactory choices, none of which included rapid transit or light rail options.
…The project proponent should be required to investigate a true rapid transit or light
rail option.... The project proponent should lay out a strategy for moving the bus rapid
transit service to light rail without significant disruption in existing service. The project
proponent has made public statements that once Urban Ring Phase 2, bus rapid
transit is implemented, it may be very difficult to go to Phase 3 rapid transit or light rail.
“While initially more expensive, The Sierra Club finds it may be a far more costeffective use of our limited tax dollars to construct the Urban Ring “right” in the first
place, as a rapid transit or light rail transit line.”
Response
See response to Comment F-2.1 regarding why the project is not proceeding directly to
Phase 3 (rail).
F-10.3 Comment
“The project proponent should evaluate the no build alternative to provide bus service
used in combination of transportation mechanisms to reduce car and truck use of
designated roadways during the peak service hours to clear the roadways for the
buses; existing bus lines also serving these areas can be evaluated for improvements
in service. The project proponent should also investigate making those portions of the
urban ring bus lines in Somerville, Everett and Chelsea where the bus will be in an
abandoned rail right of way light rail from the beginning to provide better service to
those communities.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding potential early actions to
improve transit service. Also, see response to Comment F-2.1 regarding why the
project is not proceeding directly to rail service.
Group F - Response to Community Advocacy and Organization Comments
Page 73
RESPONSE TO COMMENTS ON RDEIR F-10.4 Comment
“The Sierra Club would not like for the environmental justice communities to serve as a
cover to improve service to the Longwood Medical Area and the Cambridge institutions
and businesses. The RDEIR fails to provide a discussion of how the environmental
justice communities are served by the Urban Ring besides its travel through their
communities. The Sierra Club also notes that there is no direct connection between the
E-line branch on the green line and the 39 Bus, one of the heaviest used lines in the
system and the Urban Ring even though they intersect at Huntington Avenue. The
Environmental Justice communities along these lines would not have an easily
accessible connection with the Urban Ring. In additional several major cultural and
education institutions in this area would also benefit from a direct connection to
Huntington Avenue from the Urban Ring.”
Response
See response to Comment F-2.4 regarding analysis of Environmental Justice
communities. Improved connections between the Urban Ring services and the existing
Green Line E Branch and #39 bus will be evaluated as part of any planning for
improved interim surface routing, and would be addressed in the preliminary
engineering and final environmental stages for the Fenway/LMA tunnel at such time as
that section advances.
F-10.5 Comment
“The Sierra club notes that many of the streets proposed for the routing of the Urban
Ring are too narrow to successfully accommodate bus lanes, particularly in the
Fenway and Audubon Circle neighborhoods and on the Boston University Bridge….
Moreover, in places where the Urban Ring is planned to have its own right-of-way, like
the abandoned Grand Junction railroad through Everett, Chelsea and East Boston, the
Sierra Club still wonders if the route is really a thinly disguised highway project, also
designed for trucks and other non-transit vehicles. If so, the project proponent should
finance its construction with highway money, not transit funding.”
Response
On-street parking is proposed to be removed in some areas to accommodate bus
lanes, including Mountfort Street. Conceptual plans indicate that the roadways
identified for the LPA can accommodate bus movements. The LPA does not include
use of the BU Bridge. It is noted that the CT2 and #47 buses travel on the BU Bridge
today.
Exclusive right of way identified for the LPA in Everett and Chelsea are for the sole
purpose of transit vehicles. In East Boston the Urban Ring would likely share the
proposed East Boston Haul Road which is listed in the current Transportation
Improvement Program.
F-10.6 Comment
“The Sierra Club remains concerned about the bus tunnel and its connection to
Cambridge over the Grand Junction Bridge. The proposal to place bus lanes on
Mountfort Street, a narrow thoroughfare running for four blocks parallel to the Turnpike
between Beacon and Carlton Streets, requires the removal of all traffic to be effective
or building a wider road.
“…Articulated buses heading into Cambridgeport would have to make a sharp U-turn
to access the Grand Junction bridge. There may not be enough land area to design an
effective connection. In addition there is no discussion of how construction of the new
bridge would affect use of the river surface by recreational users.”
Group F - Response to Community Advocacy and Organization Comments
Page 74
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment 10.5 regarding Mountfort Street discussion. The conceptual alignment plans show that a busway alignment can be constructed that
can accommodate articulated buses. A u-turn movement is not required. Potential
impacts on the Charles River water sheet are discussed in the response to Comment
C-1.5 and will be evaluated further in preliminary engineering and final environmental.
F-10.7 Comment
“In the Executive Summary on page ES-4 it states that the Environmental Justice
Population would benefit from improved access to the transit system. What needs to
be demonstrated is that the Urban Ring bus routes would give better access for these
populations to the transit system.”
Response
See response to Comment F-2.4 regarding Environmental Justice populations. F-10.8 Comment
“On page E-8: Weekend statistics should be included. Current, CT1, CT2, and CT3
Bus service does not run on week-ends or after 7 pm during the week.”
Response
Weekend travel demand was not analyzed for the RDEIR/DEIS. The CTPS travel
demand model used for forecasting future transit ridership does not include weekend
conditions.
EOT will be coordinating with the MBTA to consider service enhancements to CT
routes as mentioned in the NPC Attachment 6 (Section 6.2.2).
F-10.9 Comment
“On Page E-21: Locally Preferred Alternative should be modified to include a station on
Huntington Avenue to allow transfers between the E-Line and the 39 Bus (one of the
system’s heaviest traveled bus lines) to improve services to cultural and educational
institutions in the area as well as to provide better service to the Fenway, Mission Hill
and Jamaica Plain communities.”
Response
Alternatives 1, 2, 2A, 3, 3A, 3B, 3C, 4, and 4A evaluated a station on Huntington
Avenue. Refer to the response to Comment F-10.4 regarding improved connections
with the Green Line E Branch and the #39 bus.
F-10.10
Comment
“On page ES-17: Need to include travel time savings for each environmental justice
neighborhood not just the whole.”
Response
See response to Comment F-2.4 regarding the level of environmental justice analysis
provided in the RDEIR/DEIS. Travel time savings, ridership, etc. was evaluated on a
Segment (A-C), Sector (1-11), and station basis (36), as shown in Chapter 2 of the
RDEIR/DEIS.
Group F - Response to Community Advocacy and Organization Comments
Page 75
RESPONSE TO COMMENTS ON RDEIR F-10.11
Comment
“On page ES-19: Need to be specific as to which Green Line branches will have
reduced ridership. Also could service be moved from bus routes, such as the 66 or 47,
to the Urban Ring.”
Response
Ridership analysis was done on a rapid transit line basis (Green, Red, Orange, Blue).
Analysis was not done on the individual Green Line branches. The analysis results
show that the LPA would reduce total Green Line daily ridership by approximately 10
percent compared with the 2030 No-Build Alternative (see Table -13 in the
RDEIR/DEIS).
F-10.12
Comment
“On page ES-21: Which roads will have reduced automobile traffic? Are there any
roads for which automobile traffic will increase?”
Response
Because the project will shift some motorists to buses and the additional bus traffic
created by the project is nominal, there is expected to be some small decrease in
general traffic volume at the vast majority of study intersections and roadways. See
discussion starting on page 4-66 of RDEIR/DEIS.
F-10.13
Comment
“On Page ES-31: Over 2 acres of parkland are identified as being impacted by
permanent lost as a result of construction of the Urban Ring. There is no discussion of
how the lost of the park land will affect park users or how the project proponent
proposes to replace the park land with equal or better park lands as required under the
state’s Art. 97 policy.”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended alignment
change in Everett, which would avoid the permanent parkland impacts along the
Revere Beach Parkway, which comprise 1.9 acres of the permanent impact identified
in the RDEIR.
F-10.14
Comment
“On page 3-3: The only routes left from the Urban Ring Phase 1 are CT1, CT2 and
CT3. These routes do not start early in the morning nor do they run after 7 P.M. in the
evening on weekdays. There is no weekend service. This could be an indication of
how the service on the Urban Ring Phase 2 will eventually be implemented…. The
Sierra Club believes that there may be much demand for rush hour service, as riders
switch from other transit lines but limited demand for service during the day and
evening for many segments of the Urban Ring.”
Response
The MBTA is responsible for scheduling, operations, and maintenance of the existing
CT buses.
EOT will be coordinating with the MBTA to consider service enhancements to CT
routes and other bus routes as part of the early actions identified in the NPC
Attachment 6 (Section 6.2.2). Operating plans for proposed Urban Ring BRT routes in
the Northern Tier will be defined in greater detail during preliminary engineering and
final environmental.
Group F - Response to Community Advocacy and Organization Comments
Page 76
RESPONSE TO COMMENTS ON RDEIR F-10.15
Comment
“On page 3-20: An analysis of each commuter rail stop on the Urban Ring Phase 2
needs to be done to see how many passengers will be trying to board one bus after
the commuter rail has deboarded. Commuter rail comes every 75 minutes or so. Can
one articulated bus which may already have passengers on it accommodate a fully deboarded Commuter Rail Train. The Sierra Club believes that many people will transfer
from the commuter trains onto buses during rush hour creating overcrowding.”
Response
The expected number of transfers to the Urban Ring from commuter rail will be
analyzed further in the FEIR and the development of BRT operating plans.
F-10.16
Comment
“Page 5.8.2: Many parts of this area are filled wetlands from the 19th century. Also the
area included at least one waterway that was placed in to culvert during the 20th
century. Construction in this area may affect the groundwater in this area and the
buildings supported by wood pilings.”
Response
Refer to the response to Comment C-2.2 regarding Chapter 91. F-10.17
Comment
“Sections 6.1 and 6.2 Financial Framework: In general, this section is weak and needs
to be more fully developed; particularly; the section on the operation and maintenance
cost funding. The MBTA currently faces significant financial challenges supporting its
current system. The District Improvement Financing would may create hardships for
taxpayers, particularly low and moderate income homeowners and business. In
addition, many non-profits in the Urban Ring area are in a weakened financial
condition or may be negatively impacted by the project they may be required to pay
for. This item needs much more elaboration if is to have any meaning.”
Response
See response to Comment F-1.2 regarding financing options under consideration. F-10.18
Comment
“Section 6-11 Phasing and Implementation: A complete discussion of phasing is
required…. The Sierra Club questions the long-term commitment of the project
proponent to provide the same quality of service to all service areas….On examination
of the present proposal, it is clear that solely a unified rail transit system will allow the
Ring to operate as a coherent whole, an integral part of our public transportation
system. Anything less makes no sense and is an egregious waste of our scarce public
resources.”
Response
See response to Comments F-1.1 regarding phasing and implementation of the
project. Phasing and implementation information is also provided in the NPC document
required by MEPA. See response to Comment F-2.1 regarding proceeding directly to a
rail alternative (Phase 3).
Group F - Response to Community Advocacy and Organization Comments
Page 77
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-11
Received from: The Fenway Alliance
February 9, 2009
Comment No.
F-11.1 Comment
“We question the effectiveness and value of the Urban Ring plan as proposed, and its
impacts on the environment in our area, our neighborhood, and our institutions.
“…We believe that significant improvements to the existing E-Line might vastly improve
public transportation, more than adequately serve the LMA, and eliminate the need for
the Urban Ring in our area.
“We believe that EOT’s Phase II preferred design alternative compromises the Fenway
which is a unique cultural and environmental area of Boston, distinct from the LMA and
any other area in the City.
“We believe that the current preferred alternative as described by EOT…still
compromises pedestrian safety, and the historic, cultural and green environment of the
Fenway.
“…We are concerned that under the proposed phase II design, the historic Fenway
Parkway… would have to accommodate a significant increase in MBTA bus traffic (6
MBTA buses per hour or one every ten minutes) under the proposed routing. And that
even if this is proposed by EOT as an “interim plan,” we are extremely skeptical about
the likelihood that once allowed on the parkway, MBTA buses would ever be removed
from it, but instead, would become a thoroughfare and “cut through” for the LMA.
“We support the tunnel option, going directly to underground rail, or segmenting the
Urban Ring to only those areas in which it will not bring serious environmental harm for
all of the reasons cited above.”
Response
Refer to the RDEIR Executive Summary pages ES-15 through ES-33 for a summary of
the benefits and impacts of the Urban Ring project. Further details specific to the
Fenway benefits and impacts are contained in Chapters 2, 4, and 5.
Improvements to the Green Line E Branch could improve radial transit service along
the southeast side of the Fenway but would not improve transit service in the
circumferential corridor between radial lines, which is the unmet need addressed by
the Urban Ring project.
The LPA recommended in the RDEIR contains a BRT tunnel which would enable
Urban Ring buses to completely avoid operations on surface streets through the
Fenway between Yawkey Station and Ruggles Station. It is unclear how, as stated in
the comment, this alternative “…compromises the Fenway”. The recommended LPA
Fenway/LMA tunnel was carefully defined in coordination with area stakeholders to
achieve just the opposite – avoid impacts on the Fenway.
See response to Comment C-1.2 regarding the planning process to be followed for any
interim surface routing.
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. See response to Comment F-2.1 regarding directly proceeding to
rail (Phase 3).
Group F - Response to Community Advocacy and Organization Comments
Page 78
RESPONSE TO COMMENTS ON RDEIR F-11.2 Comment
“We also believe that a funding strategy for these much more satisfactory options
which have the benefit of much wider consensus support could be developed and
achieved, particularly given the change in federal administration, the need for
economic stimulus projects, and the new commitments to infrastructure improvements
by both the Federal government and the Commonwealth.”
Response
See response to Comment F-1.2. Group F - Response to Community Advocacy and Organization Comments
Page 79
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: F-12
Received from: Walk Boston
December 28, 2009
Comment No.
F-12.1 Comment
“As the project moves forward, we look forward to engaging more fully in the details of
the planning process to advocate for safe and generous pedestrian access…. We
would be pleased to work with EOT, the MBTA and the local communities to help attain
that goal.
“We would suggest the following guidelines for the next phase of work on the Urban
Ring:
• Pedestrian access must be considered from the outset of the detailed
study of routes and station locations. There may be distinct advantages or
disadvantages for pedestrian access in various locations, and only
detailed study can reveal these conditions.
• It is particularly important that there be detailed studies of routes, stops
and stations where tracts of abutting land may house transit-oriented
development. This is crucial because such developments will need
excellent pedestrian access to transit to fulfill their potential.
• …There is no illustration of Phase 3 in the document…. We urge that
future planning specifically illustrate which routes and stops or stations will
be permanent and which will be added in the later of the three phases.”
Response
EOT will work with MBTA, the local communities, and other stakeholders to evaluate
and provide adequate pedestrian and bicycle accommodations. The FEIR will include
analysis of routes, stops and stations.
Phase 2 planning considered the potential future needs of Phase 3 so as not to
preclude its implementation at a later date.
Group F - Response to Community Advocacy and Organization Comments
Page 80
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-1
Received from: Beth Israel Deaconess Medical Center
February 10, 2009
Comment No.
G-1.1 Comment
“The RDEIR/DEIS documents that the proposed Urban Ring project with a tunnel has
greater benefits, to transportation and the environment, when compared to surface
routing, at the metropolitan area level; and on a local scale, for the Longwood Medical
and Academic Area (LMA) and the Emerald Necklace parks and parkways. We agree
and suggest that the interim surface routes evaluated in the LMA, to date,
underestimate access impacts of the surface routes, particularly the queue jump lane
at the Longwood/Brookline Avenue intersection and the sheer number of buses
proposed through the LMA. Any surface alternatives considered in the future cannot
worsen access conditions in the LMA and should be considered only the most
temporary in nature.”
Response
Comment noted. See response to Comment G-7.17 regarding surface route impacts. G-1.2 Comment
“The tunnel segment is a critical link in the Urban Ring and is a vital part of Phase 2 to
achieving the projected benefits associated with its successful implementation…. The
planning and preliminary engineering of this vital segment of the Urban Ring should
therefore continue without delay.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding major infrastructure elements
such as the Fenway/LMA tunnel.
G-1.3 Comment
“Additional studies must fully analyze and resolve tunnel routing and portal options to:
determine the maximum regional ridership while balancing the local impacts of
construction and operation on private property, public open space and transportation
systems serving the area; and define the recommended tunnel alignment, construction
methodology and tunnel configuration including the land area required along the
alignment both to support construction and for permanent right of way, with a full and
accurate assessment of costs, legal and political feasibility of land or easement
acquisitions.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding major infrastructure elements
such as the Fenway/LMA tunnel.
G-1.4 Comment
“There appears to be a high cost premium associated with design and building the
Phase 2 bus tunnel in part because if its requirement to plan for Phase 3 future heavy
rail technology. We encourage you to allow for some relief of this condition in your
Certificate for the RDEIR/DEIS; a light rail option allows for alternative tunnel routes to
be considered, such as a tight-turn option, which could both lower the cost for the
tunnel construction and potentially lower the impacts on private property, lower
vibration impacts, and reduce disruption to surface transportation during construction.”
Group G - Response to Institution Comments Page 81
RESPONSE TO COMMENTS ON RDEIR Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding major infrastructure elements
such as the Fenway/LMA tunnel.
G-1.5 Comment
“As a potential abutter to a tunnel route, it is also imperative that site-specific
geotechnical information be obtained to inform the preliminary engineering including a
thorough investigation of building foundation locations and type adjacent to any of the
alignments or proposed underground station, the likely impacts to each building
resulting from the tunnel and station construction work in close proximity, and the most
likely and effective mitigation.”
Response
See response to Comment G-7.9 regarding geotechnical impacts. G-1.6 Comment
“We have facilities that host sensitive medical equipment, research studies, and
medical procedures and would like to see a thorough evaluation of the impacts related
to alternative tunnel construction techniques and operational aspects of the future
Phases 2 or 3 services particularly with respect to vibration, electromagnetic field and
moving metal.”
Response
The RDEIR conducted a thorough evaluation of the potential impacts associated with a
wide range of Phase 2 tunnel alignments, including consideration of construction
phase impacts. The RDEIR Chapter 5, Sections 5.6 and 5.12 summarize the
evaluation of noise and vibration, and electromagnetic fields and moving metal.
Detailed documentation of these evaluations, which included coordination with a
separate working group of institutions along the tunnel alignment, were distributed to
the members of the working group and are available on the project website at
www.theurbanring.com. Potential Phase 3 impacts were considered at a general level
in the Phase 2 RDEIR and a detailed analysis would be the subject of a separate
environmental process.
G-1.7 Comment
“Preliminary engineering and the FEIR/FEIS should develop a more detailed phasing
and implementation plan that identifies potential early action items and schedules, in a
manner that does not segment future tunnel costs from ridership benefits of the whole
project. Early action items in the LMA should include the advancement of commuter
rail platform improvements at nearby Ruggles Station, which represent a relatively
modest investment with significant transportation benefits to the Longwood, Fenway
and Roxbury communities.”
Response
See responses to comments F-1.1 and F-1.2 regarding early action items and a
phasing and implementation plan. The inbound commuter rail platform at Ruggles
Station is included as an early action item in the “Southern Tier” of the project. See
NPC Attachment 6 (Section 6.2).
G-1.8 Comment
“Planning and engineering for the Urban Ring must move forward in consistent stages
so that the project can be ‘ready to go,’ as the economy improves and as solutions are
found for Massachusetts’ transportation financing for roadways, the Turnpike and the
Group G - Response to Institution Comments Page 82
RESPONSE TO COMMENTS ON RDEIR MBTA. While potential exists for some private funding opportunities, a broader-based financing plan should be constructed that recognizes the significant statewide and metropolitan area benefits of the project, not just the Urban Ring corridor. The plan should take care not to place the Urban Ring in competition with municipal sources of funding in a way that would undermine local support for the project. We also recommend that the State explore new opportunities for regulatory flexibility regarding
Federal financing of transit projects with the changed administration in Washington.” Response
See responses to Comments F-1.2 and G-7.22 for next steps and funding options. G-1.9 Comment
“We request that the Secretary’s scoping for preliminary engineering and the
FEIR/FEIS require that EOT proceed without delay to advance a short-term work
program to include some aspects of preliminary engineering, including additional
tunnel evaluations, using state bond funds earmarked for the Urban Ring in the 2008
Transportation Bond Bill. In this way critical progress can be made in 2009 in advance
of entering into the New Starts process and monitored during 2009 through the
submission of biannual progress reports.”
Response
See response to Comments F-1.1 and F-1.2 for short-term work program and funding
options.
See response to Comment G-7.4 regarding the request for biannual progress reports.
Group G - Response to Institution Comments Page 83
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
G-2.1 G-2
Boston University
February 3, 2009
Comment
“The enormous cost of the entire LPA is also a concern and remains a significant
impediment both to advancing and completing this project. We encourage the project
team to identify measures that can be taken, within the limits of the federal financing
process, to advance this project on a timely basis.”
Response
See response to Comment G-7.7, and response to Comment F-1.3 for a schedule for
resolving key remaining technical, routing, and implementation issues.
Group G - Response to Institution Comments Page 84
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
G-3.1 G-3
Children’s Hospital Boston
February 3, 2009
Comment
“We strongly believe that a tunnel is preferable to surface routing, and in fact, have
some concerns about the effectiveness of surface routes in the Longwood Area.
Therefore we do not support deferral of a tunnel as a future Phase II element. The
tunnel serves the largest projected ridership on the Ring and will avoid worsening
roadway congestion in the LMA.”
Response
See response to Comment G-7.1 for status of interim surface improvements planning. G-3.2 Comment
[We] “respectfully request that the Secretary’s scoping should require EOT to proceed
without delay on advancing a short-term work program to include some aspects of
preliminary engineering, utilizing this state funding.”
Response
See responses for Comments F-1.1 and F-1.2 for short-term work program and
funding options.
G-3.3 Comment
“Resolution of a final locally preferred alternative, tunnel routing options and portals
including, but not exclusively limited to, further evaluation of tight-turn, medium-turn,
and wide-turn tunnel options, and Park Drive and Ruggles Station portals, with the
goals of determining the least impactive alternatives to private property and public
open space. Specifically, the Hospital-owned parcel at 819 Beacon Street has been
shown on some plans as a ‘lay down’ construction use area, which would be directly at
odds with our plans to develop this site for use by the Hospital over the next few years,
pursuant to our Institutional Master Plan.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding major infrastructure elements
including the Fenway/LMA tunnel.
G-3.4 Comment
“Thorough evaluation of vibration impacts of alternative construction methods and
operational aspects of the future Phases II and III, which is particularly important given
the sensitive work and equipment that occurs on our campus, and in the LMA in
General.
• Sufficient preliminary engineering to determine what is the best method of
tunnel construction.”
Response
See response to Comment G-1.6 regarding vibration. Potential tunnel construction
methodology is discussed in Chapter 3, Section 3.14 and the supporting technical
report.
Group G - Response to Institution Comments Page 85
RESPONSE TO COMMENTS ON RDEIR G-3.5 Comment
“It is important that the project’s planning continue to move forward so that all the work
done to date will not be in vain, and so that the state will be ready when hopefully the
funding climate improves. The expected benefits gained from the Urban Ring warrant
the additional engineering and design, into the preliminary engineering and FEIR/FEIS
phases…. We encourage the State to continue this work in the next phase
expeditiously.”
Response
See response to Comment G-7.7, and response to Comment F-1.3. Group G - Response to Institution Comments Page 86
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-4
Received from: Harvard University
February 9, 2009
Comment No.
G-4.1 Comment
“The projected serious congestion and delays on the central transit system are due in
part to the absence of effective circumferential transit mobility, but we would urge EOT
to take the point further: The fact is that none of the transit improvements on the
planning horizon will be viable without implementation of the Urban Ring
circumferential transit option. The transit system that our regional economy depends
on will not continue to be viable without a component that allows riders to bypass the
central core. The Urban Ring is the only planned system improvement that reduces
central system congestion. We hope that EOT will present this benefit more clearly in
the FEIR.
“The Urban Ring is as important to the future operations of the transit system as the
transit system is important to the future of the region.”
Response
Comment noted. Urban Ring benefits on reduction of transit congestion in the central
subway system will be developed further in the FEIR.
G-4.2 Comment
“The engineering for all of the tunnel portal options is still at a basic level, and will
remain so until the project advances to Preliminary Engineering. We believe that it
would not be prudent, at this point in the technical analysis, to drop either the Mountfort
Street or the BU Bridge tunnel portal alternative from public review and comment. The
proposed Landmark Center and Miner Street options have generated significant
technical questions about design and construction feasibility that remain unanswered
at this time. Each of these options seems to rely on implementation of a Yawkey
Station full-service commuter rail facility for which no functional, ADA-compliant design
exists, and on Urban Ring construction and bus operation plans that appear to rely on
the acquisition of property rights from third parties even though the related project
costs are not addressed in the DEIR/S. If the Urban Ring project is to remain on
schedule through Preliminary Engineering, EOT will need as many options as possible
to draw from in order to overcome the inevitable technical difficulties that will arise as a
fully-engineered tunnel alignment is developed.
“Second, it is essential under federal law (National Environmental Policy Act) to
evaluate, during this phase of the environmental review, potentially beneficial options
that do not have preclusive or seriously prejudicial impacts on beneficial alternatives
in Phase 3. This is also required by your May 20, 2005 Certificate:
‘Likewise, the Revised DEIR should demonstrate that the implementation of
Phase 2 would not adversely affect the implementation of Phase 3.’ (page 6,
Certificate of the Secretary of Environmental Affairs on DEIR, May 20, 2005.)
“One of the goals of Phase 3 of the Urban Ring is to extend the tunnel under the
Charles River to connect the LMA directly to Kendall Square. Only the Mountfort Street
or the Brookline-recommended BU Bridge portal option would allow Phase 2 service to
continue uninterrupted during the construction of this Phase 3 tunnel. These two portal
options, which the DEIR/S implies should be dropped, are the very two options that will
retain ridership and save cost in the Phase 3 implementation plan. On balance, these
Group G - Response to Institution Comments Page 87
RESPONSE TO COMMENTS ON RDEIR savings in Phase 3 may well justify the additional cost of extending the Phase 2 tunnel
to the Mountfort Street/BU Bridge area. We believe that one of these alternative tunnel
alignments should be the preferred alternative presented in the FEIS, but only
Preliminary Engineering will identify the appropriate solution.”
Response
Refer to the NPC Attachment 6 (Section 2.2.2) regarding future environmental steps
for the tunnel portion of the LPA. The tunnel portion of the project will not be included
in the early action implementation items due to funding constraints and further
evaluation needed to resolve key engineering and alignment issues. The RDEIR LPA
does not preclude converting some portions of the alignment to heavy rail, light rail, or
commuter rail technology in the future.
G-4.3 Comment
“We are glad that EOT recognizes the importance of West Station in Beacon Park Yard
and has included it as part of the Locally Preferred Alternative. However, the
description of the station and the associated analysis does not fully articulate the many
opportunities to improve the regional transit system that are made possible by
implementing a major transit hub in the Beacon Park Yard area.”
“We urge EOT to highlight the unique opportunity that West Station at Beacon Park
Yard provides as a major consideration in the development and refinement of the
Urban Ring’s locally preferred routing. We urge that any further study and design of the
Urban Ring project estimated the likely commuter rail system constraints of the future
and describe how a well-located and integrated multimodal West Station, with the
Urban Ring as a component, could mitigate or eliminate those constraints.”
Response
Comment noted. The location of the Allston Multimodal Station was the subject of a
separate but related study by EOT, which identified a preferred location at Cambridge
Street located at the west end of the Beacon Park Yard (BPY) served by the Urban
Ring BRT6 route via the busway alignment beneath the Turnpike and through the
BPY. Further development of the Urban Ring Allston connection will incorporate the
results of that study.
G-4.4 Comment
“EOT has been diligent in working toward a locally preferred connection for the Urban
Ring from the Boston University area through Allston to Harvard Square. We were
encouraged by EOT’s recent analysis of a route under the Allston Turnpike viaduct that
provides for two-way bus service, but we caution that this alternative needs not only
engineering detail but also coordination with CSX’s operations on the Main Line and
the Grand Junction Line, and with the Turnpike’s plans to repair the viaduct’s structural
deficiencies. We urge EOT to maintain other options for the Urban Ring to cross from
Commonwealth Avenue into Allston, allowing more flexibility in the final design process
to achieve the best solution.
“A variety of routes through Allston to the Charles River have been discussed in the
recent review process. We continue to believe that the best route through Allston for
the Urban Ring BRT, a regional transit service, is the Stadium Way option. We
encourage EOT to study how local bus services might also use this new right of way to
enhance the quality of local transit services in the Allston community.”
Group G - Response to Institution Comments Page 88
RESPONSE TO COMMENTS ON RDEIR Response
Since the RDEIR/DEIS, the recommended Urban Ring alignment from Boston
University through Allston to Harvard Square has been identified. The proposed
alignment provides a busway beneath the Turnpike viaduct through Beacon Park Rail
Yard, along other rail right of way adjacent to the south side of Cambridge Street, and
into the proposed buslanes along future Stadium Way, Western Avenue to Barry’s
Corner, and North Harvard Street to connect with Harvard Square. This alignment was
chosen based on a comprehensive study of project impacts in this area and extensive
input from the City, the neighborhoods, Harvard, and other stakeholders.
G-4.5 Comment
“We join with our fellow CAC members in urging that EOT take immediate steps to
initiate early action components of the Urban Ring project that will improve transit
service throughout the corridor and begin to relieve the pressure from the central
transit system…. This program of early actions could be limited to signal and lane
priority improvements at key locations within the Urban Ring corridor (with no adverse
impact on the environment) coupled with increased service frequency using standardsized buses. In addition, as bridges and roadways in the Charles River Basin are
repaired and reconstructed, Urban Ring early actions may be implemented as traffic
mitigation measures, thereby making the most of the Commonwealth’s transportation
funds by utilizing the investment in the near-term bridge reconstruction projects to help
meet the longer-term transit needs of the region.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding early action implementation
plans.
Group G - Response to Institution Comments Page 89
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-5
Received from: Isabella Steward Gardner Museum
February 6, 2009
Comment No.
G-5.1 Comment
“Although state policy prohibits commercial vehicles on historic parkways in
accordance with the state’s Historic Parkways Initiative and related guidelines, trucks
and buses are using the parkways (Park Drive and The Fenway) rather than city roads.
These historic parkways were not built for heavy commercial traffic and their overuse is
dissociating the park from its surrounding community and poisoning the area with
noise and pollution. This overuse harms the pedestrian and student-friendly character
of the Fenway neighborhood and threatens The Fenway’s many important abutting
environmental and cultural resources.
“While the Urban Ring Phase 2 RDEIR/DEIS is a great improvement from the original
proposal, the Museum cannot support it at this time, given that the preferred alternative
for the Fenway/Longwood Area proposes interim use of the Urban Ring buses on the
historic Fenway parkway. With regard to the Urban Ring project, the Museum will only
support a proposal that proceeds directly with the rail tunnel option under the
Longwood area and one that does not support an interim solution on the historic
parkway. Our concern remains that the interim solution would become the permanent
solution if funding cannot be realized to pursuer the tunnel option in the long term.
“The Museum recognizes the challenge of traffic congestion in the Fenway and
Longwood areas and has long been advocating for improved public transportation
access to the neighborhood, including improved service on the MBTA E-Line, given
that a large percentage of our visitors travel to the Museum on public transport. We
encourage the EOT to do a comprehensive analysis of the traffic challenges that
burden the Fenway and Longwood Areas before proposing additional surface transit
solutions for the neighborhood.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding potential early actions and
the impediments impacting the schedule of the recommended Fenway/LMA tunnel.
Group G - Response to Institution Comments Page 90
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-6
Received from: Massachusetts Institute of Technology, Department of Facilities
February 10, 2009
Comment No.
G-6.1 Comment
“Changes to proposed alignment, vehicle propulsion technologies that include use of
electric motors outside of tunnel operations, use of vehicles other than from rubbertired buses and any contemplated Phase III Light Rail or Heavy Rail in any alignment
around MIT would require a new and more detailed review by the project proponents
and MIT.”
Response
The FEIR/FEIS will analyze the impacts associated with any changes to the proposed
alignment and/or vehicle propulsion technologies.
Refer to the NPC Attachment 6 (Section 6.3) regarding Phase 3.
G-6.2 Comment
“Galaxy Park – Absent inclusion of the preliminary design referenced on page 2-18, it
is impossible to conclude, as the Revised DEIR does, that “this element can be
implemented without significant impact on the park.” Section 4(f) analysis beginning on
page 7 provides a precise determination of impact that does not seem consistent with
the level of detail provided elsewhere. There is very limited park space in Kendall
Square, so even relatively minor impact will require thoughtful mitigation. The further
development of this portion of the route would benefit from more direct consultation
with a broad array of local stakeholders and abutters.”
Response
EOT will continue to work with stakeholders and abutters to minimize park and Section
4(f) impacts during preliminary engineering and final environmental for the
recommended Northern Tier.
G-6.3 Comment
“Page 2-19 describes a Main Street route operating in mixed traffic, while Figure 5-18
on page 5-51 depicts Main Street bus lanes in Kendall Square. The figure 2-8 on page
2-55 also shows bus lanes in both directions on Main Street from Third to Vassar
Streets. Please clarify the intention here. There is a complex set of retail parking and
pedestrian, bicycle, shuttle, taxi, automobile and MBTA bus moves along and across
Main Street. The Urban Ring bus lanes will impact each of these issues and will
require more detailed study.”
Response
The LPA was generally identified with bus lanes on both sides of Main Street between
Third and Vassar Streets. A portion of this segment will include a 4-bay bus station on
each side of Main Street. The implementation of new bus lanes will continue to be
considered in this area through coordination with the City of Cambridge. It is
anticipated that the other modes listed will continue to be accommodated, but with
limitations on general automobile traffic and parking. Mitigation for removal/relocation
of on-street parking in this area will be further evaluated in preliminary engineering and
final environmental.
Group G - Response to Institution Comments Page 91
RESPONSE TO COMMENTS ON RDEIR G-6.4 Comment
“The intermodal prototype station (shown as Figure 3-6, page 3-30) and the Kendall
Station visualization (Figure 5-11, page 5-43) do not provide the basis for an
appropriate design for the third largest station (15,000 daily boardings) in the Urban
Ring. The prototype identifies some of the important elements in any such station, but
the concept of a simple façade extension and graphic treatment for this location is
inadequate and should be avoided.”
Response
Comment noted. Scale and character of proposed stations and modifications to
existing stations will be defined during preliminary engineering and final environmental
in coordination with adjacent landowners and stakeholders.
G-6.5 Comment
“Main and Albany Streets – This unsignalized intersection is identified in Table 4-28 on
page 4-73 as having a Level of Service (LOS ) of F. While this may, in part, be an
artifact of the SYNCHRO modeling, this critical access point on the Urban Ring route
needs greater attention and analysis to ensure that it can operate successfully.”
Response
The LOS F designation represents the minor left-turn movement from Albany Street
northbound onto Main Street westbound. Urban Ring buses would make a right turn at
this approach, not a left turn. However, to try and reduce the impact of left-turning
vehicle queues on the right-turn movement, eliminating on-street parking spaces on
Albany Street is proposed. This would create a separate right turn lane on Albany
Street for buses.
G-6.6 Comment
“The 172 parking spaces proposed to be removed to make way for bus lanes on
Albany Street is the second largest parking elimination on the 25-mile Urban Ring
route and by far the largest elimination proposed in Cambridge. No further coordination
with MIT, other stakeholders or the City of Cambridge is mentioned. The sheer number
of spaces suggests consideration for reducing the number where possible and
mitigating this loss in some form. Although segregated right-of-way is a preferred
condition in principle, there may be places like on Albany west of Massachusetts
Avenue where low traffic volumes or street cross section variation would allow parking
to remain with no additional travel time. The Main Street and Massachusetts Avenue
approaches are the important queue jump locations that could affect operations.
Albany traffic flows smoothly away from these intersections, as shown on Table 4-28,
page 4-76.”
Response
Bus lanes proposed for Albany Street require the elimination of approximately 172
parking spaces. The possibility of reducing this number or potential locations for
parking replacement to mitigate the impact of eliminated parking spaces will be
examined as the project progresses.
Note that the traffic analysis includes the impacts of queue jump lanes where
proposed.
Group G - Response to Institution Comments Page 92
RESPONSE TO COMMENTS ON RDEIR G-6.7 Comment
“Albany Street and Mass Avenue – The Revised DEIR/DEIS is not specific about how
stations would be located, exact lane configuration or use of signal prioritization, what
property would be taken, sidewalk alterations needed or joint development
opportunities. Opportunities to integrate proposed stations into the urban context while
retaining the necessary identity remain to be explored. Since so many of these
elements await further development, the functionality and impact of these stations and
intersection cannot be fully assessed without more study and design.”
Response
Further study and analysis will occur with the preliminary engineering and final
environmental review of new BRT stations, as applicable. Additional analysis will
include station location, exact lane configuration, use of signal prioritization, property
takings, sidewalk alterations, and/or joint development opportunities. To the extent that
flexibility still remains in the selection of station locations, open space, adjacent
architecture, waterways and historic resources, among other criteria, will be
considered. Opportunities to integrate proposed stations into the urban context while
retaining necessary identity will also be explored.
G-6.8 Comment
“The move from Albany Street to the Grand Junction around Fort Washington Park and
then to an expanded Grand Junction bridge over the Charles creates new and different
challenges, as enumerated on page 2-20: “to develop a busway alignment and station
location that serves the needs of the Urban Ring project; that serves the pedestrian,
bicycle and transit needs of students and neighborhood residents; and that is
compatible with the character of Ft. Washington Park and amenable to MIT parcel
development needs.” While progress has been made, no alignment which
appropriately balances the considerations noted above has yet been achieved. The
Section 4(f) analysis on page 7-5, similar to the Galaxy Park analysis, provides an
overly precise estimate of impact given the level of detail reached in the development
of the busway alignment and station location thus far. Similarly, the reference to
property takings for right of way and stations on page 2-65 provides precise acreage
summaries, but no detail as to where these might be. Property takings and appropriate
mitigation must be elaborated on to assess overall environmental impacts.”
Response
As the alignment from Albany Street to the Grand Junction bridge is refined, EOT will
continue to consider and balance the needs of the various stakeholders and abutters
with the performance requirements of the new service. The numbers provided in the
Section 4(f) analysis are in acres and are approximate. Property takings for proposed
stations will be shown in detail and evaluated during preliminary engineering.
G-6.9 Comment
“The MIT parcel described as “empty” on page 2-20 contains the recycling and
grounds storage and outdoor operation area for entire university and off-street parking.
Both of these uses were relocated for the Ashdown House graduate residence at 235
Albany Street. When the recycling area is combined with an abutting parcel, a nearly 2
acre development parcel is created. It would be more properly called a development
parcel with transitional uses on it.”
Response
Comment noted. Future environmental review documents will clarify the uses on this
site.
Group G - Response to Institution Comments Page 93
RESPONSE TO COMMENTS ON RDEIR G-6.10
Comment
“The limitation of the busway crossing of the railroad tracks at Fort Washington to the
existing pedestrian crossing, as suggested on page 2-20, prematurely limits the range
of options that could satisfy the interests outlined in the document. The proposed
acquisition of the CSX track rights and land by the Commonwealth opens considered
for this location.
“The revised DEIR/DEIS states on page 2-81 that revised traffic patterns adjacent to
Fort Washington will require careful evaluation of any potential adverse effect. There is
also an opportunity for the Urban Ring to improve and enhance this historic park which
has suffered from isolation and inappropriate uses.”
Response
As the alignment from Albany Street around Fort Washington Park to the Grand
Junction bridge is refined, EOT will continue to balance the needs of the various
stakeholders and abutters with project goals. Acquisition of the CSX track rights and
land, as well as opportunities to improve and enhance the park, will be considered.
G-6.11
Comment
“An interim route that would make use of eastbound Albany Street and westbound
Vassar Street BRT operations is mentioned on Page 2-20. The use of this interim route
in the event of difficulties coordinating with CSX on the Grand Junction crossing and
bridge or project construction phasing, either of which might be combined with early
action implementation of transit service, might well be a practical alternative. However,
nothing is articulated about how such an interim route might work, station placement,
property needs, need for any road or signal alterations, etc. Further consideration of
such an interim route would be contingent on a complete development and
assessment of these impacts, particularly since MIT is completing the reconstruction of
Vassar Street with enhanced bicycle and pedestrian facilities.”
Response
Future environmental review documents will provide more detail regarding proposed
interim routes, station placement, and associated impacts.
G-6.12
Comment
“All of the benefits provided by the Urban Ring can be realized sooner if we can find a
way to begin implementation of early actions – critical first components of the overall
Urban Ring System – that can begin to enhance current transit service in the area,
provide better connections between radial and transit commuter rail lines, and provide
an alternative route that will reduce crowding in Park Street and Downtown Crossing.
“A more immediate benefit of selected early actions would result from use of Urban
Ring components as mitigation for Charles River Basin project impacts. The current
program of reconstruction and rehabilitation projects for bridges and roadways in the
Basin being planned by the Department of Conservation and Recreation will have a
range of different impacts on the transportation network. Mitigation measures will need
to be taken to reduce traffic impacts over the eight year life of the program. Putting in
place early Urban Ring bus service at strategic locations in Boston and Cambridge can
help address this need.
“…The final EIR/EIS should include a more detailed phasing and implementation plan
that identifies specific early action items and provides schedules for their
implementation.”
Group G - Response to Institution Comments Page 94
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment F-1.1 regarding early action implementation plans. G-6.13
Comment
“Immediate next steps should be taken to initiate any additional analysis and
engineering, including release of bond funding designated for these purposes, that will
advance the Urban Ring tunnel design, and the timely implementation of early actions
that will provide improved transit service in segments located throughout the corridor,
with an emphasis on segments where the need for transportation improvements is
greatest.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding potential early actions and
major infrastructure elements.
G-6.14
Comment
“EOT should move toward adopting a final Locally Preferred Alternative by laying out a
schedule for resolving the key remaining technical issues, including the connection
between Albany Street and the Grand Junction Corridor in the vicinity of Fort
Washington Park.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding potential early actions and
major infrastructure elements. As the alignment from Albany Street to the Grand
Junction bridge in the vicinity of Fort Washington Park is refined, EOT will continue to
balance the needs of the various stakeholders and abutters with project goals.
G-6.15
Comment
“The modeling has been done assuming that there are no capacity constraints in the
MBTA system. We urge that you ensure that the Final EIR/EIS includes a ridership
analysis which takes into account capacity constraints on the rapid transit lines and in
the core stations.”
Response
See response to Comment G-7.3. Group G - Response to Institution Comments Page 95
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
G-7.1 G-7
Medical Academic and Scientific Community Organization (MASCO)
January 30, 2009
Comment
“Interim surface routes evaluated underestimate access problems and impacts of the
surface routes in the LMA… We therefore do not support deferral of a tunnel as a
future Phase 2 element. The tunnel serves the largest projected ridership on the Ring,
and will avoid worsening roadway congestion for local traffic in the LMA and regional
traffic in the corridor.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding the timing of potential early
actions and major infrastructure elements.
G-7.2 Comment
“We request that the Secretary’s scoping for preliminary engineering and the
FEIR/FEIS require that EOT proceed without delay on the following steps:
•
•
Immediately advance a short-term work program to include some aspects of
preliminary engineering, including additional tunnel analysis, using state bond
funds earmarked for the urban Ring in the 2008 Transportation Bill;
Encourage EOT to extend its existing contract so that time and momentum is
not lost in the procurement process.”
Response
Refer to the NPC Attachment 6 (Section 6.2.2) regarding the timing of potential early
actions and major infrastructure elements.
G-7.3 Comment
“Conduct additional ridership modeling which takes into account capacity constraints
on the rapid transit lines and in the core stations, and which will identify more
accurately the ridership and environmental benefits of the project.”
Response
Ridership modeling sensitivity analysis with capacity constraints will be reviewed and
considered during preliminary engineering and final environmental.
G-7.4 Comment
“Require the submission of biannual progress reports to monitor the project’s progress
during 2009.”
Response
Because bi-annual monitoring reports would only be published in the Environmental Monitor for informational purposes and not subject to a full public review under MEPA, the Secretary’s Certificate issued on March 6, 2009 directs EOT to submit a Notice of Project Change by June 30, 2009 to provide information regarding early action items, financing, construction schedule, and implementation. Group G - Response to Institution Comments Page 96
RESPONSE TO COMMENTS ON RDEIR G-7.5 Comment
“Overall, additional studies should resolve important issue areas including Allston
connections, the Charles River crossing, Longwood Area tunnel, and Somerville
routing near Sullivan Square and Mystic River.”
Response
Since the submission of the RDEIR/DEIS, EOT has identified the preferred BRT
alignment and configuration for the Allston connection, but impediments remain for this
and the other two major infrastructure elements in the Southern Tier (Charles River
Crossing and the Fenway/LMA Tunnel) and the approach for resolving them is
described in the NPC Attachment 6 (Section 6.2.2). In the Northern Tier it is
recommended that the routing near Sullivan Square and the Mystic River be modified
as described in the NPC Attachment 5 (Section 6.1).
G-7.6 Comment
“Specifically to the Longwood Medical and Academic Area there is a need for
additional studies to address resolution of the final locally preferred alternative (LPA)
tunnel routing options including further and full evaluation of tight-turn, medium-turn,
and wide-turn tunnel options; and resolution of final locally preferred alternative (LPA)
tunnel portals, not exclusively limited to the Park Drive portal options on the west end
of the LMA. The goals of further evaluation should be to determine the optimal
alignment while balancing the impacts of construction and operation on private
property, public open space and the transportation systems serving the area.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Also see response for Comment F-1.3 for a schedule of resolving
key issues.
G-7.7 Comment
“Due to its cost, construction impact, permanence and complexity, the development of
the tunnel will require more time and resources than other segments of the Urban
Ring. The planning and continued engineering of this vital segment of the Urban Ring
should therefore continue without delay.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Also see response for Comment F-1.3 for schedule for resolving
key remaining technical, routing, and implementation issues.
G-7.8 Comment
“Additional engineering work is required to define the recommended tunnel alignment,
construction methodology and the tunnel configuration (single bore, twin bores, etc.)
and cost. The land area required along the alignment both to support construction and
for permanent right of way should be accurately assessed as well as the costs, legal
and political feasibility of land or easement acquisitions.”
Response
See response for Comment G-7.7. Additional tunnel construction data and right-of-way
impacts will be provided in future environmental review documents for this element of
the project.
Group G - Response to Institution Comments Page 97
RESPONSE TO COMMENTS ON RDEIR G-7.9 Comment
“It is imperative that site-specific geotechnical information be obtained to inform the
preliminary engineering of the tunnel. Similarly, a thorough investigation should be
made of the buildings adjacent to the alignments and proposed underground station,
focusing on the location and type of foundation system supporting each. Potential and
actual conflicts should be identified, and an assessment should be made of the likely
impacts to each building and campus resulting from the tunnel and station construction
work in close proximity, and the most likely and effective mitigation.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Specific geotechnical impacts and associated mitigation will be
identified in future environmental review documents for this project with the
identification of a final LPA tunnel alignment through the LMA.
G-7.10
Comment
“The Final EIR/EIS should present a thorough discussion of the tunnel construction
methodology, costs, staging sites, and physical and economic impacts on private land
uses and public property; and traffic, pedestrian and excavate management impacts
and procedures during construction. It should identify associated construction phase
impacts, including noise, vibration and EMF/Moving Metal impacts that may have the
potential to affect sensitive medical, academic, cultural or research facilities; as well as
operational impacts on such facilities related to both Phase 2 BRT and future Phase 3
rail plans.”
Response
Busway tunnel construction methodology was discussed in RDEIR/DEIS Section
3.15.5. Construction noise and vibration impacts were discussed in RDEIR/DEIS
Section 5.6.6.
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Tunnel construction methodology, costs, staging sites, physical and
economic impacts on private land uses and public property; traffic, pedestrian and
excavate management impacts and procedures; and noise, vibration and EMF/Moving
metal impacts will be further defined in future environmental review documents for this
project with the identification of a final LPA tunnel alignment.
G-7.11
Comment
“One objective of the next phase should be to reach a definitive policy decision with
regard to the Phase 3 alignment and anticipated rail technology (light or heavy rail). At
present, the decision to develop Phase 2 so as not to preclude the use of heavy railtransit technology in a future Phase 3 results in limiting the alignments available for
consideration. All heavy-rail transit compatible alignments require wider turns with the
potential for substantial private property impacts that are likely to increase the cost of
Phase 2. A tight-turn option more suited to light-rail technology could be constructed
primarily within the public right-of-way with less impact to private property and could be
constructed without the extent of vibrations, cost and surface impacts at the critical
Longwood/Brookline intersection related to use of a tunnel boring machine as
proposed in the RDEIR/DEIS. Given the impact and burden placed on the planning,
and to an extent the cost of Phase 2 by the heavy rail design criteria, it is worthwhile to
re-examine the recommendations in the 2001 Major Investment Study (MIS) of
Circumferential Transportation Improvements in the Urban Ring Corridor in the context
of the regulatory and federal funding framework in place today.”
Group G - Response to Institution Comments Page 98
RESPONSE TO COMMENTS ON RDEIR Response
Comment noted. G-7.12
Comment
“A full documentation of the cost, ridership, environmental, and public and private
property impacts of construction and operation related to each of the tunnel alignments
being considered must be completed in the FEIR/FEIS.”
Response
See responses to Comments G-7.8 and G-7.10 regarding tunnel impacts. G-7.13
Comment
“The proposed service plan should be revised to make sure that it can accommodate
the passenger demand. There is likely a need to provide more service in the Urban
Ring corridor between Ruggles Station and Yawkey to accommodate this demand.
This could be achieved by running an additional route as a shuttle between these two
points through the tunnel in addition to the proposed through service. The scope of
work for the Final EIS/EIR should provide for more development of the service plan in
the LMA segment to maximize the throughput and therefore the benefit of the tunnel.
Engineering studies should be performed at the portal locations to provide for the
vehicles to turn around in a controlled ROW in order to avoid the risk of delay to the
service schedule from operations in mixed traffic.”
Response
The tunnel service plan will be revised/updated at such time as the Fenway/LMA
Tunnel element of the project is advanced. The concept of a potential shuttle service
between Yawkey Station and Ruggles Station can be evaluated at that time. The goal
will be to maximize the throughput capacity of the tunnel.
G-7.14
Comment
“Preliminary engineering and the FEIR/FEIS should develop a more detailed phasing
and implementation plan that identifies potential early action items and schedules, in a
manner that does not segment future tunnel costs from ridership benefits of the whole
project. It is suggested that the EOT work with the Federal Transit Administration (FTA)
to develop the Urban Ring as a ‘Program of Interrelated Projects’ for the purpose of
FTA review and New Starts funding, similar to the approach undertaken by Utah
Transit Authority in its ‘Transit 2015 Program.’ By so doing, various elements of the
Urban Ring can be implemented early in the program while other critical elements will
be done in later years without the potential for segmentation of the project. As a
‘Program of Interrelated Projects,’ the benefits of the full program could be recognized,
with local funding expended on any of the projects within the program counting
towards the local match.”
Response
See response to Comment F-1.1 regarding a phasing plan with early action items. EOT
will continue to coordinate with FTA on the concept of treating the Urban Ring Phase 2
as a Program of Interrelated Projects.
G-7.15
Comment
“The RDEIR/DEIS references a potential ‘interim surface route’ in the LMA prior to
completion of the tunnel described in the LPA without clearly specifying the route in the
LPA and the impacts. As noted in the document, and as a result of the comments
made on the 2004 DEIR and in the EOEA Certificate of 2005, a tunnel through the
LMA is critical due to: (1) the detrimental impacts a surface option would have on the
Group G - Response to Institution Comments Page 99
RESPONSE TO COMMENTS ON RDEIR access needs of the LMA; and, (2) the unreliable travel times that would plague Urban
Ring service throughout the corridor if a surface route were implemented in the LMA.
While MASCO supports the LPA, we reserve the right to comment on any future
proposed interim surface option. Much of the roadway data presented in Section 4.4 of
the RDEIR/RDEIS rely on general regional transportation documents, which do not
highlight the surface transportation issues in the LMA. The current levels of congestion
in the LMA on major roadways proposed for interim surface Urban Ring service, such
as Longwood and Brookline Avenues, are not emphasized.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Various potential interim surface routes in the LMA were
developed and discussed with the City of Boston and area stakeholders throughout the
RDEIR process but were opposed by the stakeholders. EOT remains willing to work
with the City of Boston and stakeholders to reach agreement on a strategy for
improving transit in the Fenway/LMA between Yawkey and Ruggles Stations prior to
the tunnel being completed and operational.
G-7.16
Comment
“The intersection Level of Service data in Table 4-28 underestimate typical operating
conditions at some intersections and are inconsistent with the findings of traffic
analyses, included in the LMA projects referenced on page 4-66.”
Response
As noted in RDEIR/DEIS Section 4.4.4.1 and in Section E (page 50) of the Technical
Traffic Report, traffic volumes generally decreased between 2002 and 2006. This could
explain slight discrepancies in LOS analysis results provided in the RDEIR/DEIS
compared to previous studies.
G-7.17
Comment
“The impacts of possible future queue jump lanes on general LMA access needs for
patients and others, for example at the Longwood/Brookline Avenue intersection, are
underrepresented. The traffic Technical Report does not provide additional clarification
regarding methodology and assumptions used that explains this discrepancy. This is
concerning for two reasons: (1) the need for the tunnel due, in part, to existing roadway
congestion is not emphasized by the analysis presented; and, (2) the impacts of the
interim surface options cannot be determined from the data represented.
“Any surface route in the LMA, if implemented, should be considered only the most
temporary of solutions. As a surface route alternative to implementation of a queue
jump lane at Brookline and Longwood Avenues, the FEIR/FEIS could evaluate as a
possible early action item making signal and bus stop improvements to benefit the
existing CT2 route, which for the most part parallels a future BRT5 and part of BRT1.
This could result in a more efficient service without adding additional buses to the
congested LMA area and reduce capital and operating costs for the MBTA, rather than
adding a new service which could require the purchase of a fleet of buses to support
it.”
Response
The RDEIR/DEIS traffic analysis includes the impacts of queue jump lanes where they
are proposed. Additional clarification regarding the methodology and assumptions
used for traffic analysis at proposed queue jump lane locations will be provided during
final environmental filings.
Group G - Response to Institution Comments Page 100
RESPONSE TO COMMENTS ON RDEIR See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. The interim surface route proposed in the LMA is intended to be
only a temporary route until construction of the tunnel is complete. The signal and bus
stop improvement suggestion for the existing CT2 route in this comment will be
considered as an alternative to a queue jump lane at Brookline and Longwood
Avenues in future environmental review documents for this project.
G-7.18
Comment
“The document is inconsistent in its description of existing transit services at Ruggles
Station. In an effort to clarify the importance of Ruggles Station as a regional, multimodal station, please note that the station serves three commuter rail lines: Needham,
Providence/Stoughton, and Franklin. The reference to the Ruggles Station platform
configuration (page 3-34) appears to be from an analysis completed by MASCO in
2008. If this design option is assumed for the Urban Ring Phase 2, the cost should be
adjusted to reflect $13 million, rather than $32.5 million (Table 2-10, page 2-47). This
platform has potential to be advanced as an early action item.”
Response
Comment noted. Ruggles Station is identified in the NPC Attachment 6 (Section 6.2.2) as a potential early action.
G-7.19
Comment
“The document indicates on page 3-34 that commuter rail service at Yawkey Station
could be substituted for other commuter rail facilities that might be considered in the
future. Funding of $12 million was designated in the 2006 Massachusetts Economic
Stimulus Bill to implement full-length commuter rail platforms at Yawkey, and design
and construction of a new station is proceeding through the Fenway Center multi-use
project approved by the City of Boston’s Redevelopment Authority on January 29,
2009.”
Response
Comment noted. G-7.20
Comment
“The document provides a sample station for the Longwood Avenue Station location,
and indicates the precise location could change during preliminary engineering. The
minimum sidewalk dimensions in Chapter 4 (p. 4-88), present a challenge to locate a
station headhouse in the LMA while still allowing space for high levels of pedestrian
volumes. Because of this and the high incidence of strollers and handicapped patients,
this minimum standard for sidewalk width in areas of high pedestrian volumes should
be revisited in the FEIR/FEIS analysis, and should be considered more as a last resort
rather than a standard.”
Response
Minimum standard sidewalk widths will be revisited during preliminary engineering of
the project. We agree that for areas with high levels of pedestrian activity such as the
LMA with its mix of users, sidewalk widths may need to be wider than the indicated
minimum.
G-7.21
Comment
“The positioning of stations should be additionally evaluated in the context of quality
and quantity of open space, conflict with adjacent architecture, and impacts on
waterways and historic resources, in conjunction with other criteria.”
Group G - Response to Institution Comments Page 101
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment G-6.7 regarding additional evaluation of station locations
and orientation.
G-7.22
Comment
“Planning and engineering for the Urban Ring must move forward in consistent stages
so that the project can be ‘ready to go,’ as the economy improves and as solutions are
found for Massachusetts’ transportation financing for roadways, the Turnpike and the
MBTA. While potential exists for some private funding opportunities like joint
development and easements, and potentially other measures, a broader-based
financing plan should be constructed that recognizes the significant statewide and
metropolitan area benefits of the project, not just in the Urban Ring corridor. The plan
should take care not to place the Urban Ring in competition with municipal sources of
funding in a way that would undermine local support for the project. Alternative
financing mechanisms have been used elsewhere in the United States to fund
infrastructure improvements, but are relatively new concepts for transportation
planning in Massachusetts. If they are to be adopted by the Commonwealth, they
should be applied universally to all expansion projects and not just the Urban Ring.
“Additionally, given the difficult economic climate nationally, we recommend that the
Secretary of EOEEA request that EOT explore opportunities for additional regulatory
flexibility with the Federal Transit Administration with respect to requirements for
detailed financing plans at this stage of a project, including the possibility of securing a
Federal waiver to allow projects to go for New Starts applications, and address the
very detailed finance plans prior to a project entering into a full funding grant
agreement. It will also be essential for EOT to secure sufficient language for the Urban
Ring in the Regional Transportation Plan Update to proceed with Preliminary
Engineering/Final Environmental Report.”
Response
The funding suggestions posed in this comment will be considered. See response for
Comment F-1.2 for implementation schedule and funding options.
G-7.23
Comment
“Additional engineering and design should be pursued, to capture existing momentum,
into additional engineering and the FEIR/FEIS phases.”
Response
See response to Comment F-1.2 for Urban Ring project implementation schedule. Group G - Response to Institution Comments Page 102
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-8
Received from: Partners HealthCare System
February 12, 2008
Comment No.
G-8.1 Comment
“Critical issues that need to be addressed and resolved during the remainder of the
MEPA review process…:
• Advancing the design and engineering of the Urban Ring in support of
developing a Locally Preferred Alternative, with a particular focus on the
critical Longwood Medical Area transit tunnel, options for connections to
Allston, and the possibility of a supplemental connection to Charlestown
• Ensuring that the project’s ridership, transportation, economic and
environmental benefits are fully captured by modeling that accurately depicts
the likely range of the project’s benefits”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Also see response to Comment F-1.3 for a schedule to resolve
remaining key technical, routing, and implementation issues.
As the LPA alignment is developed, project benefits will be modeled and presented in
future environmental review documents.
G-8.2 Comment
“With projected employment increases in the future, even maintaining the current
transit mode share would create demand for hundreds of additional daily transit seats
for Brigham employees alone.
“The only way to provide such an additional transit service for Brigham and Women’s
and the LMA, in the long run, is by constructing an LMA transit tunnel…Without high
quality and frequent transit service, such a high level of employment and activity
density generates unacceptable high levels of traffic congestion. But this same density
of employment and activity makes it difficult to provide the desired frequency and
quality of Urban Ring Bus Rapid Transit service in the LMA on existing surface streets.
The LMA transit tunnel serves a very high share of new Urban Ring riders and
provides a well controlled, reliable service that makes critical connections to existing
transit facilities as well as to other areas in the Urban Ring corridor.”
Response
The importance of the LMA tunnel portion of the project is noted. See response to
Comment E-2.10 regarding future environmental steps for the tunnel portion of the
LPA.
G-8.3 Comment
“Partners is committed to continuing to work to identify near-term improvements
including potential surface routes that can be implemented as part of early phases of
the Urban Ring. Even the most optimistic timelines for designing, engineering,
financing and constructing the LMA transit tunnel ensure that the tunnel will not be in
service for many years and the LMA’s congestion problems necessitate interim
improvement measures.”
Group G - Response to Institution Comments Page 103
RESPONSE TO COMMENTS ON RDEIR Response
Commitment to near-term improvements as part of early phases of the project is noted. G-8.4 Comment
“The development of the tunnel requires additional analysis, design and preliminary
engineering. The RDEIR/DEIS does not provide sufficient information to allow EOT to
make a final decision on critical issues for the LPA as portal locations, tunnel routing
and construction methodology. Partners therefore asks that your Certificate require
EOT to continue analyzing alternatives with respect to the location of the west portal
and with respect to how and where the tunnel will be built.”
Response
See responses to Comments G-7.7, G-7.8, and G-7.10. G-8.5 Comment
“Urban Ring buses would enter the LMA transit tunnel through a western portal
adjacent to the Green Line D branch on the east side of Miner Street near Landmark
Center and continue in the tunnel to two underground stations, Fenway Station and
LMA station, emerging through an eastern portal on the north side of Ruggles Street to
Ruggles Station.
“…We do not believe that EOT is in a position to make a final decision on the location
of the western portal for the LMA tunnel. During the CAC’s review of tunnel analyses
produced in support of the RDEIR/DEIS, Partners indicated its interest in a through
analysis of the advantages and challenges of extending the tunnel and tunnel portal
further west. We continue to believe that this option has benefits with respect to
constructability, reliable operation of BRT routes and potentially reduced costs for
Phase 3. The final EIR/EIS needs to include an extensive, well-documented and fair
comparison of portal options based on substantial additional design and engineering
work beyond that undertaken for the RDEIR/DEIS.”
Response
The RDEIR evaluated the option of extending the Phase 2 tunnel further west to the
vicinity of the BU Bridge and the results of that evaluation are summarized in the
RDEIR Chapter 3, Section 3.14. Also, see response to Comment G-7.7.
G-8.6 Comment
“Choosing a route for the tunnel, once the portals are fixed, requires a careful
balancing effort that takes into account ridership, cost, technological feasibility,
constructability, operability and issues such as vibration and other impacts. The
Longwood Medical Area is the site of some very specific and important functions,
which will make tunnel construction and operation challenging. These functions include
vibration-sensitive research and delicate surgery and it is obviously important for
emergency access to be maintained. All of these factors (and others) must be
identified, analyzed and presented clearly to the CAC before a final decision as to the
tunnel’s route and construction methodology is made in the final EIR/EIS.”
Response
See responses to Comments G-7.7, G-7.8, and G-7.10. Group G - Response to Institution Comments Page 104
RESPONSE TO COMMENTS ON RDEIR G-8.7 Comment
“In considering the inter-related issues of portal location, tunnel route and tunnel
construction methodology, EOT must respect MEPA’s requirement that all aspects of
Phase 2 ensure compatibility with a future Phase 3 of the Urban Ring. While Partners
continues to strongly support a future rail version of the Urban Ring, we do not believe
that this requirement necessitates that each and every tunnel option considered
support all rail technologies (eg light and heavy rail). Instead, the final EIR/EIS can
comply with this requirement by presenting different options and explaining the extent
to which they would support future light rail, future heavy rail or both.”
Response
Comment noted. This approach was taken in the RDEIR, which identifies three tunnel
alignment options for the LPA, one of which is not heavy rail compatible. This
approach could also be used in future preliminary engineering and environmental work
on the Fenway/LMA tunnel.
G-8.8 Comment
“The tunnel portals and route might ensure compatibility with all of the options still
under consideration for extending the Urban Ring to serve Allston. Partners supports
further analysis of Urban Ring options for serving Allston, including the area where
Harvard University is planning, and has begun constructing, a major sciences campus.
Harvard’s Allston campus is currently slated to include a relocated Harvard School of
Public Health and many life sciences-related laboratories. Brigham and Women’s
Hospital collaborates with the School of Public Health and other Harvard research
faculty on numerous projects and is committed to maintaining a high level of
collaboration when the Allston campus opens. Given traffic congestion and parking
limitations in both LMA and Allston, transit in general and the Urban Ring in particular
will have to provide a vital link between these two important life science clusters. Your
Certificate should therefore provide the broadest possible scoping for pursuing
potential Allston alignments and ensuring that those alignments are evaluated for their
compatibility with ongoing planning processes underway by the City of Boston and
Harvard University.”
Response
Support for service to Allston is noted. The Allston alignment has been refined since the publication of the RDEIR/DEIS. The
proposed alignment is described in Attachment 6 (Section 6.1) of the NPC. EOT is
committed to advancing this portion of the project, but must address outstanding
issues and impediments (see Attachment 6, Section 6.2 of the NPC). EOT will continue
to coordinate these planning efforts with the City of Boston and Harvard University.
G-8.9 Comment
“The DEIS/R shows the Urban Ring alignment proceeding from Lechmere to Sullivan
Square across the Somerville rail yard, but fails to consider the benefits of a
supplementary alignment connecting Lechmere to Sullivan via Charlestown. We
believe this supplemental route could provide added benefit and early implementation
and should be developed in the FEIR/S.”
Response
The alignment via Bunker Hill Community College and Rutherford Avenue in
Charlestown was evaluated in the RDEIR in Alternatives 1, 2, 2A, 3, 3C, 4, and 4A and
found to be less effective than the routing via Cobble Hill in Somerville. Charlestown is
served by the Urban Ring at Sullivan Square.
Group G - Response to Institution Comments Page 105
RESPONSE TO COMMENTS ON RDEIR G-8.10
Comment
“One of the most critical shortcomings of the generally excellent RDEIR/DEIS is that it
fails to analyze the environmental benefits and impacts of the Urban Ring in light of the
real capacity constraints that exist in the MBTA’s rapid transit system. The modeling
conducted to project Urban Ring ridership is based upon current regulations of the
Federal Transit Administration... The modeling does not include growth that would be
induced by the transit improvement itself, even though such “induced” growth would
likely mean additional development in the Urban Ring corridor and even greater
ridership for the Urban Ring. While the use of FTA modeling protocols is appropriate as
a base case, MEPA can and should require additional or alternative modeling (eg.
Sensitivity analyses) if the modeling protocols do not fully illuminate the potential
environmental benefits of a transit project like the Urban Ring – as is the case here.
“The RDEIR/DEIS ridership projections for 2030, for both the No Build and LPA case, starkly demonstrate another critical shortcoming of the Modeling. The 2030 ridership projections show a massive growth in MBTA ridership on both the Red Line and the Green Line… Even before the recent and much-welcomed rise in transit ridership, transportation planners knew that critical parts of the MBTA’s rapid transit system were approaching capacity. The Urban Ring RDEIR/DEIS simply confirms these concerns. “…The Central Transportation Planning Staff modeling protocols used for the Urban Ring (and, apparently, all proposed transit expansion projects) assume no capacity constraints in the MBTA system – but in reality such constraints exist. So while the projections accurately reflect the demand for transit, they do not reflect what the MBTA system will be able to supply in 2030 given real capacity constraints on the system. On the Green Line in particular, where there are no viable plans for increasing capacity, the MBTA simply cannot accommodate the level of ridership projected in the “no build” 2030 scenario presented in the Urban Ring RDEIR/DIES. “These “unconstrained” ridership projections mean that the Urban Ring’s benefits are being underestimated in the RDEIR/DEIS… The “core congestion” benefits of the Urban Ring become even more significant if the system in 2030 is examined in light of the very real capacity constraints that exist. “Even if the FTA does not change its New Starts modeling protocols, MEPA can and should ensure that all MEPA analyses that include future ridership projections clearly identify and model the effects of projected capacity constraints in the MBTA system in the analysis year and explain how the proposed project will relieve (or exacerbate) those capacity constraints.” Response
See response to G-7.3 regarding ridership modeling with capacity restraints. Growth levels in Red and Green line ridership by 2030 are based on CTPS regional
model projections, which account for anticipated growth and development projects in
the area consistent with MAPC adopted land use projections.
G-8.11
Comment
“Partners strongly urges both you and EOT to move this vital project ahead
expeditiously. Partners is therefore troubled by language in the RDEIR/DEIS that
seems to indicate that completion of the final EIR/EIS could take up to three years.
Partners does not read the document as formally requesting an extension of the
deadlines in the current MEPA Special Review Procedure, which includes a December
31, 2009 deadline for filing of a final EIR/EIS. If such a request has been made by
EOT, Partners would oppose such an extension at this time.
Group G - Response to Institution Comments Page 106
RESPONSE TO COMMENTS ON RDEIR “Partners believes that you should use the current structure of the Special Review
Procedure to ensure progress toward timely completion of the final EIR/EIS. Your last
Certificate, written in response to EOT’s April 2008 Notice of Project Change, provided
for biannual progress reports to be filed on March 31 and September 30, 2009. We ask
that your Certificate on the RDEIR/DEIS provide that specific issues be addressed in
those next two progress reports.
“…While Partners continues to support the expeditious submission of the Urban Ring
to the New Starts program, we do not believe that such a step is necessarily required
at this time to advance further environmental review, design and preliminary
engineering. The last transportation bond bill contained ample funds to continue Urban
Ring MEPA and NEPA review for the time being. EOT already has an excellent
consultant team in place, which was selected by a thorough procurement process that
took place only a few years ago. Hopefully EOT can keep this team in place and use
the bond bill funds to begin immediate work on the FEIR/FEIS, without a lengthy delay
like the one that occurred after issuance of the 2005 Certificate on the DEIR…
Partners would like to see a full discussion of procurement/staffing, and financing and
other related issues, including the timing of applying for entry into the New Starts and
Preliminary Engineering processes in the March 31 biannual report so that you, the
CAC members and the general public have a clear understanding of EOT’s timetable
for moving ahead with the final EIR/EIS.”
Response
See response to Comment F-1.2 regarding immediate next steps and financing options
under consideration. See response to Comment G-7.4 regarding the request for
biannual progress reports.
See response to Comment F-1.3 regarding a schedule for resolving key remaining
issues of the Urban Ring project.
G-8.12
Comment
“Partners also urges you to require EOT to move ahead on a phasing and
implementation plan for Urban Ring phase 2 in advance of final publication of the final
EIR/EIS. Such an implementation strategy can and should be included as part of the
September 30 2009 biannual progress report… The RDEIR/DEIS acknowledges that
early implementation of some project elements is both possible and desirable. In order
to ensure early action and ongoing implementation – rather than an “all or nothing”
strategy that delays realization of the Urban Ring’s many benefits – EOT needs to act
quickly to develop a detailed phasing and implementation. Your Certificate should
require EOT to prepare and circulate to the CAC and the public (by September 30,
2009) a blueprint for ensuring that early action opportunities are identified and realized,
one which identifies specific early action items and schedules for their implementation.
“This phasing and implementation plan should not be constrained by the Federal
Transit Administration’s current regulations that seem to have the unfortunate
consequence of warping decision making about phasing. (This occurs because if any
project element is implemented early, then both the costs and benefits of that early
action are apparently removed from the analysis of the overall project… Instead, the
plan should specify an optimal timetable, identify responsible parties and cost
estimates and analyze the pros and cons of various approaches to phasing. As part of
this analysis, EOT and the FTA can explain the potential financial and regulatory
consequences of different phasing strategies. One potential model identified by
MASCO is to develop a “Program of Interrelated Projects” for the purpose of FTA
review and New Starts funding, similar that undertaken by Utah Transit Authority in its
‘Transit 2015 Program.’”
Group G - Response to Institution Comments Page 107
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment F-1.1 for phasing and implementation plan and early action
items. See response to Comment G-7.4 regarding the request for biannual progress
reports.
See responses to Comments F-1.2 and F-1.3 for a definition of project phasing,
possible funding sources, and a schedule for resolving remaining issues.
Group G - Response to Institution Comments
Page 108
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
G-9.1 G-9
University of Massachusetts Boston
February 9, 2009
Comment
“Over the next several years, Columbia Point will see many changes to its commercial,
educational, and residential base which will demand improved commuter access to the
region.
“Given this level of planned development on the peninsula, the University is greatly
concerned that the connection between the JFK/UMass Station to the campus via
Mount Vernon Street has been removed from Phase II of the project. Terminating at
JFK Station does not allow for a sufficient level of service that will be required on
Columbia Point as future construction and development takes shape. Accordingly,
UMass Boston respectfully requests that the Mt. Vernon Street link be reconsidered.”
Response
The Mt. Vernon Street link will be reconsidered in future environmental review for this
project. Refer to the NPC Attachment 6 (Section 6.2.1).
G-9.2 Comment
“In order to begin to receive the benefits of the Urban Ring service as soon as
possible, and to take advantage of the ability to implement the project one piece at a
time, I ask that you also recommend that EOT move ahead swiftly to identify potential
early actions and to begin planning and design of these actions in the near term. The
project needs to continue into the Preliminary Engineering phase and then complete
the Final EIR so that we can move ahead with all components of the project.”
Response
See responses to Comments F-1.1, F-1.2 and F-1.3 regarding early action items, project phasing, and a schedule for resolving remaining issues. G-9.3 Comment
“Throughout this process, I expect that community involvement will continue to be
emphasized and that stakeholders will have an opportunity to be involved in the
process that brings this project into reality.”
Response
Public participation will continue to be a vital part of the planning process as Urban
Ring Phase 2 moves forward.
Group G - Response to Institution Comments Page 109
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-10
Received from: Wentworth Institute of Technology
February 10, 2009
Comment No.
G-10.1
Comment
“We have significant concerns over the economic viability of the LMA tunnel portion of
the LPA as well as the details of the tunnel and its portal and its specific system
connectivity features, its anticipated construction period, its impacts on pedestrian and
bike access to Wentworth via Ruggles and Parker Streets, and its long-term visual
impacts.
“As we said in our prior letter, this tunnel should be designed to accommodate a future
rail service (probably Green Line light rail). We ask that the incremental cost to
construct the tunnel to LRV standards be identified in the RFEIR/S so that it can be
clear that the switch from BRT to LRV is seamlessly possible without major service
disruptions.
“We certainly never envisioned a tunnel portal on Ruggles Street with a 6-lane crosssection on Ruggles Street at Leon Street.”
Response
See responses for Comments G-7.7, G-7.8 and G-7.10 regarding additional tunnel
analysis.
Additional cost data will be provided in future environmental review documents for this
project.
G-10.2
Comment
“With modifications identified below, we can endorse the Interim Surface Alignment
option, but question whether the $2.4 billion (2007 dollars) investment identified in the
RDEIR/S for the Phase 2 Urban Ring project is warranted within the context of the
anticipated benefits for our campus and the MBTA’s public transportation system as a
whole.
“Based on our understanding of the MBTA system, it would seem that an investment of
that magnitude would be better spent in a cost effective manner by enhancing the
capacity of the Green Line’s Central Subway, where its five branches merge into two
tracks and have little or no capacity for providing additional Green Line service.
“…We are highly concerned about the long-term benefits to the public transportation
system overall compared to other worthwhile system enhancements that could be
made – e.g., addressing the capacity issue of the Green Line Central Subway to create
opportunities for major enhancements to the existing Green Line system. Perhaps it is
time to take a step back and look at the functionality of the Urban Ring project,
particularly as it relates to the underlying “bus” premise of Phase 2.”
Response
The Urban Ring project simultaneously provides additional transit capacity to meet
existing and growing demand for circumferential trips, while also relieving some of the
existing congestion on the central subway system (eg. the Green Line) by allowing
many trips currently transferring between radial lines downtown to have a direct trip on
the Urban Ring service – thereby freeing up capacity in central subway system. This
benefit of the Urban Ring will be defined and evaluated further during preliminary
engineering and final environmental review.
Group G - Response to Institution Comments Page 110
RESPONSE TO COMMENTS ON RDEIR G-10.3
Comment
“We have always understood that to be effective for urban development and creative
regional routing options, Green Line technology must be the transportation mode of
choice for the Urban Ring. We do not believe that a BRT system with its required
transfers and street-running traffic issues is a cost effective way to provide this service
within the context of development potentials, tunnels and street lane capacity needed,
etc.
“Specifically, the projected long duration of adverse construction period impacts as it affects Wentworth’s campus are expected to be substantial. Without a long-term seamless switch to rail for Urban Ring services, which creates the opportunity for one-
seat rides along circumferential and radial corridors, Wentworth believes the adverse impacts we will need to endure will not be offset by Phase 2 benefits to our campus.” Response
Green Line technology (light rail) is still under consideration as part of Phase 3. G-10.4
Comment
“Wentworth also has serious concerns about the validity of the year 2030 ridership
estimates contained in the RDEIR/S document.
“…Major MBTA ridership increases will occur with or without the Urban Ring… During
the 23-year period from 2007 to 2030, the RDEIR/S projects that the MBTA, with the
No-Build alternative, will pick up more than 55,000 new riders per day or, on average,
approximately 24,000 riders per day per year. How is this projected huge ridership
increase possible? Will jobs and population be expanding at a rate more than 5 times
as great as recent history indicates? Both the Red and Green lines are all packed
during peak periods. Doubling the ridership on these lines by 2030, as shown on
Figure ES-6 does not make sense within the context that the capacities of the subway
systems themselves…. The Red and Green Line train set limitations are not conducive
to doubling ridership on these two lines without major changes that to our knowledge
are not programmed.”
Response
Growth levels in Red and Green line ridership by 2030 are based on CTPS regional
model projections, which account for anticipated growth and development projects in
the area. See response to Comment G-7.3 regarding ridership projections with
capacity constraints.
G-10.5
Comment
“On several occasions, the CAC questioned how the ridership data was derived, and
based on conversations with the CAC members, we understand that there are still
many unanswered questions among the CAC. As a member of the public, we did not
receive any information about how these numbers were derived, and would like to
request further clarification as to how these ridership projections were calculated.”
Response
Ridership data was obtained from the CTPS Regional Travel Demand Model. The
methodology used to develop the ridership estimates is described in the Travel
Demand Modeling Methodology Technical Report, which was completed in December
2008.
Group G - Response to Institution Comments Page 111
RESPONSE TO COMMENTS ON RDEIR G-10.6
Comment
“Interim modifications are proposed to enhance Bus Rapid Transit use of Ruggles
Street. Referred to as the “Interim Surface Alignment” (ISA), the concept provided in
the RDEIR/S is the same paved cross-section as to the Lane Balance Concept
developed by MASCO, Northeastern University, and Wentworth Institute of Technology
several years ago. While some features of the ISA are good, like the short median to
enhance pedestrian crossings on Ruggles Street at the Ruggles Station, we prefer the
two-lane cross-section of the Lane Balance Concept, rather than the three lanes
westbound and one lane eastbound at Huntington Avenue and Parker Streets. As in
the 2004 DEIR, the prospect of buses turning left from the right lane and vehicles
turning right from the middle lane are built into the concept sketch for the “Interim
Surface Alignment” (“ISA”) is very disconcerting for vehicle and pedestrian safety
reasons.
“…We believe the ‘Lane Balance’ Alternative generally can accommodate BRT flow
better than the illustrated ISA. Geometric features of the ISA are close enough to the
‘Lane Balance’ Alternative, that it can be modified with minor striping and tweaking. We
believe the CT2 and CT4 westbound BRT’s should be accommodated on the west side
of Huntington Avenue just south of Louis Prang Street, not the north side of Ruggles
Street at Huntington Avenue with BRT left turns being made from the right travel lanes
when motorists in the center lane are allowed to turn right.
“With the ‘Lane Balance’ Alternative, riders from the Green Line outbound who desire
to transfer can do so by crossing Louis Prang Street, but the two BRT Routes that will
be turning left would be turning from the left lane, not the right lane. Similarly the CT3
Westbound route would be crossing the Huntington Avenue from the right lane.
Through use of state-of-the-art bus vehicle detectors, BRT/MASCO shuttle priority can
still be provided with the ‘Lane Balance’ Alternative without the necessity of going to a
whole separate signal system or criss-crossing conflicting vehicle movements at an
already skewed intersection with very high pedestrian movements and a historically
high crash rate. The same situation holds for the ISA’s proposed treatment of Ruggles
Street at Parker Street. The proposed alignment of the lanes at Parker Street is
troubling as the through lanes appear to be offset.”
Response
EOT appreciates the constructive input provided, which will be considered during
further planning of the Interim Surface Alignment for transit service in the Ruggles
Street corridor.
G-10.7
Comment
“The traffic analysis of the ISA traffic projections were made for the year 2030, which
leads us to conclude that the ISA, without funding for the LPM LMA tunnel, will likely
serve as the long-term solution.”
Response
The analysis year 2030 was only used to demonstrate how the ISA would operate
under a future “worst case” build-out scenario. The ISA is intended to represent a
temporary condition until the Fenway/LMA tunnel can be constructed.
G-10.8
Comment
“We note that the ISA includes a short median east of Leon Street. While we recognize
this benefits pedestrian crossings, we are unclear as to where the added width of
Ruggles Street will be taken from in this area. We recommend it come from the MBTA
layout, as narrowing the sidewalk in front of the Alice Taylor housing area would be
Group G - Response to Institution Comments Page 112
RESPONSE TO COMMENTS ON RDEIR problematic.”
Response
Based on conceptual engineering in the RDEIR, the needed width for the median
along Ruggles Street east of Leon Street would be taken from the MBTA layout on the
north side of the street.
G-10.9
Comment
“Construction period impacts of the tunnel on Wentworth and Northeastern’s campus
and the Alice Taylor housing as illustrated in the RDEIR/S are expected to be
significant. During the construction period, there will be substantial disruptions to the
Ruggles Street traffic flow, pedestrian and bicycle flow and noise along the Ruggles
Street corridor.
“The documentation of construction period impacts needs clarification to identify how long the work on Ruggles Street will occur. We understand that one of Wentworth’s parking areas we are proposing for a future academic building is being proposed as a construction work zone site. How is this to be resolved? “We believe that the segment of Ruggles Street between Leon Street and Huntington Avenue will be disrupted for a very long period of time to endure cut-and-cover construction plus Tunnel Boring Machine (TBM) access. The RDIER states that “neither tunnel terminus (Leon Street or Yawkey Station Parcel 7) has optimal space or configuration for a TBM launch chamber. This may require an intermediate location for a TBM launch chamber, which would require additional cut and cover construction, and the efficiency of the tunnel boring operations would be reduced by requiring the TBM to be assembled, launched, received and disassembled twice instead of once.” We
conclude this means substantial long term excavation activities at Wentworth’s front door, including the possibility of a long-term disruption to Parker Street – an unacceptable condition. “…Proposed cut and cover operations occur along mainly on Ruggles Street in front of Wentworth. According to the Tunnel Study, the cut-and-cover tunnel that closes Parker Street would be occurring over an undetermined period of time. This will also involve costly measures to maintain the Stony Brook stormwater Channel under Parker Street. After the cut-an-cover portion of the work is completed, the tunnel boring machine (TBM) work will entail construction impacts for a couple of years while the tunnel is bored between Huntington Avenue and the new LMA Station. This means continuing the noise, vibrations, and excavate removal with additional trucks on Ruggles Street over an extended period of time in front of Wentworth’s front door.”
Response
The comments and concerns regarding construction phase impacts are noted. Additional details on construction phase planning and potential impacts is contained in the Tunnel Technical Report found on the project website at www.theurbanring.com. Construction impacts, duration, and mitigation will be further evaluated and documented in future environmental review documents for this project. G-10.10
Comment
“The LPA, as currently envisioned, means that Wentworth will need to endure the bulk
of construction activities and impacts, but will gain very little from a transit access
perspective, as no good connection to the Avenue of the Arts Green Line ‘E’ Line is
proposed with the LPA, and the BRT connection easterly to Ruggles Street Station
made primarily under mixed street traffic conditions. The proposed LMA Station is
Group G - Response to Institution Comments Page 113
RESPONSE TO COMMENTS ON RDEIR located a ten minute walk from the MFA Green Line Station, further than the typical
quarter mile (5-minute) walk generally recognized as being the maximum that people
will walk to access transit.”
Response
The LPA tunnel as proposed in the RDEIR would connect to the Green Line E Branch
via a walk connection from the existing LMA Green Line Station near the corner of
Huntington Avenue and Longwood Avenue, which is about a quarter mile from the
proposed Urban Ring station at Oscar Tugo Circle. East of Ruggles Station the LPA
would provide a center median busway along Melnea Cass Boulevard which provides
dedicated right of way for the Urban Ring – not mixed traffic.
G-10.11
“The proposed tunnel will cause major adverse long-term visual impacts with the
creation of what would be a six-lane cross-section of Ruggles Street between a new
portal at Field Street and the Ruggles Station entrance, a linear distance of
approximately 560 feet. The section would consist of two lanes on the BRT open cut
roadway dropping at a 7 percent grade plus four lanes on Ruggles Street. Two twoway roads within close proximity of one another will be a nightmare for pedestrian
crossings in the vicinity of Ruggles Station at Leon Street.”
Response
See response to Comment E-2.10 regarding future environmental review steps for the
tunnel portion of the project. EOT will continue to work with the City and stakeholders
to minimize aesthetic and pedestrian impacts during preliminary engineering phases of
the project.
G-10.12
Comment
“There is also an inconsistency between the Tunnel Report sketches and the RDEIR/S
sketches of the LPA at Ruggles Street. The tunnel report indicates that the portal
crosses and possibly closes Leon Street. While Chapter 2 indicates the portal starts
immediately west of Leon Street. The inference from the Chapter 2 illustration is that
two-way traffic enters and emerges from the BRT tunnel via sharp turns to and from
Ruggles Street. Which illustration is correct? In the Chapter 2 illustration either the
grade of the BRT tunnel entrance increases or the portal moves westerly, and neither
of these situations is good.
“…We would, in concept, support the tunnel’s use under Ruggles Street without a
portal on Ruggles Street at Leon Street.”
Response
The correct proposed location of the portal is immediately west of Leon Street as
depicted in the conceptual plan and profile drawings on Sheet 6T. Figure 2-9 in
Chapter 2 is a route diagram and the portal symbol there incorrectly shows it east of
Leon Street. Future environmental review documents will clarify the portal locations
consistent with plan and profile drawings.
Group G - Response to Institution Comments Page 114
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
G-11.1
G-11
Wheelock College
February 10, 2009
Comment
“We… suggest that interim surface routes evaluated in the LMA, to date,
underestimate access impacts of the surface routes, particularly the queue jump lane
at the Longwood/Brookline Avenue intersection and the sheer number of buses
proposed through the LMA. Any surface alternatives considered in the future cannot
worsen access conditions in the LMA and should be considered only the most
temporary in nature.”
Response
See response to Comment G-7.17. G-11.2
Comment
“The development of the tunnel will require more time and resources than other
segments of the Urban Ring. The planning and preliminary engineering of this vital
segment of the Urban Ring should therefore continue without delay.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Also see responses to Comments F-1.2 and F-1.3 for Urban Ring
project implementation schedule for resolving key remaining issues.
G-11.3
Comment
“Additional studies must fully analyze and resolve tunnel routing and portal options to:
determine the maximum regional ridership while balancing the local impacts of
construction and operation on private property, public open space and transportation
systems servicing the area; and define the recommended tunnel alignment,
construction methodology and tunnel configuration including the land area required
along the alignment both to support construction and for permanent right of way, with a
full and accurate assessment of costs, legal and political feasibility of land or easement
acquisitions.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. Also see responses to Comments G-7.7, G-7.8, and G-7.10
regarding remaining tunnel issues.
G-11.4
Comment
“There appears to be a high cost premium associated with design and building the
Phase 2 bus tunnel in part because of its requirement to plan for Phase 3 future heavy
rail technology. We encourage you to allow for some relief of this condition in your
Certificate for the RDEIR/DEIS; a light rail option allows for alternative tunnel routes to
be considered, such as a tight-turn option, which could both lower the cost for the
tunnel construction and potentially lower the impacts on private property, lower
vibration impacts, and reduce disruption to surface transportation during construction.”
Response
See response to Comment G-7.11 regarding light versus heavy rail for Phase 3.
Group G - Response to Institution Comments Page 115
RESPONSE TO COMMENTS ON RDEIR G-11.5
Comment
“It is also imperative that site-specific geotechnical information be obtained to inform
the preliminary engineering including a thorough investigation of building foundation
locations and type adjacent to any of the alignments or proposed underground station,
the likely impacts to each building resulting from the tunnel and station construction
work in close proximity, and the most likely and effective mitigation.”
Response
See response to Comment G-7.9 regarding geotechnical impacts. G-11.6
Comment
“As an abutter of the Winsor School and an institution that will be impacted by the
tunnel proposal that cuts through the Winsor campus, we strongly urge that
consideration of the alternative routes be given priority. Our hope is that while this will
impact many institutions and area neighborhoods, that this impact should be minimized
so that no one institution bares a significantly larger impact.”
Response
There are several tunnel alignment options in this area that will be evaluated in greater
detail. See NPC Attachment 6, Section 6.2.2 for further information on implementation
strategy for this and other major infrastructure elements.
G-11.7
Comment
“We would like to see a thorough evaluation of the impacts related to alternative tunnel
construction techniques and operational aspects of the future Phases 2 or 3 services
particularly with respect to vibration, electromagnetic field and moving metal.”
Response
Alternative tunnel construction techniques are evaluated in RDEIR Section 3.15.5.
Operational aspects of Phase 2 are provided in RDEIR Section 2.4. Noise and
vibration is summarized in Section 2.4.6 and detailed in Chapter 5. Electromagnetic
field and moving metal are summarized in Section 2.4.10 and detailed in Chapter 5..
Phase 3 compatibility is discussed in RDEIR Section 3.14.5. Construction and
operational impacts will be further evaluated during preliminary engineering and final
environmental.
G-11.8
Comment
“Preliminary engineering and the FEIR/FEIS should develop a more detailed phasing
and implementation plan that identifies potential early action items and schedules in a
manner that does not segment future tunnel costs from ridership benefits of the whole
project. Early action items in the LMA should include the advancement of commuter
rail platform improvements at nearby Ruggles Station, which represent a relatively
modest investment with significant transportation benefits to the Longwood, Fenway
and Roxbury communities.”
Response
See responses to Comments F-1.1, F-1.2 and G-1.7 regarding phasing and
implementation schedules with early action items.
Group G - Response to Institution Comments Page 116
RESPONSE TO COMMENTS ON RDEIR G-11.9
Comment
“Planning and engineering for the Urban Ring must move forward in consistent stages
so that the project can be ‘ready to go’, as the economy improves and as solutions are
found for Massachusetts’ transportation financing for roadways, the Turnpike and the
MBTA. While potential exists for some private funding opportunities a broader-based
financing plan should be constructed that recognizes the significant statewide and
metropolitan area benefits of the project, not just in the Urban Ring corridor. The plan
should take care not to place the Urban Ring in competition with municipal sources of
funding in a way that would undermine local support for the project. We also
recommend that the State explore new opportunities for regulatory flexibility regarding
Federal financing of transit projects with the changed administration in Washington.”
Response
See responses to Comments F-1.2 and G-7.22 for next steps and funding options. G-11.10
Comment
“We request that the Secretary’s scoping for preliminary engineering and the
FEIR/FEIS require that EOT proceed without delay to advance a short-term work
program to include some aspects of preliminary engineering, including additional
tunnel evaluations, using state bond funds earmarked for the Urban Ring in the 2008
Transportation Bond Bill. In this way, critical progress can be made in 2009 in advance
of entering into the New Starts process and monitored during 2009 through the
submission of biannual progress reports.”
Response
See response to Comments F-1.1 and F-1.2 for short-term work program and funding
options.
See response to Comment G-7.4 regarding the request for biannual progress reports.
G-11.11
Comment
“Additional engineering and design should be pursued, to capture existing momentum,
into the preliminary engineering and FEIR/FEIS phases.”
Response
Since the submission of the RDEIR/DEIS, EOT has advanced the BRT alignment and
configuration of the project. See responses for Comments F-1.2 and F-1.3 for project
phasing schedule summary and the schedule for resolving key remaining issues.
Group G - Response to Institution Comments Page 117
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: G-12
Received from: Winsor School
January 7, 2009
Comment No.
G-12.1
Comment
“The Winsor School (“Winsor”) is writing in support of the Urban Ring Corridor Phase 2
Project, but we urge that the route of the tunnel portion of the Ring not run under our
property and thereby destroy the operational functioning and educational development
of the school.
“…We urge the adoption of one of the two available tunnel routes which do not involve
a destructive taking of Winsor School’s private property…. The EOT has developed, as
one of three potential tunnel route choices, one option that would cut right through the
heart of the Winsor School Campus (the “Cut-Through-Winsor Route”)…. Winsor has
been asked to stand alone among all the institutions in the LMA – and, indeed, among
all the residents, businesses, and institutions affected by the Urban Ring project – as
the only party whose future is potentially devastated by the Urban Ring. Because EOT
has already developed two other tunnel route options that achieve the purposes of the
Urban Ring without extensive private property takings, and without destroying a local
non-profit institution in the heart of Boston, we respectfully request elimination of the
Cut-Through-Winsor Route from further consideration.
“…The Tight-Turn Option would keep the tunnel alignment essentially within Longwood
Avenue and Brookline Avenue, thereby reducing the impacts on Winsor School…. The
Wide-Turn Option avoids the costly takings by eminent domain through the heart of the
Winsor School campus that would be necessitated by the Cut-Through-Winsor Route.
The Wide-Turn Option would allow Winsor to continue to operate and flourish in the
location which has been its home for almost 100 years.
“We respectfully request EOT to give full consideration to stakeholder and community
feedback, and on that basis to eliminate the Cut-Through-Winsor Route from further
consideration in this process…
“We respectfully request that the Secretary of Energy and Environmental Affairs to
require further environmental analysis of the Cut-Through-Winsor Route to make even
more clear that the institutional damage it would cause makes it a vastly inferior option
to the other two proposed tunnel routes, neither one of which undermines the
institutional mission of an organization in the LMA.
“Only further analysis can provide a full and fair consideration of the impacts on
Winsor, which have been entirely ignored by the DEIR/DEIS.”
Response
See response to Comment E-2.10 regarding future environmental steps for the tunnel
portion of the LPA. EOT will further investigate all alignment options and coordinate
with Winsor School, the City of Boston, other abutters and other stakeholders at such
time as the Fenway/LMA tunnel element of the project can be advanced.
G-12.2
Comment
“Winsor’s Master Planning efforts were not addressed in the RDEIR/DEIS.
“…The types of construction projects currently in the planning process:
Additional Floor Area to be constructed (including parking):
Group G - Response to Institution Comments Page 118
RESPONSE TO COMMENTS ON RDEIR With existing gym building retained:
125,920 gsf
With existing gym building demolished: 146,030 gsf
“These new facilities are to be located in, around, and under the Winsor athletic fields
and directly conflict with the Cut-Through-Winsor Route. Those planning conflicts are
not identified, assessed, or even mentioned in the RDEIR/DEIS.”
Response
Winsor’s current Master Planning efforts will be reviewed and addressed in future
environmental documents for the project.
G-12.3
Comment
“Winsor has also anticipated continued cooperative working relationships with its
medical and scientific neighbors. Introduction of tunnel vibrations throughout Winsor’s
campus may eliminate many of those potential opportunities for the school. The market
value of the land is dependent on the utility of the land for its likely users, that is,
hospitals and scientific organizations.”
Response
Comment noted. G-12.4
Comment
“We urge the avoidance of cut-and-cover technology for the construction methodology.
A cut-and-cover means of construction for the Cut-Through-Winsor Route would shut
down the school during the long construction process. The RDEIR/DEIS makes no
effort to discuss the impacts of a cut-and-cover approach on Winsor or on its
neighboring institutions in the LMA. The staging area necessary for cut-and-cover
would make the school’s fields unusable for the duration of the construction of the
tunnel – potentially several years – and noise and environmental effects of the
constructions would undermine educational efforts on campus. The school simply
could not co-exist with this process, and therefore its very survival as an institution
would be threatened. We note further that the use of cut-and-cover technology at the
intersection of Brookline and Longwood Avenues would exacerbate traffic issues at
one of the city’s busiest meeting points and has the potential to disrupt the activities of
several of our neighboring medical institutions. Extensive and careful analysis of
implications of cut-and-cover technology is needed to make clear the potential impacts
on Winsor and our neighbors.
Response
The final tunnel construction methodology has not yet been determined, but the
RDEIR/DEIS states that the cut-and-cover method is not under consideration as the
principal tunnel construction method. Cut-and-cover construction is under
consideration only for discrete sections of tunnel, such as portals, stations, and
potentially turns and access shafts, depending upon the construction method chosen.
The principal types of tunnel construction under consideration for major length of the
tunnel are tunnel boring machine and sequential excavation method. Additional
information will be provided in future environmental review documents for this project
as the tunnel alignment and construction method are developed. EOT will coordinate
with the City, Winsor School, and other abutters and stakeholders during preliminary
engineering and final environmental review.
Group G - Response to Institution Comments Page 119
RESPONSE TO COMMENTS ON RDEIR G-12.5
Comment
“The RDEIR/DEIS repeatedly states that “There would be no residential takings or
business relocations associated with the Project.” ES-25; 2-65; 7-16. But takings are
required through the heart of the Winsor campus for the Cut-Through-Winsor Route.”
Response
Tunnel alignment options in this area of the corridor will be addressed in preliminary
engineering and final environmental. See Attachment 6, Section 6.2.2 of the NPC for
further information.
G-12.6
Comment
“The RDEIR/DEIS states that there will be “No significant permanent adverse impacts
to parks and open space are anticipated from this project element…” 2-32. But the
impact of the Cut-Through-Winsor Route to the Winsor athletic fields would be
devastating. While impacts to the athletic fields of Wentworth Institute are mentioned,
2-33, impacts to Winsor’s athletic fields are nowhere mentioned. Id. Even though the
Winsor campus contains buildings that are eligible for listing as historic structures, the
section on historic impacts fails to list impacts to the Winsor campus. See, e.g., 2-76
and Table 2-22; 5-8-no indication of economic impacts to Winsor; 5-27 (Table 5-12­
Summary of Visual Resources – omitting any reference to Winsor); 5-65-Construction
Noise and Vibration Impacts – omitting any reference to Winsor); Table 5-42 at 5-127
listing Winsor’s 3.5 acre fields as protected open space, but then omitting any
discussion of that protected open space in the text; Figure 5-39 at 5-135 failing to
depict the Winsor fields as non-profit open space; 7-16 – omitting any discussion of
visual or aesthetic impact to Winsor School; 7-19 – omitting any listing of historic or
archaeological impact to Winsor School; 7-20 – no listing of parks or open space
impact to Winsor. The RDEIR/DEIS notes that 2.98 acres of land will be taken within
the city of Boston from the Commonwealth of Massachusetts, the City of Boston, and
Boston University. Table 5-6 at 5-13. The prospect of a taking against Winsor is not
even mentioned. The RDEIR/DEIS says that EOT took into consideration the master
planning of the LMA institutions, including Winsor, but then lists at Table 4-2 the plans
with which it is compatible – omitting any reference to Winsor. 4-5 and 4-6.
“In fact, in the whole of the RDEIR/DEIS, the only acknowledgement of some possible
negative impact to Winsor School, and its historic, archeological, cultural, economic,
and open space value to the community, takes place in Table 5-45 at 4-146, which
indicates that in connection with Alternative 3, 3A, and 3C, “Construction of tunnels
may have temporary impacts to Winsor School athletic fields.”
“These statements are hopefully true with respect to the Tight-Turn Option and the
Wide-Turn Option, but fall far short of the mark in describing the permanent and
temporary impacts to Winsor School that would result from the Cut-Through-Winsor
Route. The RDEIR/DEIS should have done more to describe these impacts.”
Response
Tunnel boring machine or sequential excavation method tunnel construction would
result in minimal or no surface disruption to Winsor School athletic fields. Future
environmental review documents for the Fenway/LMA tunnel major infrastructure
element of the project will be informed by preliminary engineering and include further
detail on the temporary and permanent impacts associated with alignment options.
G-12.7
Comment
“The RDEIR/DEIS simply assumes that a cut and cover method of construction will not
used. ES-33 (“It is assumed that the running tunnels would be constructed by methods
such as TBM or SEM that do not require surface cut and cover.”) However, the
Group G - Response to Institution Comments Page 120
RESPONSE TO COMMENTS ON RDEIR RDEIR/DEIS also acknowledges that the cut and cover construction method may be
required. See, e.g. 2-29 (“There are a number of different tunneling techniques that
can be used to construct the running tunnels. The primary ones under consideration
are: cut and cover; sequential excavation method (SEM) mined tunnel; and tunnel
boring machine (TBM) bored tunnel. …the initial assumption is that the running tunnels
would be constructed using a TBM in a single bore configuration.”) (emphasis added).
And there is no apparent basis for making that assumption aside from the fact that the
cut and cover method will have greater environmental impacts. See, e.g., 2-31 (“The
complexity of the tunnel engineering and uncertainty surrounding geotechnical
conditions in the LMA mean that final alignment and tunneling method (i.e. tunnel
boring machine versus sequential excavation method) will need to be evaluated in the
preliminary engineering and final environmental phases. However, the tunnel boring
machine method appears at this time to generate fewer impacts to the surrounding
area.”).
“By simply assuming that the cut and cover method of construction will not be selected, the RDEIR/DEIS avoids any consideration of the serious environmental impacts associated with that method, including the destruction of the Winsor campus.” Response
See response to comment G-12.4 regarding tunnel construction methodology. Group G - Response to Institution Comments
Page 121
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: H-1
Received from: Representative Frank I. Smizik
February 9, 2009
Comment No.
H-1.1 Comment
“Although a well intentioned proposal, the benefits of the planned Urban Ring fail to
outweigh its costs for neighborhoods in and abutting my district… because of the traffic
patterns, lack of existing transportation infrastructure, and sheer physical reality of BU
Bridge-Carlton St. Bridge-Mountfort St.-Miner St. portion of the corridor, the proposed
route strikes me as an attempt to squeeze additional traffic through neighborhoods that
simply can’t handle any more.
“Just looking at my section of the proposed corridor between the BU Bridge and the
Fenway, I fail to see how the plan will decrease commuting time. And without a
significant decrease in commuting time, I do not expect that we will see a sufficiently
large population of new riders emerge, meaning that the Urban Ring will not reduce
automobile traffic at all and, at least in this section of the project, only serve to increase
the number of buses idling in even heavier traffic.”
Response
The Urban Ring is an integrated system of transit improvements that meets the need to
provide better circumferential transit service in areas of Boston and the surrounding
municipalities. The project reduces congestion on heavily used MBTA rapid transit
lines; reduces regional vehicle miles traveled and air pollution; and improves travel
times and convenience for commuters and travelers throughout the region. (See
RDEIR Certificate dated March 6, 2009 for a summary of project benefits.)
Note that the recommended Urban Ring alignment does not use the BU Bridge, but
rather the Grand Junction Railroad bridge, which would be modified to handle bus-only
traffic to cross the Charles River, bypassing this major congestion point with buslanes
or busways on its approaches.
H-1.2 Comment
“As such, I believe that the Urban Ring’s environmental consequences, in terms of
both greenhouse gas and particulate emissions, will likely be negative in the densely
populated neighborhoods where Brookline borders Boston near Fenway.”
Response
Due to the significant anticipated reduction in VMT and introduction of low-emission
vehicles, air quality benefits would result from the recommended Urban Ring referred
to as the Locally Preferred Alternative (LPA). The LPA would improve air quality at the
intersections and at the municipal and regional levels compared to the No-Build
alternative, largely due to the project’s ability to divert automobile trips to public
transportation.
H-1.3 Comment
“I think there is no reason not to move forward with bus rapid transit into and out of
underserved portions of Roxbury (especially with regards to connecting those
communities to job opportunities in the Longwood Medical Area). A Dudley-Longwood
connection makes a great deal sense to me, as do other connections (such as those in
Dorchester, Chelsea, and Everett that less directly affect my constituency but could
make an important difference in people’s lives nonetheless). However, I see no EJ
Group I - Response to Individual Comments
Page 122
RESPONSE TO COMMENTS ON RDEIR reason that could justify the undue burden that will be placed on Brookline and Boston
neighborhoods by the Cambridge to Yawkey portion of the corridor, as discussed
above.”
Response
See response to Comment H-1.1 regarding the overall benefits of the Urban Ring
project. Refer to the NPC Attachment 6 (Section 6.2) regarding the implementation
strategy for early actions and major infrastructure elements.
H-1.4 Comment
“If EOT believes that a connection to the Longwood Medical Area from north of the
river is critical, I suggest that a bus rapid transit route head down Massachusetts
Avenue from Cambridge, cross the Charles River over the Mass. Ave. Bridge, and
connect to the LMA from the east. The transportation infrastructure there is more
capable of handling expanded bus traffic, and thus such a route would be less likely to
pose an undue burden on nearby communities. Furthermore, such as route would
actually be more likely to achieve EOT’s commuting time goals and thus generate the
ridership numbers required to make this project sustainable. And, finally it would be
much cheaper, since such a route would not require the construction of a LMA tunnel,
since buses could flow right down Huntington Avenue. In addition, this route would
spare the Winsor School.”
Response
Use of the Massachusetts Avenue bridge surface routing was evaluated in the RDEIR
as Alternative 2A in Chapter 3, page 3-54 and in the summary evaluation Table 3-8.
Ridership was projected to be similar to other surface routing alternatives, which are
lower than those generated by recommended tunnel alternative. Moreover, the
Alternative 2A routing would bypass important Urban Ring markets and lengthen the
travel time for other markets north, south and west of the BU Bridge.
Group I - Response to Individual Comments
Page 123
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
H-2.1 H-2
Senator Anthony D. Galluccio
December 15, 2008
Comment
“I look forward to continued discussions of the Urban Ring, its route, and how
adjustments can be made to mitigate adverse impacts. There must continue to be
coordination with communities within the proposed Urban Ring corridor to minimize
disruptions and increase ridership. The new proposed connection to Allston, for
example, requires vigorous planning in partnership with the community.”
Response
EOT will continue to work with local agencies, the community, abutters, and other
stakeholders during preliminary engineering and further environmental analysis of the
project.
H-2.2 Comment
“We must be cognizant of the dire fiscal challenges facing our transportation system.
The financial downturn and enormous debt taken on by the MBTA and the Turnpike
Authority have forced a re-examination of the entire system. All proposed transit
projects, including the transportation improvements in the Urban Ring corridor, must
take advantage of cost saving measures and outside funding sources.”
Response
See response to Comment F-1.2 for potential funding options. Group I - Response to Individual Comments
Page 124
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: H-3
Received from: Senator Anthony Petruccelli
February 9, 2009
Comment No.
H-3.1 Comment
“The Urban Ring will also support the planning and economic development initiatives
of the communities through which it passes. Support for the institutions and industries
in the Urban Ring should be an important part of any economic and job creation
strategy for the state, and providing improved transportation is a critical need in
spurring economic and job creation strategies.
“We have appreciated the inclusion of community involvement as part of the process,
and expect that this consideration will continue to be emphasized. I urge you to
continue into the Preliminary Engineering phase and then complete the Final EIR so
that we can move ahead with all the components of the project.”
Response
Comment noted. EOT will continue to work with local agencies, the community, abutters, and other
stakeholders during Preliminary Engineering and final environmental analysis of the
project.
See response to Comment F-1.3 for a project schedule for key remaining issues.
Group I - Response to Individual Comments
Page 125
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
I-1.1 I-1
Alan Moore
February 10, 2009
Comment
“The service to Somerville has already been ‘cut back’ from earlier Urban Ring
versions to only the interconnection with the Green Line extension at Lechmere,
access through Inner belt, and the service to Assembly Square. These are critical
connections for the Urban Ring to be useful for Somerville residents and those coming
to all future jobs and residences in these areas. Please do not reduce these
connections any further. The service is needed to reduce additional traffic that will be
attracted to future development in the area.”
Response
Comment noted. I-1.2 Comment
“I understand why Harvard University would want to connect both the new Allston
campus and Harvard Square to the Urban Ring but this seems to have resulted in less
optimal transportation options for people living in the northeastern communities. The
current Urban Ring plans do not provide one seat travel from the northeastern
communities to South Boston and downtown. I thought this was the whole purpose of
the Urban Ring. I hope that MEPA takes these environmental justice concerns very
seriously in its analysis of this environmental review. Please restore these through
connections.”
Response
See response to Comment D-2.13 regarding project origins-destinations in the study
area.
I-1.3 Comment
“I commend the plan for discussing the connections to the various existing bicycle
pedestrian facilities along the route. However, this should go further by building new
connections, specifically.”
Response
Connections between the Urban Ring LPA and planned new bicycle and pedestrian
facilities are discussed in the RDEIR including the Grand Junction Rail Trail in
Cambridge and the South Harbor Trail in Boston.
I-1.4 Comment
“I don’t know exactly how but somehow (more priority signals, more dedicated bus
lanes, pre-boarding ticket ‘checking’, etc.) the design needs to increase the average
speed. The time savings over the present travel routings are often not significant in my
opinion.”
Response
See response to Comment F-3.2 regarding BRT bus improvements to increase travel
speeds in the corridor.
Group I - Response to Individual Comments
Page 126
RESPONSE TO COMMENTS ON RDEIR I-1.5 Comment
“There already is a satisfactory intermodal (commuter train – subway) connection at
Malden center. Having another at Sullivan Square will seriously increase the air
pollution in this neighborhood that is already burdened with air pollution from I-93 and
the Boston Engine Terminal. Perhaps this can be done in the future when the MBTA
electrifies the commuter rail system but not now.”
Response
The Sullivan Square intermodal commuter rail station will serve both the Haverhill Line
and the Newburyport/Rockport Line which converge at Sullivan Square. It will connect
these commuter rail lines with the Orange Line and 12 MBTA bus routes, as well as
the proposed new Urban Ring service. Malden will continue be an intermodal center
for the markets it serves. Impacts of the Sullivan Square intermodal station will be
further reviewed during preliminary engineering and final environmental for the
proposed Northern Tier of the Urban Ring, as summarized in the NPC Attachment 6
(Section 6.2.1).
Group I - Response to Individual Comments
Page 127
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-2
Received from: Arshag A. Mazmanian
February 3, 2009
Comment No.
I-2.1 Comment
“I suggest, urge, the need for viewing the Commonwealth Avenue/BU Bridge area with
several extensive field trips, on the ground, both the Cambridge and Boston sides, the
BU Bridge, the Grand Junction Rail Line (GJRL) under the BU Bridge, Commonwealth
Avenue, the rail lines westerly of the BU Bridge on the Boston side of the Charles
River, the MA Turnpike Extension air rights parcels in Boston and Brookline in the area
that may eventually be developed, the feeder roads in Brookline including Essex
Street, Mountfort Street, Carlton Street, the Carlton street bridge over the Extension,
Dummer Street, Worthington Road, etc. The review of maps and drawings is not
sufficient to fully understand and appreciate the traffic and transportation issues
involved with the Commonwealth Avenue/BU Bridge area. I urge you to make several
field trips that might include even a trip on the Charles River to pass under the BU
Bridge and the GJRL.”
Response
EOT and its consultants have made many field/reconnaissance visits to the Charles
River/Commonwealth Avenue/BU Bridge area. Photographs, measurements, field
notes, and observations have been recorded. Additional visits to this area will be made
as necessary as the project advances.
I-2.2 Comment
“The Urban Ring concept for Phase 2 involves utilizing 60 foot articulated BRT buses
in mixed traffic along significant portions of the Phase 2 routes. Many comments have
been made, including by me, that the travel times for these BRT buses even with
limited stops may not be attractive to potential riders because of delays caused by
operating in mixed traffic, with the result that such riders may take a radial line into the
hub and then out on another radial line to destinations. Some members of the public,
including me, have suggested skipping Phase 2 and proceeding directly to Phase 3’s
light/heavy rail with fully dedicated routes, surface and/or tunnel.”
Response
Over 50% of the recommended project defined in the RDEIR is in some type of
dedicated right-of-way to bypass traffic congestion. Additionally, because the Urban
Ring provides more direct routing and includes bus signal priority, travel times are
improved for most origin-destination pairs, even for those sections that would operate
in mixed traffic. See response to Comment F-3.2 regarding BRT bus improvements for
portions of the alignment operating in mixed traffic.
See response to Comment F-2.1 regarding proceeding directly with Urban Ring Phase
3.
I-2.3 Comment
“So Harvard became openly a stakeholder in Phase 2. Harvard’s accumulation of
hundreds of acres of land/buildings took place over a number of years, obviously in
secret, perhaps even to the Commonwealth and EOT. The pubic became aware of
Harvard’s acquisitions from local newspapers. But surely Harvard had plans along the
way of such accumulations to seek joinder to Phase 2 long before such public
disclosure…It’s not too late for greater transparency.”
Group I - Response to Individual Comments
Page 128
RESPONSE TO COMMENTS ON RDEIR Response
EOT has and will continue to manage the project with full public disclosure and
transparency.
I-2.4 Comment
“The surface routes between the University Road portal and the portal on Beacon
Street would not provide exclusively dedicated rights of way for Phase 2’s 60 foot
articulated BRT buses; some portions would include busways (which have dedicated
rights of way) and bus lanes (which can physically accommodate mixed traffic if
adequate monitoring and enforcement are provided). These factors require a serious
review of already serious traffic and transportation issues in the Commonwealth
Avenue/BU Bridge area that this route passes through. Consider this winter’s recent
snowstorms and other weather conditions that these 60 foot articulated BRT buses
would face over these surface routes.”
Response
Conceptual engineering and traffic analysis show that providing bus lanes on
roadways in this area is feasible within existing right-of-way. No busways are proposed
as part of the LPA in this area. It is noted that MBTA bus routes #47 and CT2 currently
travel on some of these roadways between Commonwealth Avenue and Beacon Street
in mixed traffic. EOT will continue to evaluate alignments and operations and
coordinate with the Town of Brookline and City of Boston on this matter. Issues such
as potential removal of on-street parking and enforcement are critical items that will be
further evaluated as the project advances.
I-2.5 Comment
“What commuting limitations would result regarding the use of University Road as a
Storrow Drive east exit/entrance? What if any quid pro quo might be involved with BU
and the use of its property on the easterly side of the BU Bridge?”
Response
The LPA recommended in the RDEIR does not change the current use of University
Road for general traffic and exit/entrance for Storrow Drive east.
I-2.6 Comment
“What commuting limitations would result regarding the Carlton Street bridge being
part of the route, partially dedicated for these 60 foot articulated BRT buses,
concerning access to Commonwealth Avenue east and west, University Road and the
BU Bridge? What will be the commuter options for vehicles heading east on
Commonwealth Avenue approaching the Essex Street/BU Bridge intersection for
accessing the BU Bridge or University Road?”
Response
Planned changes in the RDEIR for general traffic in this area are for traffic that
currently travels westbound on Mountfort Street destined for the BU Bridge
northbound. These vehicles would be allowed to continue on Mountfort Street across
the intersection with Carlton Street. The westbound section of Mountfort Street west of
Carlton Street would be widened from one lane to two lanes on the outside (towards
MassPike). Commonwealth Avenue eastbound traffic would continue to use the
existing pattern to access either the BU Bridge or University Road. Mountfort Street
traffic destined for Commonwealth Avenue or University Road would continue to use
Carlton Street.
Group I - Response to Individual Comments
Page 129
RESPONSE TO COMMENTS ON RDEIR I-2.7 Comment
“What commuting limitations would be placed on the heavy flow of traffic on Park Drive
at its junction with Mountfort Street in accessing the Carlton Street Bridge, the BU
Bridge, Commonwealth Avenue east and west, and University Road? How might
commuter traffic on Essex, Carlton and St. Mary’s Streets be impacted for access to
the Carlton Street bridge, Commonwealth Avenue east and west, University Road and
the BU Bridge?”
Response
See response to Comment I-2.6 above. I-2.8 Comment
“How might commuter traffic from Cambridge over the BU Bridge be impacted for
access to Essex and Mountfort Streets and the Carlton Street bridge for access to
Commonwealth Avenue east?”
Response
See response to Comment I-2.6 above. I-2.9 Comment
“How might commuter traffic be impacted if the connection to Harvard’s proposed
Allston campus is by means of Commonwealth Avenue rather than along the southerly
side of the Charles River from the augmented GJRL under the BU Bridge? If such a
connection is by means of Commonwealth Avenue, then would the route of the 60 foot
articulated BRT buses be at University Road such that the buses from Cambridge to
Harvard’s proposed Allston campus would exit onto University road southerly and then
proceed westerly on Commonwealth Avenue past the BU Bridge to one of the Allston
routes? For the return trip from Harvard’s proposed Allston campus to Cambridge,
would the 60 foot articulated BRT buses proceed easterly on Commonwealth Avenue
and then south onto Essex Street and then east on Mountfort Street to the Carlton
Street bridge and then northerly crossing Commonwealth Avenue to University Road,
and then westerly on BU property to the tunnel portal and then on the GJRL under the
BU Bridge?”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended routing of
the Allston connection from the vicinity of the BU Bridge.
I-2.10 Comment
“The RDEIR/DEIS sets forth various alternatives for access to and from Harvard’s
proposed campus and the original “Ring” portion of Phase 2. There is no indication
when the EOT will decide upon the Locally Preferred Alternative for this branch line for
Phase 2. Nor does the RDEIR/REIS clearly provide for or describe connections
between Harvard’s proposed Allston campus and the LMA/Fenway.”
Response
Refer to the NPC Attachment 6 (Section 6.1) regarding the recommended routing of
the Allston connection from the vicinity of the BU Bridge.
The BRT 6 will provide a direct connection between North Allston and the
LMA/Fenway.
Group I - Response to Individual Comments
Page 130
RESPONSE TO COMMENTS ON RDEIR I-2.11 Comment
“How does Cockamamie Scheme #5 address connections of Phase 2 routes with the
radial lines, one of the major goals of Phase 2? I shall focus only upon the Green
Line’s B, C, and D branches:
1. B Branch (Commonwealth). Reference is made to a BU Station in the area of
BU property at the corner of Commonwealth Avenue and University Road.
(There is some confusion in the RDEIR/DEIS regarding the exact location of
BU Station.) Connections between Phase 2’s BU Station and the B Branch BU
Central stop on Commonwealth Avenue and St. Mary’s Street, require a
surface walk of approximately 1,000 feet.
2. C Branch (Beacon). The LMA/Fenway tunnel would have a stop adjacent to
the D branch (Riverside) Fenway Station at Park drive. Connections between
this stop and the C Branch St. Mary’s Station at St. Mary’s Street in Brookline
would involve approximately 1,500 feet surface walk as well as dealing with
stairs/elevators/escalators for the LMA/Fenway tunnel and Fenway Station.
3. D Branch (Riverside). The connections between the Phase 2 LMA/Fenway
tunnel stop in the preceding paragraph (2) and the D Branch Fenway Station
would be relatively short with less exposure to the elements than in the
preceding paragraphs (1 and 2).”
Response
1. This is a challenging area to provide a BRT surface station. Because of these
challenges and constraints two separate station locations are proposed for the
northbound and southbound directions in this area. The northbound station
would be located on Mountfort Street east of Carlton and the southbound
station would be located on University Road north of Commonwealth Avenue
(see Conceptual Plan and Profile Sheets 26 and 26A. These stations are
located approximately midway between the Green Line B Branch stops at BU
Central and BU West. The proposed BRT station locations are similar
distances from the Green Line as the current CT2 and #47 bus stops.
2. Comment noted.
3. Comment noted.
I-2.12 Comment
“Compare this to a Charles River crossing by means of a tunnel easterly of the BU
Bridge that would connect with Kenmore Station and provide convenient connections
to the B, C and D Branches without exposing passengers to the elements. This was
once proposed for Phase 3 with light/heavy rail with completely dedicated rights of
way…. Yet the EOT has continued with the Charles River crossing at the BU Bridge
with surface routes that include substantial mixed traffic in the Commonwealth
Avenue/BU Bridge area that is already plagued with serious traffic and transportation
issues.”
Response
A Charles River tunnel crossing to Kenmore Square is an alternative for Phase 3 that
was identified in the Major Investment Study in 2001, and is not part of the Urban Ring
Phase 2.
Note that the RDEIR recommended LPA alignment crosses the Charles River on a
modified Grand Junction railroad bridge, not the BU Bridge.
Group I - Response to Individual Comments
Page 131
RESPONSE TO COMMENTS ON RDEIR I-2.13 Comment
[The] “proposed augmentation [of the GJRL Bridge] with two travel lanes to
accommodate Phase 2’s 60 foot articulated BRT buses may present serious
environmental issues to be considered in the RDEIR/DEIS review…. While the GJRL
bridge currently limits the passage of tall boats, surely the augmented two BRT lanes
would create more limited navigational issues for the smaller boats that currently pass
under it…. Surely there would be some negative environmental impacts upon the
Charles River…. In the RDEIR/DEIS, EOT virtually assumes that no serious
environmental issues are presented with the Charles River crossing.”
Response
No significant impacts have been identified for the LPA with water navigational issues
for the Charles River beneath the modified Grand Junction Railroad Bridge.
Conceptual engineering indicates the vertical clearance beneath the bridge above top
of water can be maintained. Existing piers would be extended lengthwise but not
reduce the horizontal clearance between piers. The concerns raised in the comment
will be further evaluated during preliminary engineering and final environmental.
I-2.14 Comment
“Between the portal near University Road and the portal on Beacon Street, there are a
number of traffic chokepoints on the surface routes at just about every intersection:
University Road with Commonwealth Avenue; Commonwealth Avenue with the Carlton
Street bridge; the Carlton Street bridge with Mountfort Street; Mountfort Street with
Park Drive; and Mountfort Street with Beacon Street. Certain portions have busways,
which are dedicated rights of way; but a busway that replaces a vehicular commuter
lane worsens auto commuting. Certain portions have buslanes, which can include
mixed traffic if restrictions are not properly monitored and enforced. The enumerated
intersections handle significant commuter traffic that presently contributes to serious
traffic and transportation issues in the Commonwealth Avenue/BU Bridge area. The
addition of 60 foot articulated buses, even with the ability to override traffic signals, will
only make for more difficult auto commuting in this area. These chokepoints may
thwart the BRT system goal of a BRT system goal of a BRT bus every 6 or 7 minutes,
or more frequently, in each direction.”
Response
See response to Comment I-2.4. Only bus lanes are proposed in this area, no buways
are proposed. The addition of bus lanes would not reduce the number of travel lanes
for general traffic. However, the elimination of on-street parking in some areas needs
to be considered. The proposed circulation changes to allow westbound Mountfort
Street traffic to proceed past Carlton Street will improve both traffic operations and
safety in this area by reducing the number of vehicles in the section of westbound
Commonwealth Avenue between University Road and the BU Bridge. Enforcement of
bus lanes is a critical operations issue that will require continued planning and
coordination with the MBTA and the traffic departments of muncipalitiesmunicipalities
along the corridor.
I-2.15 Comment
“The Federal Transit Agency requires a minimum of 50% of dedicated rights of way….
Overall, EOT claims in its RDEIR/DEIS that 53% of the Phase 2 routes has dedicated
rights of way. But this is misleading because EOT has included buslanes as dedicated
rights of way; as is obvious from the Silver Line experience on Washington Street,
buslanes cannot be dedicated rights of way without extensive monitoring and legal
enforcement as mixed traffic can be readily accommodated. Without sufficient
Group I - Response to Individual Comments
Page 132
RESPONSE TO COMMENTS ON RDEIR dedicated rights of way, trip times will be much longer, with the result that Bus Rapid
Transit is not rapid and as transit these BRT buses are no better than cross-town
buses.”
Response
Bus lanes are identified as exclusive running way for buses, and FTA recognizes them
as such. Enforcement of bus lanes is an important element for successful operation of
the system. Several other US cities have implemented bus lanes along with an
extensive enforcement program and related policies. The EOT will work with BRT, BTD
and other municipalities to develop enforcement policies and implementation plans.
I-2.16 Comment
“The Boston Redevelopment Authority recently approved the One Kenmore project
that would include a revitalized Yawkey Station for MBTA commuter rail nearby the
Beacon Street portal referenced earlier. The City of Boston is considering a master
plan for Columbia Point, which could be accommodated by the branch of Phase 2 from
the original “Ring” to UMass Boston. Then we have potential development in the
Seaport in South Boston. In addition, the already densely developed LMA/Fenway
area has more development projects in the pipeline…. But the question raised is
whether the RDEIR/DEIS for Phase 2 addresses such potential development
adequately? Is it possible that Phase 2 with its 60 foot articulated BRT buses running
on heavily traveled surface routes with insufficient dedicated rights of way would be
inadequate to service such developments as compared with light/heavy rail? If so, then
phase 2 just might be a waste of both time and money.”
Response
The anticipated employment and population growth in the region and study corridor
was considered in the analysis of project needs and impacts. See response to
Comment F-2.1 regarding proceeding directly to Phase 3 (rail).
I-2.17 Comment
“The state’s ability to fund Phase 2 beyond such limited potential federal funding is
questionable. The financing portion of the EOT’s RDEIR/DEIS demonstrates a
complete lack of confidence in the ability to finance Phase 2 that makes it hard to
imagine it will pass muster with the Federal Transit Authority. EOT states emphatically
that the state cannot commit to funding and cannot identify definitive sources of
funding beyond any federal funding.”
Response
See response to Comment F-1.2 regarding viable options for project funding. Group I - Response to Individual Comments
Page 133
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-3
Received from: Arshag A. Mazmanian
February 5, 2009
Comment No.
I-3.1 Comment
“At pages 18 and 19 (February 3, 2009 letter), I commented upon Phase 2’s
connections with the Green Line’s B, C and D branches. With respect to the B Branch
(Commonwealth), yesterday I paced the distance from the BU Central stop to
University Road at approximately 1,000 feet, substantially longer than “a couple of
hundred feet” I referred to. With respect to the C Branch (Beacon), the distance is
longer, perhaps as much as 1,500 feet between the C Branch St. Mary’s Street station
and the Phase 2 tunnel station, substantially longer than “a several hundred feet
surface walk” I referred to.
“Kindly consider this update with my February 3rd comment letter.”
Response
This comment has been updated in Comment I-2.11 of February 3rd comment letter. See responses to Comment I-2.11. Group I - Response to Individual Comments
Page 134
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-4
Received from: Arshag A. Mazmanian
February 10, 2009
Comment No.
I-4.1 Comment
“Since my focus has been upon Phase 2’s Charles River crossing and the impact of
Phase 2 upon the Commonwealth Avenue/BU Bridge area, I feel obliged to bring to
your attention the Boston Globe Metro Section, page 1, article today [Feb.10 2009]
“BU Bridge plans could spur road rage” by Stephanie Ebbert. The impact of the
proposed narrowing of auto travel lanes by adding bike lanes over the BU Bridge
would exacerbate current traffic and transportation issues in this area and might
prevent the temporary utilization of the BU Bridge for Phase 2 pending obtaining
necessary approvals from CSX with respect to the GJRL under the BU Bridge
proposed to be augmented as part of Phase 2 for the Charles River crossing. Even
absent such temporary use of the BU Bridge or Phase 2, the changes proposed in the
Boston Globe article should further impact and exacerbate the serious traffic and
transportation issues with the GJRL augmentation as part of Phase 2 in the
Commonwealth Avenue/BU Bridge area.”
Response
The narrowing of general traffic lanes on the BU Bridge to which you refer are not
proposed as part of the Urban Ring project. That said, typically the narrowing of traffic
lane widths result in slower travel speeds which tend to improve safety. The
bottlenecks in this area are the intersections on each end of the BU Bridge in Boston
and Cambridge and not the bridge itself. Refer to response to Comment 1-2.12
regarding the proposed Urban Ring route in this area.
Group I - Response to Individual Comments
Page 135
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-5
Received from: Christiana Fischer
February 9, 2009
Comment No.
I-5.1 Comment
“In reference to EOE No. 12565, I would like to express my displeasure with the
proposal for the Urban Ring. While I think public transportation enhancements are
necessary for existing infrastructure, I do not feel that the addition of a bus line will
alleviate any congestion, nor will it connect current existing transit in an effective way.
“As a loyal T and MBTA bus rider (I do not own a car), I can say that this proposal does not draw a clear line fixing any of the current frustrations with the system. Quite frankly, the buses that currently run aren’t even very efficient (especially during high traffic times). Why invest in adding something to an already flawed system? Perhaps we could look into improvements on the highly trafficked E-Line? Like putting rail underground?
“Also, the proposed addition of the Urban Ring bus line would only further congest an all too congested Longwood Area and highly traveled stretch of Huntington Avenue.” Response
See response to Comment H-1.1 regarding overall project benefits. The MBTA is responsible for maintenance and operations of MBTA buses and routes.
EOT will continue to work with the MBTA to develop optimal Urban Ring routes and
schedules as the project advances.
Analysis included in the RDEIR has shown in many cases the Urban Ring would
improve operations for general traffic by 1) separating buses from general traffic; 2)
reducing the number automobiles on roadways; and 3) implementing geometric and
signal control improvements at intersections.
Group I - Response to Individual Comments
Page 136
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-6
Received from: Craig A. Kelley
February 9, 2009
Comment No.
I-6.1 Comment
“For vast amounts of scarce mass transit money, the URII will simply create sections of
new or improved roadways for rubber-wheeled vehicles that will periodically break free
from regular street traffic and at other times will mix the URII vehicles in with general
traffic. As with the Silver Line, the part that is on a dedicated track will be expensive to
build and to operate, but will not get stuck in traffic. The rest of the line, however, will
get stuck in traffic and that leads one to the inescapable conclusion that the URII will
be a lot of money spent on a very limited improvement in mass transit as people do not
like to ride traffic-bound buses if they can avoid them.”
Response
See response to F-3.2 regarding improvements to increase bus travel speeds in mixed
traffic.
I-6.2 Comment
“It is also likely that the areas set aside for the rubber-wheeled URII vehicles will be
made available for other types of rubber-wheeled vehicles, from taxis to shuttle buses
or trucks, making the URII expenditures more of a general roads and area
development project than a project focused on mass transit. Given that much of the
project will go through Cambridge neighborhoods,… increasing the volume of cars and
trucks following the URII as a shortcut would be detrimental to many of the residents….
Further, there is a concern that, while the URII will shunt a problematic number of
vehicles, large and small, through or adjacent to Cambridge’s dense residential
neighborhoods, those neighborhoods themselves will see little benefit as it is not clear
that the URII will actually have stops that readily support the local residents.”
Response
In addition to Urban Ring buses using the planned busways and bus lanes,
consideration has been given to allowing other MBTA buses, shuttle buses, and
emergency vehicles in these facilities. However, it is not always possible to have local
buses use these facilities as they have more closely-spaced stops than the Urban Ring
service. At this point trucks have not been considered for use in the busways and bus
lanes, except as part of the East Boston Haul Road facility. EOT will continue to
coordinate with agencies and municipalities as to the use of busways and bus lanes by
other transit and emergency vehicles.
EOT has spent considerable time and effort to meet, plan, and coordinate with City of
Cambridge, Cambridge neighborhood groups, and other stakeholders regarding the
Urban Ring alignment, operations, and station locations. The City and stakeholders are
supportive of the Urban Ring LPA. EOT recognizes that several engineering details
need to be resolved as the project advances.
A total of seven Urban Ring stations are planned for Cambridge as shown in the tables
and figures in RDEIR Chapter 2 .
I-6.3 Comment
“There are a many good public transit projects that could and should happen in the
greater Boston area, the primary one being to link North and South Stations. Other
Group I - Response to Individual Comments
Page 137
RESPONSE TO COMMENTS ON RDEIR worthy projects include the Red line/Blue Line connector, extending the Green Line
and simply installing raised platforms at Purple Line stations for safer and faster
boarding and exiting of the trains. Funds could even be spent to preserve the right of
way for the future rail-based URII, should that project ever come to fruition. But at this
point, plans for the URII should be discarded and the mass transit money spent on
more worthy projects.”
Response
Analysis has demonstrated, as documented in the RDEIR/DEIS, that the Urban Ring
project will produce some of the highest transit benefits in the region in terms of
ridership, connectivity, travel time savings, and supporting smart growth, transitoriented development, and environmental justice.
Group I - Response to Individual Comments
Page 138
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-7
Received from: Ellen Reisner, PhD
February 9, 2009
Comment No.
I-7.1 Comment
“The goal of creating a circumferential transit system is to provide convenient public
transportation across the metro Boston area that would provide access from the
environmental justice communities such as Chelsea, Everett, Revere, and Roxbury to
institutions, schools and jobs. I have attended many of the community advisory
meetings over the past few years and have observed a shift of emphasis on
addressing these environmental justice community needs to meeting goals of Harvard
University to include the new Allston campus in the Urban Ring and link it to its
Cambridge campus and the Longwood medical area. I am not opposed to serving
these needs, but I do believe that this focus has resulted in less optimal transportation
options for people living in the communities mentioned above. At the same time,
recommendations have been made to site the BRT maintenance facility in Medford, a
community that is barely served by the Urban Ring. I hope that MEPA takes these
environmental justice concerns very seriously in its analysis of this environmental
review.”
Response
Environmental justice remains one of the many beneficial impacts of the project. As
noted in the RDEIR: “The LPA would not have disproportionately high and adverse
effects on the minority or low-income populations in the corridor or the seven-city
region. The LPA also would provide benefits to residents including the minority and
low-income populations living near proposed stations.” The addition of the North
Allston area to the Urban Ring alignment does not reduce planned service to
environmental justice neighborhoods. Urban Ring vehicle maintenance facility needs
are being coordinated with the MBTA system-wide bus maintenance facility planning
process.
I-7.2 Comment
“The current configuration of BRT for the Urban Ring does not provide convenient one
seat travel from the northeastern communities to South Boston and downtown. The
emphasis on South Boston service is for people heading to the airport, but it provides
terrible service for people from communities such as east Boston, Revere, Chelsea,
and Everett who are likely to be traveling to South Boston to work in the hotels,
restaurants, etc. Providing convenient public transportation to workers is critical
because travel by car is not a realistic option nor should it be an unintended
consequence of poor planning.”
Response
See response to Comment D-2.13 regarding origin-destinations within the study area. I-7.3 Comment
“It is critical that the Urban Ring go through Assembly Square and I hope that the
project will prevail upon the developers and the City of Somerville to ensure that this is
accomplished. All efforts to reduce auto traffic to this development should be
encouraged.”
Group I - Response to Individual Comments
Page 139
RESPONSE TO COMMENTS ON RDEIR Response
An Urban Ring Station was planned for Assembly Square as part of the LPA, and the
route modification described in the NPC Attachment 6 (Section 6.1) will continue to
include an Urban Ring station at Assembly Square.
I-7.4 Comment
“I am opposed to a commuter rail connection at Sullivan Square because this will
seriously increase the air pollution in this neighborhood that is already overburdened
with pollution from I-93 and the Boston Engine Terminal. Trains passing through a
station do add to the pollution, but not as much as trains that stop and then must
accelerate when they leave a station. If a commuter rail connection is desired it should
be located where there are current commuter rail stations north of Sullivan Square.
Until the MBTA electrifies the commuter rail system, adding stations in overburdened
communities to benefit people who do not live near these stations increases the
environmental burden of communities such as East Somerville.”
Response
See response to Comment I-1.5 regarding Sullivan Square station.
I-7.5 Comment
“I strongly support the Urban Ring going through and stopping in the Inner Belt in
Somerville and connecting to the Green Line either at Lechmere or the proposed
Brickbottom Washington St. station.”
Response
Comment noted. I-7.6 Comment
“Finally, I recognize the challenges of creating a circumferential system in our densely
developed metro area, but we must recognize that the BRT options proposed does not
provide seamless access across the region.”
Response
EOT will continue to refine and develop the project elements to enhance access and
mobility benefits as the project advances.
Group I - Response to Individual Comments
Page 140
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-8
Received from: Fred Salvucci
February 24, 2009
Comment No.
I-8.1 Comment
“The Draft EIS, and its proposed locally-preferred alignment, does not consider the
interrelationship of these issues in a confined urban space, and therefore ignores the
opportunity to do 3 things simultaneously with 80% Federal Funds: provide a
reconstruction strategy for the BU Bridge that would properly mitigate construction
disruption; deal with the Urban Ring river crossing problem; and remedy the severe
deficiency in bicycle connectivity between the BU Bridge and the Storrow
Esplanade…. The proposed Urban Ring tunnel under the LMA…. is vitally important
for Longwood Medical Area to grow without gridlock, but the DEIS provides no
information on the proposed construction lay-down area, excavate removal, and other
logistical requirements for tunnel construction…. The only suitable area for these
disruptive but necessary features of tunnel construction are in Beacon Park Yards,
which CSX is now proposing to vacate. In this location, construction material can be
brought in, and excavate removed, by train or truck directly onto the Turnpike without
using city streets. Since all necessary construction and reconstruction projects in
question – the BU Bridge, the CSX Bridge, the Turnpike viaducts, the Commonwealth
Avenue bridges, and the Urban Ring tunnel – are now, or are proposed to be, under
the jurisdiction of EOT, it is essential that the FEIS take a comprehensive look, and
seek to minimize adverse impact while maximizing the use of Federal bridge funds. I
respectfully request that your certificate on the DEIS take note of the Governor’s
proposed transportation reform and require that the EOT develop a comprehensive
plan for this area.”
Response
Comment noted. See response to Comment G-8.5 regarding options considered for extending the
tunnel further west, and the Tunnel Technical Report for conceptual analysis of tunnel
staging and laydown requirements.
EOT will continue to look comprehensively at all relevant transportation projects in the
vicinity of the Urban Ring to maximize coordination and use of available federal funds.
Group I - Response to Individual Comments
Page 141
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-9
Received from: Joel N. Weber II
February 9, 2009
Comment No.
I-9.1 Comment
“I believe that any major new investment in mass transit ought to have the entire route
use overhead wire and/or third rail to power the vehicles from the electric grid, to
eliminate pollution, open the door to use of clean energy sources, and to help us meet
President Obama’s goal of reducing our dependency on oil from places such as the
Mid-East.”
Response
The use of third rail power is not feasible for this project due to the inability to create
the type of 100% grade separate alignment required by such a system throughout the
entire 25 mile corridor. Overhead wire for trolley buses, while technically feasible,
would greatly increase capital costs with little benefit to overall performance and
ridership. The project proponent is committed to utilizing low emissions BRT vehicle
technology such as hybrid electric, which has been successfully implemented in many
systems nationwide and overseas. As the project advances, vehicle propulsion
technology will be further reviewed during preliminary engineering and final
environmental.
I-9.2 Comment
“Robert La Tremouille has argued that an alternative of building the LMA tunnel
proposed in the Urban Ring documents as an extension of the MBTA’s existing
Orange Line from Ruggles instead of as a bus tunnel should be studied, and I believe
this is an excellent alternative that the study needs to contemplate more thoroughly.”
Response
See response to Comment F-2.1 regarding proceeding directly with Urban Ring Phase
3.
I-9.3 Comment
“Having compared the Urban Ring study’s proposed route to MBTA bus ridership
statistics, I am concerned about whether the Urban Ring’s proposed route really
matches the areas of greatest potential benefit from investment in new mass transit
infrastructure. In particular, the MBTA’s route 66 bus has significantly higher ridership
than the bus routes near the Longwood Medical Area tunnel, and I would like to see
the study explain in greater detail why it chooses not to follow the 66 bus’s route more
closely.”
Response
Route 66 has an existing daily ridership of over 11,000 boardings. In the LMA area
crosstown Routes 8, 19, 47, CT2, and CT3 have approximately the same daily
ridership. The Urban Ring alignment in this area connects the institutional and
employment areas of LMA/Boston Medical Center/Boston University with residential
areas to the north and south, including environmental justice (EJ) neighborhoods. The
Urban Ring would provide a high level, single-seat, limited stop service in this area that
is not currently provided. The projected ridership at the proposed LMA station is over
27,000 riders based on RDEIR analysis. The Urban Ring alignment does not try to
replicate the Route 66 alignment which serves a travel market further west.
Group I - Response to Individual Comments
Page 142
RESPONSE TO COMMENTS ON RDEIR I-9.4 Comment
“The Urban Ring project as proposed, while it claims to be rapid transit, does not meet
this definition of rapid transit [transit service operating completely separate from all
modes of transportation on an exclusive right of way]; there are mixed traffic areas.”
Response
Over 50% of the Urban Ring alignment will be in dedicated right-of-way, primarily
busways and bus lanes, with queue jump lanes and/or bus signal priority in areas of
mixed traffic. Also see response to Comment F-3.2 regarding mixed traffic.
I-9.5 Comment
“There are also areas which could be exclusive to the proposed buses which are
proposed to be shared with bicycles. I am concerned about how well buses and
bicycles can share the right of way, such as how well buses can pass bicycles, and
would like to see the study comment on whether there are successful examples of
such sharing elsewhere in the US. I am baffled that the study proposes dedicated bus
lanes in congested areas. Are operators of single occupancy vehicles in those
congested areas going to be willing to give up a lane for the buses?”
Response
A growing number of communities are using shared bus and bike lanes to give
preferential treatment to both bikes and public transport. Examples currently include
Tucson, AZ; Madison, WI; Toronto, Ontario; Vancouver, BC; and Philadelphia, PA.
Often the lanes also permit the use of taxis and right-turning vehicles.
EOT is continuing to look at operations of busways and bus lanes in conjunction with
other modes including bicycles for specific areas. One area is the Grand Junction Rail
corridor in Cambridge. No final decisions have been made at this time regarding
shared-use. This issue will be further evaluated in conjunction with the MBTA and
municipalities during preliminary engineering and final environmental review.
The number of existing lanes provided for general traffic has not been reduced as a
result of the proposed Urban Ring LPA bus lanes throughout the corridor. Therefore,
the project will not reduce capacity for general traffic. There may be instances in the
interim condition where general traffic lanes are reduced during project construction.
However, the interim condition and alignment have not been identified.
I-9.6 Comment
“The choice of symbols in the map is problematic. Solid yellow is the mixed traffic
color. But the tunnels and busways are dotted yellow and other colors, such that one
can’t tell if some of the solid yellow is the dotting pattern, or a tiny mixed traffic section
being hidden. For a multibillion dollar project, I would expect that the study could
provide a more readable and less ambiguous map.”
Response
For corridor-wide maps such as Figure 2-1 the mapping is highly diagrammatic due to
the large geographic area being shown on a single page. More detailed diagrams
showing individual routes and their operating environment (i.e. mixed traffic, buslane,
busway, etc…) are provided in Figures 2-4 through 2-11 in Chapter 2 of the RDEIR.
Yet further detail is provided in the conceptual Plan and Profile drawing set. The level
of detail in the mapping and drawings will advance with preliminary engineering.
Group I - Response to Individual Comments
Page 143
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-10
Received from: John F. Burckardt, PE
February 9, 2009
Comment No. I-10.1
Comment
Transit’s Positive Impact on the Environment
“The Urban Ring, like the proposed Green Line Extension, will have a significant
positive impact on the environment and energy use by reducing motor vehicle trips,
with the benefits of less air pollution and less roadway congestion.
“…The Secretaries of EOEEA and EOTPW should establish a special status in the
MEPA process. This special status should recognize the inherent environmental
benefits of the project and allow for the project proponents a greater degree of
flexibility in incorporating and implementing the MEPA regulations and the comments
received in this process.”
Response
Comment noted. I-10.2 Comment
Bus Transit vs. Rail Transit
“Clearly, EOTPW had determined that Urban Ring Phase II should be implemented
with all bus-based transit services rather than implementing any new rail transit (as is
proposed for Phase 3 in the MIS).
“Nevertheless, I believe there is merit in considering the incremental costs and benefits
of rail transit. Since the LPA includes a costly tunnel in the Longwood Medical and
Academic Area (LMA), the Phase 3 costs may justifiable in light of the benefits of
greater capacity and faster travel times.”
Response
See response to Comment F-2.1 regarding immediate implementation of Phase 3 rail
service.
I-10.3 Comment
Bus Transit vs. Rail Transit
“Simply put, the Urban Ring Phase II does not resemble BRT in terms of velocity or
travel times. As demonstrated above, rail transit in the Urban Ring would achieve
significantly better travel times.… Much of the Urban Ring is a patchwork of facility
types: some street running, then a few blocks with a dedicated bus lane, then a few
blocks of dedicated busway. While it may mathematically add up to over 50%
dedicated facilities, these are not contiguous segments.
“Granted, exceeding the 50%+ dedicated facilities threshold and the BRT label may
facilitate FTA funding. Nevertheless, my opinion remains that the Phase 2 proposal is
not truly BRT, but rather a form of enhanced urban bus transportation. It adds transit
services to the region, improves mobility and convenience, but remains a few cents
shy of a true BRT.”
Response
See response to Comment F-3.2 regarding planned bus improvements to improve
travel speeds. Refer to the NPC Attachment 6 (Section 6.2) regarding the Northern
Tier implementation stage and its contiguous dedicated right-of-way.
Group I - Response to Individual Comments
Page 144
RESPONSE TO COMMENTS ON RDEIR I-10.4
Comment
Phase 3 Compatibility
“This is discussed in Section 2.2.4 of the RDEIR/DEIS, but the section does not
answer the important questions:
• How do you convert from Phase 2 to Phase 3 without significant disruption
to service?
• How long will it take?
“If the tunnel is the only way to get the buses through the LMA, what good is a plan
that would require shifting the buses out of the tunnel to the surface for a year or two?
In my opinion, there is no Phase 3 compatibility if such a major disruption is part of the
plan for a Phase 2 to Phase 3 transition.”
Response
An interim routing of buses through the LMA will be developed to be in place while
Phase 2 is being constructed. The interim surface routes would be designed to
address the major transit demand and the need for measures to improve transit
mobility in this area. Similarly, an interim routing plan would be developed to convert
Phase 2 to Phase 3 technology. This issue will be further reviewed and addressed
during preliminary engineering and final environmental review.
I-10.5
Comment
Bicycle Facilities
“The Urban Ring is very thorough in the small details: enumerating existing and
proposed bicycle facilities. But there is a big picture opportunity that is being missed.
“The Urban Ring is in the vicinity of Harvard, MIT, BU, LMA and BU Medical essentially
links a series of world-class medical and health education and research institutions
and facilities. So, why, in the interest of promoting public health, is there not a plan to
provide a parallel bicycle and pedestrian path system?
“…The Commonwealth should strongly back this proposal and get the institutions to do
their part.”
Response
EOT supports pedestrian and bicycle accommodation and facilities as modes of
access to the proposed Urban Ring service, and will continue to coordinate with
municipalities, DCR, and institutions where such networks are in proximity to the Urban
Ring corridor.
I-10.6
Comment
Logan Airport
“I would question the decision to have the Urban Ring service only stop at the Central
Garage and not the individual terminals. Currently, Silver Line Route SL-1 does stop at
each terminal. I have found this to be very convenient service, with an easy transfer at
South Station and convenient service to each terminal. If airport employees are the
likely riders, then the one central stop may work for such daily transit patrons.
“However, I believe the Urban Ring Service will be much less convenient if it is
intended for the flying public, particularly infrequent flyers and out-of-towners not
familiar with Boston and its transit system. I recommend stop at each terminal.”
Group I - Response to Individual Comments
Page 145
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment D-2.6 regarding Logan Airport terminal stops. I-10.7
Comment
Bus Cut-Through Connection at Kendall Square
“I applaud the proposed connection for buses between Main Street and Third Street.
The impact to Galaxy Park can be mitigated. I would recommend that this bus
connection be also available for bicyclists, as this connection has been recommended
by the Cambridge Bicycle Committee (which I have been a member for over 10
years).”
Response
Comment noted. EOT has discussed several options for accommodating bicycles at
this location with the City of Cambridge and the Cambridge Redevelopment Authority.
EOT will continue to coordinate with them as the project enters preliminary engineering
and final environmental review.
I-10.8
Comment
Main Street Cambridge
“Bus lanes are proposed in both directions, displacing existing on-street parking and
potentially impacting existing bike lanes. These features calm traffic and provide a
normative and pedestrian-amenable urban retail/commercial district feel to the street.
Stripping the on-street parking would reverse these gains in traffic calming and
creating a pedestrian amenable environment by reverting Main Street to its previous
“urban arterial feel” where there are just unrestricted travel lanes and no parked car
buffer between the sidewalk and motor vehicle traffic.
“While curbside bus lanes may work in other areas of the corridor, I believe they are
not compatible with the pedestrian environment of this segment of Main Street.”
Response
On-street parking does act as a passive traffic calming feature by reducing the
effective roadway width. The proposed bus lanes would reduce the effective road width
for general traffic, but they would not eliminate existing bike lanes. EOT will continue to
work with the City of Cambridge to develop preliminary designs that accommodate
buses and preserve safety and mobility for all users.
I-10.9
Comment
Fort Washington Park, Cambridge
“Page 5-120 discusses making “every effort” to prevent “future deterioration” Table 5­
45 indicates “no permanent land takings/alterations of use” but does not directly
appear to address these issues:
• Will the final alignment for the busway be such that no portion of the
busway is within park property? This would require that the busway
passing the park is 100% in what is now the CSX Grand Junction right-of­
way.
• The statement of making “every effort” to prevent “future deterioration”
does not seem like a strong enough statement to assure that the historic
resources will not be impacted by this project. The Secretary should
require a firmer commitment to projection of the resources and a
commitment to repair any resources damaged as a direct impact of this
project.”
Group I - Response to Individual Comments
Page 146
RESPONSE TO COMMENTS ON RDEIR Response
No portion of the proposed busway will be within the Fort Washington Park as shown
in the conceptual alignment plans. The busway will be within the Grand Junction
railroad right-of-way.
I-10.10
Comment
Harvard Square
“The Urban Ring should use the existing bus tunnels at Harvard Square. This would
improve travel times through the square and can be accomplished at no cost to the
project.”
Response
Use of the existing bus tunnels at Harvard Square is planned as part of the Urban Ring
LPA, per the RDEIR. Whether it is feasible to utilize the Harvard Square bus tunnels in
both directions is something that will be looked at further during further planning and
engineering.
I-10.11
Comment
BU Bridge/Charles River Crossing
“A separate bus crossing using a reconstructed rail bridge would avoid the peak hour
traffic backup on the BU Bridge, particularly evenings before Red Sox games. As the
existing 12-degree curve on the Boston side is as tight as a curve can be on the Grand
Junction Branch, there are some geometrics to be refined regarding how to
accommodate a track and busway while clearing the existing piers of the BU Bridge.”
Response
Comment noted. Conceptual engineering performed during the RDEIR shows the
proposed geometrics are feasible. The issues raised will be evaluated further during
preliminary engineering.
I-10.12
Comment
Emerald Necklace
“The FEIR should consider all of the possible impacts that have not currently been
anticipated by the preparers of the RDEIR/DEIS:
“Ground Monitoring: The 3 tunnel alignments pass under the park and Muddy River.
Assuming a bored tunnel, heaving or settlement are a concern and typically when
tunneling is proposed under other linear infrastructure facilities (e.g., rail lines,
highways).
a. Will there be ground monitoring proposed within the Emerald
Necklace?
b. If yes, where will the monitoring points be located, will they impact
vegetation or wetlands, how will they be accessed to install and
monitor (e.g., route taken, type of vehicle, where will it park)?
c. If no, why is this historic linear open space infrastructure considered
different from other linear infrastructure (e.g., streets, MBTA tracks,
utilities)?”
Response
Final tunnel alignment, construction methodology, and measures such as ground
monitoring will be addressed during preliminary engineering.
Group I - Response to Individual Comments
Page 147
RESPONSE TO COMMENTS ON RDEIR I-10.13
Comment
Emerald Necklace
“Curbline Changes: While no change in curblines for the “interim surface bus service
for the Fenway” appears to be currently proposed, such changes were proposed in the
previously issued DEIR. It must be emphasized that any curbline changes could be an
impact to this historic resource. The FEIR should confirm that there will be no curbline
changes proposed with the historic Emerald Necklace.”
Response
Interim surface bus alignments developed in the RDEIR differ from the DEIR in that no
curbline modifications are proposed.
I-10.14
Comment
Emerald Necklace
“Ventilation Shafts: Ventilation is discussed, but ventilation shaft locations are not
located. Based on current codes for transit tunnels, a one-station tunnel with long
approaches would likely require four (4) ventilation shafts in the configuration indicated
below.
“…I would anticipate needing a ventilation shaft near the west portal. This would be
somewhere in the vicinity of Park Drive, and potentially either at Back Bay Yard or
within the Emerald Necklace, within any of three alignments shown in the
RDEIR/DEIS.
• The FEIR should indicate potential location of ventilation shafts.
• The FEIR should indicate whether any shafts would be within the Emerald
Necklace.
• If any shafts are within or near the Necklace, the FEIR should indicate the
impacts to historic and wetland resources of the shaft itself, or constructing
the shaft including the power feed conduits, and of accessing the shafts for
maintenance and operations.”
Response
Conceptual engineering of the tunnel indicates ventilation shafts may need to be
located at both ends of each proposed underground station. The proposed
underground stations are located adjacent to the Landmark Center and at Longwood
Avenue. Neither location is within the Emerald Necklace. Refer to the RDEIR Plan and
Profile drawing set Sheets 1T-W, 1T-C and 1T-E for the underground station next to
the Landmark Center and to Sheet 4T for the underground station beneath Longwood
Avenue. Potential ventilation shaft locations and their impacts will be further analyzed
during preliminary engineering and final environmental.
I-10.15
Comment
Emerald Necklace
“Tunnel Access Shafts: While the exact number and locations of additional access
shafts are not typically known at this time, the presence of any such shafts within the
Emerald Necklace would be a significant impact on this historic resource and could
also impact wetland resources.
“Therefore, the FEIR should anticipate whether there would be any such access shafts
within the Emerald Necklace. If any shafts are within or near the Necklace, the FEIR
should indicate the impacts to historic and wetland resources of the shaft itself, of
constructing the shaft including any utility connections, and of accessing the shafts for
maintenance and operations.”
Group I - Response to Individual Comments
Page 148
RESPONSE TO COMMENTS ON RDEIR Response
The tunnel alignment is still under consideration. Potential access shaft locations and
the impacts of the shafts will be discussed in future environmental review documents
for this project.
I-10.16
Comment
Reliability of Articulated Buses in Winter Storm Conditions
“During winter storms with snow, sleet, icing and/or freezing rain, the MBTA is currently
substituting 40-foot single-unit buses in place of the usual 60-foot articulated buses on
Route 39 (Back Bay to Forest Hills).
“The Urban Ring Phase II indicates the proposed use of similar 60-foot articulated
buses. The FEIR should address this issue and discuss the winter weather reliability of
the buses proposed for Phase II. If 40-foot buses must replace the higher capacity
articulated buses on the higher demand travel days during winter storms, this may alter
both the operating plan and the expected system capacity and travel times.”
Response
There are many factors to consider substituting bus types during winter conditions
including grade, surface conditions, tire type, propulsion, etc. For the Urban Ring, most
of the alignment and route is relatively flat with significant portions of the route
provided in exclusive busway. It is ultimately up to the MBTA to decide what type of
vehicle is best for specific weather conditions. EOT will continue discussions with the
MBTA regarding use of 60-foot articulated during winter conditions.
Group I - Response to Individual Comments
Page 149
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
I-11.1 I-11
Karen Wepsic
February 5, 2009
Comment
“As presently proposed it does not conform to the original intent. If it is now just a
proposal to offer these multiple bus routes what needs to also be proposed is
improvements to some of the heavily traveled bus routes that currently serve the
corridor.”
Response
Improvements, maintenance, and operations of other bus routes are the responsibility
of the MBTA. However, the busways, bus lanes, queue jump lanes, bus signal priority,
and Intelligent Technology Systems planned as part of the Urban Ring project would
also improve travel and reliability for other MBTA buses and shuttle buses.
I-11.2 Comment
“In the Executive Summary on page ES-4 it states that the Environmental Justice
Population would benefit from improved access to the transit system. What needs to
be demonstrated is that the Urban Ring bus routes would give better access for these
populations to the transit system.”
Response
See response to Comment F-10.7 regarding improved access for environmental justice
populations.
I-11.3 Comment
“On page ES-8: Weekend statistics should be included.”
Response
See response to Comment F-10.8 regarding weekend service. I-11.4 Comment
“On page ES-17: Need to include travel time savings for each environmental justice
neighborhood not just the whole.”
Response
See response to Comment F-10.10 regarding travel time savings for environmental
justice populations.
I-11.5 Comment
“On page ES-19: Need to be specific as to which Green Line branches will have
reduced ridership.”
Response
See response to Comment F-10.11 regarding the Green Line ridership analysis.
I-11.6 Comment
“On page ES-21: Which roads will have reduced automobile traffic? Are there any
roads for which automobile traffic will increase?”
Group I - Response to Individual Comments
Page 150
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment F-10.12 regarding automobile traffic increases/decreases. Table 4-27 shows traffic volume changes on roadways. I-11.7 Comment
“On page 2-63: If the articulated buses cannot be used on any of the routes due to ice
and snow as is the current requirement for the Route 39 buses, how is the MBTA
going to be able to supply enough buses on those ice and snow days to run the Urban
Ring bus routes?”
Response
See response to Comment I-10.16 regarding winter weather impacts for buses.
I-11.8 Comment
“On page 2-44: It discusses no adverse visual impacts. I see visual impacts in placing
a station entrance right in front of the entrance to the education building of Harvard
Medical School. I see a visual impact in placing the station entrance right in front of the
Kendall station on the Red Line.”
Response
We assume you mean Section 2.4.4 (page 2-65). It is the intent of the project to
enhance and complement visual and aesthetic conditions with new, clean, attractive
facilities using context sensitive design. Specific station location and design standards
will be further defined as the project advances.
I-11.9 Comment
“On page 2-82: There is totally outdated information about Harvard Medical School.
There is no more department of Anatomy and Histology. There is no more Department
of Physiological Chemistry. Boston Lying-In Hospital no longer exists. That building is
now a laboratory.”
Response
This information regarding Harvard Medial School will be noted in future environmental
review documents for this project.
I-11.10 Comment
“On page 3-3: The only routes left from the Urban Ring Phase 1 are CT1, CT2 and
CT3. These routes do not start early in the morning nor do they run after 7 P.M. in the
evening on weekdays. There is no weekend service. This could be an indication of
how the service on the Urban Ring Phase 2 will eventually be implemented.”
Response
See response to Comment F-10.14 regarding CT bus route service. I-11.11 Comment
“On page 3-20: An analysis of each commuter rail stop on the Urban Ring Phase 2
needs to be done to see how many passengers will be trying to board one bus after
the commuter rail has deboarded. Commuter rail comes every 75 minutes or so. Can
one articulated bus which may already have passengers on it accommodate a fully
deboarded Commuter Rail train.”
Group I - Response to Individual Comments
Page 151
RESPONSE TO COMMENTS ON RDEIR Response
See response to Comment F-10.15 regarding commuter rail analysis. I-11.12 Comment
“Page 4-20: Silver Line Phase 3 is actually Silver Line Phase 1 plus Silver Line Phase
3. Silver Line Phase 1 will remain with increased headways and using articulated CNG
buses. Silver Line Phase 3 is an add-on with dual mode articulated buses only some of
which will depart from Dudley.”
Response
The Silver Line description will be clarified in future environmental review documents
for this project.
I-11.13 Comment
“Page 4-29: Need to add the Kennedy Library shuttle from the JFK stop on the Red
Line which also serves UMass.”
Response
The Kennedy Library Shuttle will be added to future environmental review documents
for this project.
I-11.14 Comment
“Page 4-30 Table 4-9: It estimates the Ruggles Express would shift 1,311 riders to the
Urban Ring. The Urban Ring is proposed to have the station at Ruggles be on the
Northeastern University side of Ruggles Station. The bus station at Ruggles is all the
way on the other side of Ruggles Station and at a lower level. It seems much more
likely that bus riders coming to Ruggles to get to the Longwood Medical Area would
take a connective bus at the bus station area of Ruggles (Bus Routes 47, 8, 19) rather
than walk upstairs, a long walk through the station and then wait for the Urban Ring
bus.”
Response
Comment noted. Specific boarding locations for Urban Ring BRT at Ruggles Station
will be defined as part of operations planning as the project advances.
I-11.15 Comment
“Page 4-88: It states that pedestrian crosswalk distances will not increase with the
addition of busways and bus lanes. A full detailed description of every crosswalk
across Melnea Cass Boulevard for its full length needs to be described for pedestrian
safety – where are there traffic lights, including walk lights. Melnea Cass is already too
wide for pedestrians an additional two more lanes can only make it more dangerous for
pedestrians.”
Response
The Conceptual Alignments, Profiles, Station Locations, and Typical Sections Draft
Plans dated November 2008 show locations of crosswalks and signals. The proposed
BRT stations near Washington Street would provide refuge islands for pedestrian
crossings. Signals would be improved to provide adequate protected crossing times for
pedestrians. EOT will continue to coordinate with BTD and BRA to ensure pedestrian
safety and access as the project enters preliminary engineering.
Group I - Response to Individual Comments
Page 152
RESPONSE TO COMMENTS ON RDEIR I-11.16 Comment
“Page 5-67 and 5.7.2: This talks about low value and common birds. I have seen a
blue heron and a sandpiper in my occasional strolls in the Muddy River/Fens Area.
There is an Emerald Necklace Bird Club that has a detailed listing of bird sightings in
that same area.
“Looking at the list of bird sightings in the Urban Ring affected area one can hardly say
that there are only low value and common birds here.”
Response
The discussion of bird impacts will be reviewed and revised as appropriate in future
environmental review documents for this project.
I-11.17 Comment
“6.1.2 Operating and Maintenance Costs: Needs to include a more detailed listingincluding bus replacement costs and how this will be paid for. The current MBTA draft
PMT (Program for Mass Transportation), a 25 year planning document which the
MBTA is required to submit to the legislature every 5 years as part of the MBTA’s
enabling legislation, explicitly states on page 3 of Chapter 3 that the Urban Ring “will
require state and/or federal funding to design, build and operate”. The current
document under review needs to include how the state intends to pay for all of this.”
Response
The Certificate dated March 6, 2009 has required additional information on funding and
scheduling for the FEIR. See response to Comment F-1.2 for funding options under
consideration.
I-11.18 Comment
“6.2 Financial Framework Talks about District Improvement Financing: The many nonprofits in the Urban Ring area are in a weakened financial condition. This item needs
much more elaboration if it is to have any meaning.”
Response
See response to Comment F-1.2 regarding potential funding options. Additional
financing information will be provided in the FEIR/FEIS.
I-11.19 Comment
“Page 6-11 Phasing and Implementation: A detailed scenario for phasing needs to be
addressed. Who will benefit? Are there environmental justice communities that will
short-changed by phasing?”
Response
See response to Comments F-1.1 and F-1.3 for additional information regarding
phasing and implementation.
The NPC recommends the Northern Tier as the first stage of Phase 2 implementation,
which will provide major access and mobility benefits to environmental justice
communities.
I-11.20 Comment
“Page 8-5 Community meetings: All meetings and meeting minutes were not shared
with the CAC or posted on the Urban Ring web site. A public meeting I attended in
Group I - Response to Individual Comments
Page 153
RESPONSE TO COMMENTS ON RDEIR Roxbury only permitted written questions to be turned in before the presentation with
no follow-up questions.”
Response
Minutes from all major public meetings, CAC meetings, subcommittee meetings and
working group meetings are posted on the project website. Because there were
several hundred meetings, the notes from every single meeting were not posted, but
they could be made available on request. At one of the Roxbury meetings, the
participants were asked to submit questions in writing during the presentation and
during the question-and-answer session itself. There were follow-up questions (in
writing) and there was a robust dialogue at that meeting.
Group I - Response to Individual Comments
Page 154
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-12
Received from: Kenneth J. Krause
February 10, 2009
Comment No. I-12.1
Comment
Lack of Dedicated Bus Lane in Wellington area:
“Only 52 percent of the Urban Ring is currently designed to [run in dedicated busways].
A crucial section that does not is in the Wellington Station/Route 16/Route 28 area.
Wellington Circle already is one of the most congested and poorest performing
intersections in the state, and this condition is likely to get only worse with the
additional traffic anticipated from the Assembly Square/IKEA development.
“I would urge that every effort be made to create dedicated busway lanes for the Urban
Ring in this area, and also that the project to depress Route 16 under Wellington Circle
– which is in the state’s Long Range Transportation Plan – be expedited to be part of
the Urban Ring project. This will go a long way toward achieving the overall
performance goals of the entire Urban Ring project.”
Response
Wellington Circle is recognized as an area experiencing long traffic delay and heavy
congestion. Several alternative routings have been evaluated during the environmental
process to avoid Wellington Circle. Refer to the NPC Attachment 6 (Section 6.1) where
the Route 99 routing is recommended to replace the Wellington routing.
I-12.2 Comment
Lack of Commuter Rail Connection at Wellington Station:
“A major shortcoming – and missed opportunity to accommodate North Shore travelers
bound for Logan Airport – in the Urban Ring DEIR remains the lack of a commuter rail
connection at Wellington Station; instead, the DEIR proposes for two commuter rail
trains to stop at Sullivan.
“A commuter rail stop at Wellington would give travelers from the north the opportunity
to change to the Urban Ring uses for a one-seat ride from there to Logan through
Everett and Chelsea.
“I urge the consideration of adding a commuter rail stop at Wellington to connect with
the Urban Ring.”
Response
See response to Comment I-1.5 regarding the benefits of a commuter rail station at
Sullivan Square.
Group I - Response to Individual Comments
Page 155
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-13
Received from: Mark Sutherland
February 9, 2009
Comment No.
I-13.1 Comment
“The Urban Ring will not effectively provide mass transit unless the bus stop locations
are selected in a rational manner to maximize ridership. We have been advised that
the only bus station proposed for Cambridgeport is at the Fort Washington Park, which
is a relatively isolated location. We urge that the EOEA and EOT demonstrate how this
location was selected and by what criteria locations are selected, and we recommend
that steps be taken to ensure that bus stop locations be selected in Cambridgeport that
are accessible to the maximum number of potential users…. We also recommend that
Urban Ring include a bus stop at Massachusetts Avenue and one near the BU Bridge
Rotary within Cambridgeport.”
Response
EOT has conducted an extensive evaluation of alternatives routings, alignments and
station locations in the Cambridgeport area. This effort has been coordinated with the
City of Cambridge and MIT. As part of the overall BRT system, stations have been
selected to be widely-spaced, approximately 3/4ths of mile on average between
stations, which is comparable to rail transit service.
The number of locations where a station can be located in the Cambridgeport area is
constrained by several factors including available right-of-way, abutting land uses,
CSX rail operations, historic parks and properties, and conflicts with the roadway
system. The location of Cambridgeport station was included in the LPA to minimize
impacts and to serve the adjacent neighborhood. Alternatives were investigated on the
local roadways, but were found to be less conducive to accommodating 60-foot
articulated buses.
Station 6.1 is located at Massachusetts Avenue.
I-13.2 Comment
“We have been advised that the Urban Ring route in Cambridgeport will be near or
within the Grand Junction Railway right-of-way, where Cambridgeport residents have
long advocated for improved pedestrian and bicycle paths and access. Accordingly, we
recommend that any Urban Ring development of this route, whether bus or rail, must
include a design to maximize alternative and environmentally sound pedestrian and
bicycle routes.”
Response
EOT has coordinated extensively with the City of Cambridge on these issues. The City
is planning to implement a mixed-use trail within the CSX Grand Junction railroad rightof-way. The Urban Ring project will not preclude that project.
I-13.3 Comment
“The Charles River is Cambridgeport’s ‘front yard’ and it is of course a regional,
historical and natural treasure…. We therefore recommend that the Urban Ring
project, and the MEPA review and its report, show consideration and adoption of
specific plans and measures to ensure that the Charles River be protected to the
maximum in the course of any Urban Ring development, whether bus or rail.”
Group I - Response to Individual Comments
Page 156
RESPONSE TO COMMENTS ON RDEIR Response
The Urban Ring project is required to conform to all applicable environment permitting
and regulations. All potential impacts and mitigation concerning the Charles River will
be reviewed by MEPA and coordinated with relevant agencies, including DCR, ACOE
and others. At this time, the proposed Urban Ring project is not anticipated to create
significant impacts to the Charles River.
I-13.4 Comment
“The Urban Ring involves major capital spending throughout Boston and Cambridge
area and therefore it is imperative that it include comprehensive plans for urban ‘best
practices’ to help implement appropriate open space planning, amenities such as
proper bus shelters, accessible sidewalks, environmentally appropriate materials,
permeable ground surfaces for runoff (where possible). We urge that the MEPA review
and report in this manner show comprehensive plans for implementation a broad range
of such amenities to enhance the overall Urban Ring use experience and to benefit
surrounding neighborhoods. We urge in this time of economic crisis to not have to pay
for the amenities twice, once for a temporary bus line, and eventually for a rail line. It
might make economic sense to go straight to the rail line so as not to duplicate these
costs. The federal economic stimulus package could perhaps provide money for rail
line; it is just the type of infrastructure project for which the government is looking.”
Response
Development and design of amenities such as stations and sidewalks are a critical
element of the project. Preliminary concepts of stations and sidewalks are provided in
the RDEIR and the in the draft Conceptual Alignments, Profiles, Station Locations, and
Typical Sections document dated November 2008. Environmental issues are
evaluated in the RDEIR. Design details and materials will be identified and reviewed as
the project enters the preliminary engineering phase.
See response to Comments F-1.1, F-1.2, and F-1.3 regarding phasing/implementation
plans, project funding, and a schedule for resolving key remaining issues.
See response to Comment F-2.1 regarding proceeding directly to Urban Ring Phase 3.
I-13.5 Comment
“We urge outreach to community organizations and the public so that the general
public has ongoing opportunity to continuously be appraised of the Urban Ring details,
perhaps similar to the e-mails sent to surrounding residents by DCR on construction
updates. Furthermore, and more importantly, we urge proactive steps to seek
community and public input on a continual basis.
“We are concerned about whether the selection of the buses will be made to minimize
pollution and noise…. We therefore urge that this process not go forward with a “knee
jerk” decision to use over-sized, energy inefficient buses during off peak or peak hours
or to use buses at all.”
Response
See Response I-11.20 regarding public outreach on the project to date. Community
outreach will continue as the project advances.
See response to Comment F-3.5 regarding bus propulsion technology types under
consideration.
Group I - Response to Individual Comments
Page 157
RESPONSE TO COMMENTS ON RDEIR I-13.6 Comment
“We would like to receive a copy of the proposed route and plans for this project, or
where we could access them. We would also like to know if studies have been done to
show that there is a specific need for this route and whether a study has been done to
determine whether buses or rail lines are the best choice.”
Response
The proposed Urban Ring Phase 2 LPA route is provided in Chapter 2 of the RDEIR.
Plans are provided in the draft Conceptual Alignments, Profiles, Station Locations, and
Typical Sections document dated November 2008, a copy of which is on the project
website, along with other project technical reports, at www.theurbanring.com
The Purpose and Need for the project is presented in Chapter 1 of the RDEIR.
Previous documents, including the 2004 DEIR and the Major Investment Study also
evaluate the need for the project and mode type.
Group I - Response to Individual Comments
Page 158
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-14
Received from: Marilyn Wellons
Undated
Comment No. I-14.1
Comment
Phase 3
“Like many others, I favor going directly to the 2001 Major Investment Study’s (MIS) Phase 2 A2 rail in the central corridor while improving existing bus routes, such as the No. 47, for example. Given the cost of the tunnel through Longwood Medical Area
(LMA), the need to keep all Phase 3 options open (Secretary’s May 20, 2005 Certificate), and the renewed understanding of mass transit’s benefits, this makes more sense to me than spending money on BRT. Consequently the RDEIR’s failure to maintain alternative UR 3 A2 at the northern end of the LMA tunnel raises serious doubts about the state’s commitment Phase 3 and, with it, to environmentally responsible transportation planning. “Analysis of the RDEIR’s understanding of the Charles River and other riverfront
parkland and of the Beacon Freight Yards does nothing to dispel these doubts.” Response
See response to Comment F-2.1 regarding proceeding directly to Urban Ring Phase 3. See response to Comment I-2.1 regarding reconnaissance efforts in the Charles River
and associated parkland areas. Additional visits to these and other areas will be made
as necessary as the project advances.
I-14.2 Comment
Open Space
“Beginning with Table 5.5.B’s misidentification of Charles River parkland around the
UR 2 River crossing in Cambridge (Segment B, sector 6) as entirely “commercial” (p.
5-11), the RDEIR fails to see the value of this land’s current use, in addition to sports
and cycling, as urban wild – home to waterfowl, songbirds, rabbits, and hawks – and
passive open space. Later references to “recreation” in the inventory of parks are to
active uses, with no apparent sense of open space as a place for the re-creation of the
human mind and spirit. Thus at the B6 Charles River crossing, the document’s attempt
at fine-grained description of parkland vanishes. It quickly pulls away from the plants,
animals, and humans whose habitat this is, to a satellite-level view of the entire “17­
mile linear park…stretching from Watertown to the Charles River Dam in Boston” and
its listing on the National Register of Historic Places. It notes bicyclists, walkers, and
joggers, but not the many thousands of people who need unmediated contact with the
natural world and have found it here.”
Response
Table 5-5B does not list any locations as being entirely commercial. See response to
Comment I-2.1 regarding reconnaissance efforts in the Charles River area. The
categorization of areas around the Charles River and descriptions of open space will
be reviewed during preliminary engineering and final environmental review for the
project.
Group I - Response to Individual Comments
Page 159
RESPONSE TO COMMENTS ON RDEIR I-14.3
Comment
Open Space
“The RDEIR at Section 5.7 cites ‘common,’ not rare or endangered, plants and animals
in this sector, apparently to dismiss their destruction as trivial. Just this indifference to
the ‘common’ has made many species rare, endangered, or extinct. Understanding the
worth of the ‘common’ – including us city dwellers – was the foundation of the Charles
River Reservation in the first place. Also, please note the Wetlands Protection Act
(WPA), M.G.L. Ch. 131, is not restricted to protecting rare or endangered species.
Consigning this “common” habitat to destruction, or accepting the rationalization that
damage from UR 2 is not permanent (Table 5-45, p. 5-146) is a travesty.”
Response
These issues will be reevaluated during preliminary engineering and final
environmental review of the project.
I-14.4
Comment
Open Space
“Please note that the UR2’s river crossings at the Malden and Charles Rivers Chapter
91 will apply…. While the RDEIR notes where in UR2 Chapter 91 applies, it fails to
record the consequences.
“The effect of Ch. 91 on WPA protections, themselves assumed in federal law requiring
environmental review of this transportation project, would thus seem to raise serious,
and unaddressed, questions about the validity of the RDEIR itself in the federal
process.”
Response
Chapter 91 impacts will be further addressed in final environmental review of the
project.
I-14.5
Comment
Beacon Yards
“The RDEIR fails to assess the environmental consequences of reducing or eliminating
the Beacon Freight Yards. Harvard’s plans for this land are important to the RDEIR’s
estimates of regional growth in jobs and population, hence ridership, hence the viability
of UR2. However, the planned change from intermodal freight in the urban core to
institutional uses will increase truck traffic in the regional, with negative effects on
public health. The RDEIR does not, for example, ask whether the presumed increase
in public transportation ridership and assumed reduction of vehicle trips will offset
these unexamined effects. It is not clear that the state’s Freight Study will consider this
issue, or if it will, whether the results will be available before filing of the FEIR.”
Response
The Urban Ring assumes the land use changes in the Beacon Park freight yards that
are part of the adopted MPO land use forecast to year 2030.
Group I - Response to Individual Comments
Page 160
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-15
Received from: Michael S. Dukakis
February 3, 2009
Comment No.
I-15.1 Comment
“I still do not understand what happened to Phase One… For reasons I don’t
understand, Phase One seems to have disappeared. Why? And when might we see
some evidence that it is not only back on the state’s transportation agenda but that it is
being seriously implemented?”
Response
MBTA Crosstown (CT) Routes CT1, CT 2, and CT3 were implemented as part of
Urban Ring Phase 1.
I-15.2 Comment
“I believe Phase Two is fatally flawed because it accepts as a given that continued
growth in the Fenway area is not only inevitable but even desirable – so much so that
we are being told that it will require a tunnel through the area that will cost at least 1.5
billion dollars. The kind of growth that we should be encouraging in the city’s
extraordinary medical establishment should be moving from the LMA across
Huntington Avenue and into Roxbury where there is available land, people who need
jobs, and a corridor down Melnea Cass Boulevard that could connect the LMA with
Northeastern and the Boston University Medical School and the Boston Medical
Center.
“…The Roxbury Master Plan already anticipates that kind of growth, and it is now past
time when it should be implemented. Piling more people and more growth into the LMA
makes no sense at all, nor does spending enormous sums of money to try to get
people in and out of the place, many of whom insist on arriving and leaving in private
automobiles.”
Response
Even under existing conditions there is significant traffic congestion and delay in the
Fenway and LMA areas. The Fenway/LMA tunnel would allow transit to avoid surface
congestion in this area of the corridor. The Urban Ring will connect the LMA and the
Boston Medical Center with Roxbury neighborhoods, which are also expected to
experience growth in the future.
Planning and development/redevelopment in the Fenway, LMA, Roxbury, and other
Boston neighborhoods is managed by the Boston Redevelopment Authority.
I-15.3 Comment
“Any transportation plans for the so-called urban ring must be weighed against other
transportation priorities in Boston, the most important of which is in my judgment the
North-South Rail Line which will finally end the absurdity of a metropolitan and regional
rail network that is broken between South and North Stations…. It will also provide a
lot more relief for the downtown subway than the proposed Urban Ring Phase Two.”
Response
Comment noted. Group I - Response to Individual Comments
Page 161
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-16
Received from: Rob Kassel
February 10, 2009
Comment No.
I-16.1 Comment
“Regarding the Urban Ring alignment connecting the Innerbelt and NorthPoint areas, I
am concerned that the current proposal does not serve the adjoining region adequately
to foster appropriate development in this valuable but long-neglected landscape.
Constructing a limited access viaduct as suggested creates yet another barrier that
adds to the burden imposed on the immediate area, including the Brickbottom
neighborhood of Somerville, without appreciable benefit to local residents and
businesses. If such a structure is required, …at minimum it should include a transit
stop approximately midway to serve a significant gap between planned stops on the
Green Line extension, but in addition vehicular and pedestrian access should be
added to help reconnect the lands long divided by rail lines that merely pass through.”
Response
The proposed alignment, route, and stations will bring transit service to the Inner Belt
area of Somerville currently underserved by existing transit. The Urban Ring service is
being coordinated with the planned Green Line extension in this area and that
coordination will continue as both projects move forward.
The planned busway viaduct portion of the alignment is not intended for general traffic.
Pedestrian and bicycle accommodations for the proposed alignment between
Washington Street and New Lechmere will be further evaluated in preliminary
engineering and final environmental.
I-16.2 Comment
“In addition, rather than the proposed “spur” serving Allston and Harvard Square, I
suggest that extending this route through Somerville’s Union Square and on to Sullivan
Square would reduce transit times while increasing ridership.”
Response
See response to Comment E-9.4 regarding project alignment through Union Square. Group I - Response to Individual Comments
Page 162
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-17
Received from: Robert J. La Tremouille
February 9, 2009
Comment No.
I-17.1 Comment
“My analysis includes objecting to false statements and inexcusable omissions about
land use, animal habitat, quality of animal residents and environmental quality on the
Charles River in the environmental section.”
Response
This information will be reviewed and revised as appropriate in future environmental
review documents for this project. See responses to Comments I-2.1 regarding
research to date, response to Comment I-13.3 regarding Charles River impacts, and
response to Comment I-11.16 regarding bird impacts.
I-17.2 Comment
“As part of Phase 2, I support heavy rail subway using the Longwood Medical Area
tunnel with direct connection to the Orange Line at Ruggles. I support a longer tunnel
in Phase 2 ending at a temporary terminus at Kenmore/Yawkey. The modified tunnel
would work well as the beginning part of an Urban Ring heavy rail subway using the
Kenmore Charles River crossing. Failure to analyze such a heavy rail use an
alternative to the LMA bus tunnel is a major defect in this proposal report.”
Response
See response to Comment F-2.1 regarding proceeding directly to rail (Phase 3).
See response to Comment I-17.29 regarding the Kenmore Charles River crossing. I-17.3 Comment
“The submittal fails the most basic of requirements for an Environmental Impact Report
by failing to consider having either of the two rail possibilities being accomplished at
the same time as Phase 2 in place of bus alternatives incorporated in Phase 2.
“The draft report fails to consider going forward with the Heavy Rail (Kenmore
Crossing) or Light Rail (BU Bridge Crossing) Subway alternatives instead of going
forward with the bus nonsense in those areas. These are simply designated by fiat as
being in Phase 3.
“…It would make an excellent sense IN PHASE 2 OF THE URBAN RING to use the
proposed LMA bus tunnel instead as the initial phase of the heavy rail Kenmore
Crossing alternative Urban Ring subway.
“The LMA tunnel used as heavy rail could be connected directly to the Orange Line at
Ruggles Station and have a temporary terminus at the Kenmore-Yawkey station…
“This option is not considered in the RDEIR/DEIS. It should be considered in the
RDIER/DEIS.”
Response
See response to Comment F-2.1 regarding proceeding directly to Urban Ring Phase 3
(rail).
See response to Comment I-17.2 regarding temporary Kenmore/Yawkey terminus and
a Kenmore Charles River crossing.
Group I - Response to Individual Comments
Page 163
RESPONSE TO COMMENTS ON RDEIR I-17.4 Comment
“The RDEIR/DEIS violates the terms on which the secretary’s order of May 20, 2005
was based.
“The secretary specifically required that Phase 2 not interfere with or predetermine
Phase 3 construction.
“The construction in Cambridge and over the Charles River resolves the crucial
decision of Phase 3 in favor of the alternative which, from a transportation and
environmental point of view, is the inferior of the two alternative Charles River
crossings.
“The proposal puts the Commonwealth in a position where the Commonwealth cannot
go forward with the Kenmore (heavy rail) crossing and must go forward with the BU
Bridge (light rail) crossing. Furthermore, the proposal accomplishes significant parts of
the environmental damage associated with the BU Bridge crossing, which damage is
part of the reasons for which the BU Bridge (light rail) crossing should be rejected.”
Response
The LPA does not use the BU Bridge to cross the Charles River, but rather the Grand
Junction Railroad Bridge. This does not preclude options for Phase 3 construction.
See response to Comment I-17.29 regarding a Kenmore Charles River crossing.
I-17.5 Comment
“One reason I reject light rail (BU Bridge crossing, Green Line technology) is because
the purpose of the Urban Ring as long as I have worked on it, has been to provide an
alternative to taking the subways downtown. Light rail simply will not get people off the
subways. It cannot compete because it is not fast enough.”
“The repeated use of the term “light rail” by BU Bridge crossing advocates to describe
both subway alternatives confuses good people and creates the apparently deliberate
effect of having people who would support heavy rail (Kenmore crossing) use the
words “light rail” not realizing they are being had.
“Such tactics are not acceptable, but should be recognized when reviewing comments.
A lot of people have been fooled by this con game and use the term “light rail” to
support the heavy rail Kenmore crossing or simply to support subway construction in
general.
“Light rail is street cars. Street cars are not an acceptable alternative. Street cars
simply would not divert enough people from the central subway.”
Response
Comment noted. See response to Comment I-17.29 regarding a Kenmore Charles River crossing.
I-17.6 Comment
“Figure 5-1 lists supposed uses on the Charles River which are flatly and simply false.
The area which is falsified is exactly the area most subject to irresponsible
environmental destruction. These false statements extend to the related text as well.
Group I - Response to Individual Comments
Page 164
RESPONSE TO COMMENTS ON RDEIR “I find it no coincidence that the DCR and Cambridge have for the better part of a
decade now have been working to destroy the environment in the area of Cambridge
falsified on this figure, that area within a half mile east and west of the BU Bridge.
Similarly, there are clear falsehoods in the figure with regard to areas west of the BU
Bridge in Boston.”
Response
The data from Figure 5-1 was obtained from MassGIS. This information will be
reviewed and RDEIR information will be updated as necessary in future environmental
review documents for the project.
I-17.7 Comment
“We will do no harm” to the Charles River White Geese.
“To make it worse, the environmental destructiveness in the BU Bridge area has been
prominently supported by the most basic of lies.
“Starting in spring 2000 when the public started objecting to their attacks on the
Charles River White Geese, DCR representatives repeatedly lied to many people
concerned about the future of the habitat of the Charles River White Geese. The DCR
representatives repeatedly denied any intent to harm the Charles River White Geese.”
Response
EOT will coordinate with DCR as the project advances to avoid environmental impacts
to the Charles River area and associated habitat.
I-17.8 Comment
“Animal habitat including the wildlife and waterfowl sanctuaries is falsely identified as in
commercial use, industrial use, or transportation use.
“According to Figure 5-1, the most delicate areas near the BU Bridge on the Charles
River in Cambridge are in commercial use. These are animal habitat. They are wildlife
and waterfowl sanctuaries.
“Full time users include the 25 year resident Charles River White Geese and
permanent resident Pekin Ducks. Visitors include Canada Geese, Red-Tailed Hawks,
Mallard Ducks, and many gulls. Rabbits have been seen in residence. Uses vary from
open fields to temporary bizarre designer bushes which should be removed and should
never have been introduced.
“Many web sources are specified below with photographs and analysis truthfully
identifying uses in this area.
“Figure 5-1 misidentifies at least half of Magazine Beach to the west of the BU Bridge
in Cambridge as commercial use.
“Figure 5-1 misidentifies the nesting area of the Charles River White Geese,
immediately to the east of the BU Bridge in Cambridge, once again as commercial
use.”
I-17.9 Comment
“Current supposed plans would destroy what little ground vegetation the DCR has not
destroyed. A significant portion of the destruction is clearly unnecessary.”
Group I - Response to Individual Comments
Page 165
RESPONSE TO COMMENTS ON RDEIR Response
EOT will coordinate with DCR as the project advances to avoid environmental impacts
to ground vegetation along the corridor.
I-17.10 Comment
“Figure 5-1 misidentifies areas of woody perennials, trees abutting the Charles River to
the east of the BU Bridge and on the sides of the Grand Junction Railroad between the
Charles River and Memorial Drive. All these areas area identified as commercial use.
“Figure 5-1 misidentifies a heavily wooded area between the Grand Junction and the BU Boathouse as industrial use. All the ground vegetation in this area has been destroyed by the DCR. “The BU Boathouse could be properly identified as a water related use. “(4) A significant portion of the area right at water’s edge east of the BU Bridge in
Cambridge is misidentified as transportation use. “It should properly be identified as open space or animal habitat. “(5) On the Boston side, pretty much everything west of the BU Bridge is identified as in transportation use. Much of that identification is false. “All these areas are falsely identified as in transportation use.” Response
See response to Comment I-17.6 regarding Figure 5-1. I-17.11 Comment
“The meadow on the Boston side is proposed for the highway connecting the Grand
Junction bridge and University Road. The Cambridge side would be destroyed for a lot
of stuff identified and not identified. Staging and subordinate highways under various
misleading names are most likely.”
Response
Comment noted. I-17.12 Comment
“The bizarre nature of Figure 5-1 may be dramatically recognized by observing the
photograph of “sector 6” which is part of Figure 5-4 (sectors 5-8) on page 5-33.
“The BU Bridge crosses the river in the middle of the photograph. The heavily treed
areas above (east) and below (west) on the left (Cambridge) side are identified in
Figure 5-1 as industrial use. The meadow which is misidentified as transportation use
is the green patch just below (west) of the right (south) end of the BU Bridge. All those
trees to the left (north) of the meadow are called transportation use.
“The sector 7 photograph on the same page is a much inferior view but it still shows a
significant number of trees on the upper (south) side of the Charles River to the right
(west) of the BU Bridge.
“The falsity of these statements in the document may be confirmed at
maps.google.com, using the satellite view. These are large areas.
Group I - Response to Individual Comments
Page 166
RESPONSE TO COMMENTS ON RDEIR “Table 5.5B identifies uses near the BU Bridge as follows: Transportation 10.1%, residential, 35.5%, Recreational 0.0%, commercial 17.3%, industrial 0.0%, urban open space 12.7%, water 11.4%. This would rather clearly be based on the FALSE information discussed immediately above. “Designations of Nesting Area of the Charles River White Geese, the meadow east of the BU Bridge is almost certainly erroneous, similarly the woods bordering it and the woods between the Grand Junction Railroad and the BU Boathouse. Similarly, a very major part of Magazine Beach is misidentified. “As well, the meadow west of the BU Bridge and bounded also by Commonwealth Avenue, the Mass. Pike, the Grand Junction, and Soldier’s Field Road is misidentified as transportation use.” Response
See response to Comment I-17.6 regarding Figure 5-1. I-17.13 Comment
“Table 5-6 on page 5-13, Summary of Anticipated ROW Impacts along the Urban Ring
Project Corridor Based on Current Land Uses, seems highly suspect both for
Cambridge and Boston. Notwithstanding this, the categories seem to be stacked
against meaningful communication when animal habitat and open space is being
destroyed.”
Response
Right-of-way requirements will be further defined during preliminary engineering. I-17.14 Comment
“Figure 5-2 on page 5-25 could possibly be correct but the results taken in real life
demonstrate severe problems in the criteria.
“I am looking at the area to the east of the water front animal habitat area being
destroyed by the use of the Grand Junction Bridge. This area includes four red colored
area, two between Memorial Drive and Vassar Street, two north of Vassar Street.
These four areas are MIT dorms/housing and include the school’s athletic fields.
According to the explanation for the colors, these four areas satisfy both of the Social
Justice criteria being evaluated. One of these areas could include a homeless shelter
which is in a building rented from MIT and subject to conversion to MIT purposes at the
end of the rental period.
“A similar evaluation applies to much of the Boston University campus. The sea of red
to the west of Kenmore Square has very little ownership other than by Boston
University. The coloring immediately changes when leaving BU owned areas.
“Each of the MIT and BU areas are very much exclusively university housing or other
university facilities, although there are some business uses in very limited area.
“Both areas include hotels.”
Response
It is important to consider that the Environmental Justice mapping in Figure 5-2 uses
Traffic Analysis Zones as its geographical unit, and will highlight the entire zone, not
just the portion of the zone where housing is physically located, when the socio­
economic criteria are satisfied.
Group I - Response to Individual Comments
Page 167
RESPONSE TO COMMENTS ON RDEIR The mapping is consistent with and reflects results illustrated on the EOEEA
Environmental Justice Maps. The presence of student populations are acknowledged
and adjusted for as part of the Environmental Justice analysis, but do not eliminate a
zone from consideration in deference to the remaining non-student population in that
analysis zone.
I-17.15 Comment
“Section 5.2.2 is striking in its total lack of any information for the BU Bridge area.”
Response
Comment noted. Chapter 5 of the RDEIR contains descriptions of existing conditons
and potential impacts in all segments of the corridor, including the Charles River
crossing area near the BU Bridge.
I-17.16 Comment
“Section 5.7 purports to refer to plant and animal species in habitats. Section 5.7.2
concerns the BU Bridge area. Not mentioned is the antipathy of the DCR to animals
living or visiting their property and the ongoing efforts by the DCR to destroy such life
by whatever technique is open to it.
“Nonetheless, the BU bridge area… contains a vibrant population of living animals.
“It very clearly is a waterfowl refuge. Failure to include it as such violates section 4(f) of
the Department of Transportation Act of 1966 codified 49 U.S.C. 303 and 23 U.S.C
138 and implemented through Final Rule at 23 CFR 774, with a new rule March 2008
23 CRF 774.
“Similarly, the riverbank on the south side of the Charles River west of the Grand
Junction bridge is also a waterfowl refuge.”
Response
This information will be reviewed and RDEIR information will be revised as necessary
in future environmental review documents for this project.
I-17.17 Comment
“Most valuable and very popular are the 30 year resident Charles River White Geese.
“The gaggle consists of Emden Geese and White China Geese with a limited
population of Toulouse Geese/Toulouse descendants. Some of the White China
descendants bear vestigial Brown China markings.
“For most of the past 30 years, they have lived in a habitat of about a mile east and
west on the north side of the Charles River centering on the BU Bridge.…The Nesting
Area of the Charles River White Geese is the meadow just east of the BU Bridge on
the Cambridge side.
“The uniqueness of a free gaggle of waterfowl which has lived in this wild area
surrounded by civilization for nearly three decades and which has maintained a
continuity of community cannot be understated.”
Response
Comment noted. This information will be provided in future environmental review
documents for this project.
Group I - Response to Individual Comments
Page 168
RESPONSE TO COMMENTS ON RDEIR I-17.18 Comment
“The DCR has irresponsibly confined the Charles River White Geese to the meadow
just east of the BU Bridge on the Cambridge side, directly impacted by Grand Junction
plans. The statement that these proposals (page 5-67, section 5.7.2, Environment
Consequences) “would not result in adverse impacts” is a knowing lie. The
characterization of this important gaggle as “low value” is similarly a knowing lie.””
Response
The comment regarding the White Geese habitat is noted and EOT will continue to
work with the goal of minimizing environmental impacts in this area.
I-17.19 Comment
“The beauty of these excellent and unique animals may be viewed at the follow sites.
Their importance, their very presence, and the presence of many other animals, may
be recognized through the fact that this list includes but a portion of the references
obtained through Google.
“The Grand Junction rail and bridge use would be devastating to this valuable and
threatened population of animals.”
Response
See response to Comment I-17.19. I-17.20 Comment
“On Page 5-73, the southern portion of the Nesting Area of the Charles River White
Geese, immediately east of the BU Bridge on the Cambridge side, is specifically
protected as wetlands.”
Response
This will be reviewed and RDEIR information will be updated if necessary in future
environmental review documents for this project.
I-17.21 Comment
Estimated Water Resources Impacts by Alternative (acres), Table 5-21, page 5-80:
“This shows 0.300 acres impacted for segment B, sector 6. This should include that
portion of the Charles River bounded by the Grand Junction Railroad Bridge, by the
BU Bridge, and by animal habitat/waterfowl refuge to the east of the BU Bridge in
Cambridge, the area to which the DCR has consigned the resident waterfowl by its
misbehavior, misbehavior which can and should be reserved as a condition for the
approval of this approval. The text on page 5-82 seems to indicate impact.”
Response
Comment noted. I-17.22 Comment
Wetland Impacts, Table 5-22, page 5-80:
“This shows 0.27 acres impacted for segment B, sector 6. This should include the
animal habitat/waterfowl refuge to the east of the BU Bridge in Cambridge, the area to
which the DCR has consigned the resident waterfowl by its misbehavior, misbehavior
Group I - Response to Individual Comments
Page 169
RESPONSE TO COMMENTS ON RDEIR which can and should be reversed as a condition for this approval.
“The text at the bottom of page 5-82 seems to indicate otherwise.
“I would suggest that the conditions listed in the supplement to this report be made conditions for approval if it is approved and I do not think it should be approved.” Response
See response to Comment I-17.21 regarding Segment B impacts.
I-17.23 Comment
Estimated Filled Tideland Impacts by Alternatives (Acres), table 5-23, page 5-81:
“0.39 acres is listed as impacted for segment B, sector 6. I presume this is the animal habitat/waterfowl refuge to the east of the BU Bridge in Cambridge, the area to which the DCR has consigned the resident waterfowl by its misbehavior, misbehavior which can and should be reversed as a condition for the approval of this approval. The text on page 5-82 seems to downplay impact. Impact should not be downplayed.” Response
See response to Comment I-17.21 regarding Segment B impacts.
I-17.24 Comment
Environmental Consequences. Analysis on page 5-82:
“Does not include discussion of the likely major impact on the animal habitat/waterfowl
refuge to the east of the BU Bridge in Cambridge. This directly abuts the Grand
Junction Railroad and Bridge. “Incidental” impact is likely to be major.
Response
This will be reviewed and RDEIR information will be revised as necessary in future
environmental review documents for this project.
I-17.25 Comment
Section 5.15.3.1, affected environment, on page 5-143:
“This section mentions Charles River Reservation but makes no mention of water fowl
habitat/refuge.
“On the Boston side, this section mentions the Charles River Esplanade on the east. It
makes no mention of the meadow bounded by the BU Bridge, the Mass. Pike, the
Grand Junction Railroad and Soldiers Field Road through which would pass the
connector from the highway proposed from the Grand Junction bridge to the
underpass under the BU Bridge.”
Response
This will be reviewed and RDEIR information will be revised as necessary in future
environmental review documents for this project.
I-17.26 Comment
“Table 5-45, Areas of Moderate to Severe Impact in Section B, on page 5-146.
“Sector 6 mentions modifications to Memorial Drive and Grand Junction railroad
bridge.
Group I - Response to Individual Comments
Page 170
RESPONSE TO COMMENTS ON RDEIR “There is no mention whatsoever of the water fowl habitat on either side, between the
BU Bridge and the BU Boathouse and on the south bank of the Charles west of the BU
Bridge.
“The project would be devastating to Charles River Wild Geese and to the many other
geese, ducks and other water birds which use this area as a refuge.”
Response
Future environmental review documents for this project will be reviewed and RDEIR
information will be revised as necessary. EOT will continue to work with the goal of
minimizing environmental impacts in this area.
I-17.27
Comment
Bus proposals:
“It is entirely possible that the bus proposal makes sense outside the Cambridge to
LMA and Allston portion of the proposal, with or without later subway construction. Bus
routing in Cambridge to LMA and Allston portions is quite silly.
“First of all, overlapping bus routes (page2-3) are nothing but overlapping bus routes.
They are not a rapid transit system.”
Response
See response to Comment F-3.2 regarding improvements that will increase BRT bus
travel speeds in mixed traffic.
I-17.28
Comment
Kenmore (Heavy Rail) v. BU Bridge (Light Rail) Crossing:
“There are two possible crossings of the Charles River, the Kenmore Crossing…and the BU Bridge crossing. I suggested the Kenmore Crossing because the BU Bridge crossing is so destructive to the environment of the Charles River, and because of that silly stop in Cambridgeport, the Putnam Avenue/Fort Washington stop. As it has developed, details have come out under which the Kenmore Crossing is increasingly more superior. “The environmental problem is at the Charles River.” Response
See response to Comment I-17.29 regarding the Kenmore Charles River crossing. I-17.29
Comment
Comparison of BU Bridge Crossing to Kenmore Crossing:
• “The connections to the three western Green Line branches would be
accomplished by two stations two blocks from each other instead of one
station which would also connect to commuter rail,
• Commuter rail transfers would be made drastically inferior,
• Support for Fenway Park would be drastically inferior,
• The purpose of the Urban Ring would be drastically degraded because
light rail is incredibly slower than heavy rail, and
• Green Line vehicles would not be able to switch off onto the Orange Line,
providing greatly inferior flexibility of the system.
• The clear inferiority of the BU Bridge crossing is itself and environmental
Group I - Response to Individual Comments
Page 171
RESPONSE TO COMMENTS ON RDEIR •
defect because that inferiority makes this crossing pretty much impossible
to get meaningful riders off the central subway.
…The existing proposal would make the heavy rail subway impossible in
favor of the far inferior light rail subway. This is accomplished by the
highway construction proposed for the BU Bridge area.
“The proposed phase 2 second stop on the busway at the existing Fenway Park
station is duplicative. If the tunnel runs as a heavy rail tunnel to Kenmore/Yawkey, the
money could be much better spent on the really valuable Kenmore station as the
temporary terminus of the Urban Ring subway.
“The proposed portals in the phase 2 proposals are flatly and simply silly.”
Response
The Urban Ring LPA would not use the BU Bridge, but rather the Grand Junction
Railroad bridge.
See response to Comment E-2.10 regarding future steps for the tunnel portion of the
project. As discussed in Attachment 6 of the NPC, there are outstanding issues related
to the areas around portals at either of the tunnel, where construction impacts are
greatest. The complexity of the tunnel engineering and uncertainty surrounding
geotechnical conditions in the Fenway/LMA mean that final alignment and tunneling
method (i.e. tunnel boring machine versus sequential excavation method) would need
to be evaluated in the preliminary engineering and final environmental phases of the
project.
I-17.30 Comment
“Please note that building an initial phase of the Urban Ring subway from Ruggles to
Kenmore would in no way prevent possible extension of the Urban Ring subway to
Dudley or Dorchester.
“Just as a connection to Kenmore/LMA can be accomplished by switches west of
Ruggles, switches east of Ruggles could connect to a spur/Urban Ring subway to
Dudley or Dorchester. The western switch would support traffic to/from Malden,
Downtown Crossing going to/from the LMA/Kenmore. The eastern switch would
support traffic to/from Forest Hills connecting to/from Dudley or Dorchester. Traffic
traveling to/from Dudley or Dorchester to/from the LMA, Kenmore and further Urban
Ring points would simply go through both switches.
“This bus thing is a very expensive, silly one bus stop bus way.”
Response
Comment noted. See response to Comment F-2.1 regarding proceeding directly to rail (Phase 3).
I-17.31 Comment
Allston Proposal
“The proposal is silly, especially when compared to the obvious alternative rapid transit
service.
“Access by Green Line on a spur from the Commonwealth Avenue line at the BU
Bridge and Commonwealth Avenue is simple, relatively inexpensive and highly
efficient…
Group I - Response to Individual Comments
Page 172
RESPONSE TO COMMENTS ON RDEIR “The southern/eastern end of the Green Line spur can readily be constructed, first by
placing switches on the existing Green Line tracks and extending those spurs over the
highway and then over the edge of that bridge…
“The slope of the Mass. Pike south of Cambridge Street is ideal for running the Green
line spur over it.
“Should the Beacon Yards no longer be needed for freight use, the Beacon Yards
could readily be converted to Green Line storage. Access would be easy by a spur run
off the overhead Green Line spur.
“Once gain, failure to propose and study this obvious Green Line spur as an alternative
to the bus nonsense in Allston is an environment defect because the spur would be so
clearly superior to the bus nonsense and could get people out of cars.”
Response
Comment noted. I-17.32 Comment
“I propose… [Comments 1 through 13].
“The environmental destructiveness of the Urban Ring Phase 2 project on the Charles
River is most definitely NOT free standing but fits in with directly related environmental
destruction. Currently, the coordination maximizes environmental destruction.”
Response
Comments listed from 1 through 13 are all related to environmental issues and are
under the jurisdiction of DCR.
EOT will work with the cities, local agencies and stakeholders to provide a Charles
River crossing alignment that will minimize environmental impacts to the greatest
extent possible.
Group I - Response to Individual Comments
Page 173
RESPONSE TO COMMENTS ON RDEIR Letter ID No.: I-18
Received from: Shirley Kressel
March 3, 2009
Comment No.
I-18.1 Comment
“I am writing to express support for the comment letter submitted by Gene Benson,
Alternatives for Community and Environment.”
Response
Comment noted. I-18.2 Comment
“The project is not genuinely concerned with improving services for environmental
justice populations, and is cynically using their presence in the area to justify a project
that will be primarily a convenience for suburban commuters to the local medical and
university institutions. The major cost of the Ring is a bus tunnel, to facilitate
commuters’ access from Ruggles station/parking garage to the Longwood Medical
Area. This will be mirrored to the north by the publicly funded newly improved Yawkey
Way station and a large parking garage planned as part of the Turnpike Air Rights
Parcel 7 Fenway Center project. Longwood Medical Area shuttle buses, transporting
medical center employees to and from these two “inner city” arrival centers, will add to
the air pollution and traffic congestion of this traffic-beleaguered neighborhood. The
Ring has never extended properly into Roxbury’s Dudley Square station, where it
would truly serve the low-income and minority neighborhood; but it is already being
modified to branch into the new Boston expansion of Harvard University.
“When confronted with this misrepresentation, Longwood representatives reply that serving the ‘economic engine’ employees is a worthwhile use of public resources. If this is their argument, it should be open and transparent, and not hidden behind false professions of service to the poor and transit-dependent. The diversion of enormous government resources to this bus tunnel for more convenient commutes (often by automobile) by middle-class suburbanites to urban institutions is not the expressed intent of the project, but it is the underlying purpose - much as the proposed Phase III Silverline connection uses the low-income population’s non-existent desire for a “one-
seat ride to the airport” as a pretext for an express route for Seaport conventioneers to the Back Bay “recreational room” as the Boston Redevelopment Authority once characterized it. “A Supplemental RDEIR should be required to document in detail the benefits of the Urban Ring for environmental justice communities.” Response
See response to Comment F-2.4 regarding environmental justice populations. See response to Comment F-10.12 regarding traffic increases and response to
Comment I-5.1 regarding increased delays. In general, changes in traffic volumes and
traffic delay (and therefore air quality impacts) are minimal.
Urban Ring BRT 7 serves Dudley Station.
See response to Comment G-10.10 regarding the overall benefits of the Urban Ring.
See response to Comments F-2.4 regarding benefits to Environmental Justice
communities.
Group I - Response to Individual Comments
Page 174
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
Comment No.
I-19.1 I-19
Wig Zamore
Undated
Comment
“I want to start by applauding the public transit performance improvements the Urban
Ring brings to the north side of the Mystic River from East Boston through Chelsea and
Everett to Wellington. This will help dense environmental justice populations and
others who have been underserved for decades. Unification of diverse job
opportunities and inner core populations exactly fits the original spirit of the Urban
Ring. It is especially heartening to see this happen in the long neglected north side of
Boston’s core.”
Response
Comment noted. I-19.2 Comment
“The research universities and teaching hospitals are a critical part of the leading edge
economy of the Boston Metropolitan area. Without well-functioning transit to these key
contributors the whole economy of eastern Massachusetts would lose much of its
potential, and the whole world would lose some of its inventiveness. The research
universities in particular are our most important regional human resource. It is critical
that they be integrated with our sustainable future and that the Urban Ring supports
that potential.”
Response
EOT will continue to coordinate with the institutions located within the Urban Ring
corridor to ensure that high level transit service is provided to this area that can
accommodate future transportation demands.
I-19.3 Comment
“There are legitimate questions of equity and finance. The Urban Ring proponents
need to make sure that all geographies and communities served receive fair treatment
relative to one another. Nurses from Chelsea and Roxbury should have just as good
future service from the Urban Ring as PhDs from MIT and Doctors from Harvard. They
have less transportation alternatives and are as important as anyone else to our quality
of life. There may also be a need to investigate significant project financial
contributions from Longwood Medical Area.”
Response
The purpose of the Urban Ring is to provide circumferential transit through densely
developed portions of seven communities and connect with existing MBTA radialoriented service. While the Urban Ring LPA serves many origins-destinations in the
study area and environmental justice areas, no one service can meet every
transportation origin-destination pair.
See response to Comment F-2.4 regarding benefits to Environmental Justice
populations. See response to Comment F-1.2 regarding potential funding options.
Group I - Response to Individual Comments
Page 175
RESPONSE TO COMMENTS ON RDEIR I-19.4 Comment
“I want to emphasize the importance of the Urban Ring in supporting the economic
development potential of eastern Somerville’s former industrial land areas. Of all the
Urban Ring compact communities, Somerville is projected to have by far the greatest
percentage increase in local jobs. Re-development of Assembly Square can support
20,000 new research & development or office jobs. Re-development of the Brickbottom
and Inner Belt areas can also support an additional 20,000 new research &
development or office jobs. Re-development opportunities in the rest of Somerville,
including in Boynton Yards and Union Square, could eventually support up to 10,000
new jobs. In recent years Somerville has received the third highest level of state
financial support per square mile per year, after Chelsea and Lawrence, out of the
Commonwealth’s 351 municipalities. Strategic economic development in eastern
Somerville along the Urban Ring corridor would provide immediate expansion
opportunities for the cramped leading edge economic centers of metro Boston, and
spawn new businesses that could expand across all of eastern Massachusetts as they
evolve and take root. This would be an extraordinary opportunity to waste. Threading
an efficient Urban Ring pathway through eastern Somerville is crucial to a healthy
future metropolitan economy. The alternative is losing both those jobs and our
sustainability.”
Response
The Urban Ring LPA will serve Assembly Square and the Inner Belt area in Somerville,
and nearby Sullivan Square and New Lechmere stations. Previous alignment options
including those to Union Square and Brickbottom were evaluated but were not carried
forward due to alignment and right-of-way constraints in these areas. The Green Line
extension project will be providing service to those locations with light rail train service
and transfer opportunities at New Lechmere Station.
Group I - Response to Individual Comments
Page 176
RESPONSE TO COMMENTS ON RDEIR Letter ID No.:
Received from:
I-20-1 through I-20-6
Individual Letters in Support of Winsor School
January 13, 2009 – February 12, 2009
A total of 100 comment letters from individuals were received in support of the Winsor
School request that the Urban Ring Fenway/LMA tunnel alignment not run under the
Winsor School property and not utilize cut and cover construction methodology.
Responses are provided below, which are applicable to all of these letters, including
the six included for reference in the annotated set of comment letters.
Comment No.
I-20.1 Comment
“I write to support Winsor’s urgent request that the route of the tunnel portion of the
Urban Ring Corridor Phase 2 Project not run under its property and thereby destroy
the operational functioning and educational development of the school.
“Because EOT has already developed two other tunnel route options that achieve the
purposes of the Urban Ring without extensive private property takings, and without
destroying a local nonprofit institution in the heart of Boston, I respectfully request
elimination of the route that cuts through Winsor from further consideration.”
Response
See response to Comment G-12.1 regarding tunnel alignment options. Also, refer to
the NPC Attachment 6 (Section 6.2.2) regarding the implementation strategy for major
infrastructure elements of the project such as the Fenway/LMA tunnel.
I-20.2 Comment
“I urge selection of a construction methodology other than the cut-and-cover method
because of the immensely adverse environmental impact of the cut-and-cover method
on Winsor and the LMA generally.”
Response
The final tunnel construction methodology has not yet been determined, but the
RDEIR/DEIS states that the cut-and-cover method is not under consideration as the
principal tunnel construction method. See response to Comment G-12.4 regarding
tunnel construction methodology.
Group I - Response to Individual Comments
Page 177
COMMENTS ON RDEIR Comment Letters
Urban Ring Phase 2 RDEIR Notice of Project Change
June 2009
A-1
A-1.1
A-1.2
A-1.3
A-1.3
A-1.4
A-1.5
A-1.6
A-1.7
A-1.8
A-1.9
A-1.9
A-1.10
A-1.11
A-1.12
A-1.13
A-1.14
Letter B-1
B-1.1
B-1.2
B-1.3
B-1.3
B-1.4
B-1.5
B-1.6
B-1.7
B-1.8
Letter C-1
C-1.1
C-1.2
C-1.3
C-1.4
C-1.5
C-1.2
C-1.6
C-1.7
C-1.7
Letter C-2
C-2.1
C-2.2
C-2.2
C-2.3
C-2.4
Letter C-3
C-3.1
Letter C-4
C-4.1
Letter C-5
C-5.1
C-5.2
C-5.3
Letter C-6
C-6.1
C-6.1
C-6.2
C-6.3
Letter D-1
D-1.1
D-1.1
D-1.1
D-1.1
D-1.2
D-1.3
D-1.3
D-1.4
D-1.4
D-1.5
D-1.6
Letter D-2
D-2.1
D-2.2
D-2.3
D-2.3
D-2.4
D-2.5
D-2.6
D-2.7
D-2.8
D-2.9
D-2.10
D-2.11
D-2.11
D-2.12
D-2.13
D-2.14
D-2.15
D-2.16
D-2.2
D-2.17
D-2.18
D-2.18
D-2.18
D-2.5
D-2.19
D-2.20
D-2.21
D-2.22
D-2.4
Letter D-3
D-3.1
D-3.1
D-3.2
D-3.2
Letter E-1
E-1.1
E-1.1
E-1.2
E-1.3
E-1.4
E-1.4
Letter E-2
E-2.1
E-2.2
E-2.2
E-2.3
E-2.4
E-2.5
E-2.5
E-2.6
E-2.7
E-2.7
E-2.8
E-2.8
E-2.9
E-2.10
E-2.11
E-2.11
E-2.12
Letter E-3
E-3.1
E-3.1
E-3.1
E-3.2
E-3.3
E-3.4
E-3.5
E-3.6
E-3.7
E-3.7
E-3.8
E-3.9
E-3.10
E-3.10
E-3.11
E-3.12
E-3.13
E-3.14
E-3.15
E-3.16
E-3.17
E-3.18
E-3.19
E-3.20
E-3.20
E-3.21
E-3.22
Letter E-4
E-4.1
E-4.1
E-4.1
E-4.1
E-4.1
E-4.2
E-4.3
E-4.3
E-4.4
E-4.5
E-4.6
E-4.7
Letter E-5
E-5.1
Letter E-6
E-6.1
E-6.2
E-6.3
E-6.4
E-6.5
E-6.6
E-6.7
E-6.8
E-6.9
E-6.10
E-6.11
Letter E-7
E-7.1
E-7.1
E-7.1
Letter E-8
E-8.1
Letter E-9
E-9.1
E-9.2
E-9.3
E-9.4
E-9.5
E-9.6
E-9.7
E-9.8
E-9.9
E-9.10
E-9.11
Letter F-1
F-1.1
F-1.2
F-1.2
F-1.3
F-1.1
F-1.1
F-1.2
F-1.2
F-1.3
Letter F-2
F-2.1
F-2.1
F-2.1
F-2.2
F-2.2
F-2.2
F-2.3
F-2.3
F-2.3
F-2.3
F-2.4
F-2.4
F-2.4
F-2.4
F-2.4
Letter F-3
F-3.1
F-3.2
F-3.3
F-3.4
F-3.5
Letter F-4
F-4.1
F-4.2
F-4.3
Letter F-5
F-5.1
F-5.2
F-5.3
F-5.4
F-5.4
F-5.4
F-5.4
F-5.5
F-5.6
Letter F-6
F-6.1
F-6.1
F-6.1
F-6.1
F-6.1
F-6.1
Letter F-7
F-7.1
F-7.2
F-7.3
F-7.4
F-7.4
F-7.5
Letter F-8
F-8.1
F-8.1
Letter F-9
F-9.1
F-9.2
F-9.3
Letter F-10
F-10.1
F-10.2
F-10.2
F-10.3
F-10.4
F-10.5
F-10.6
F-10.6
F-10.7
F-10.8
F-10.9
F-10.10
F-10.11
F-10.12
F-10.13
F-10.14
F-10.15
F-10.16
F-10.17
F-10.18
Letter F-11
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.1
F-11.2
Letter F-12
F-12.1
F-12.1
F-12.1
F-12.1
Letter G-1
G-1.1
G-1.2
G-1.3
G-1.4
G-1.5
G-1.6
G-1.7
G-1.8
G-1.9
Letter G-2
G-2.1
Letter G-3
G-3.1
G-3.2
G-3.3
G-3.4
G-3.5
Letter G-4
G-4.1
G-4.2
G-4.3
G-4.3
G-4.3
G-4.4
G-4.5
Letter G-5
G-5.1
G-5.1
G-5.1
Letter G-6
G-6.1
G-6.2
G-6.3
G-6.4
G-6.5
G-6.6
G-6.7
G-6.8
G-6.9
G-6.10
G-6.10
G-6.11
G-6.12
G-6.12
G-6.12
G-6.12
G-6.13
G-6.14
G-6.15
Letter G-7
G-7.1
G-7.2
G-7.2
G-7.2
G-7.3
G-7.4
G-7.5
G-7.6
G-7.7
G-7.8
G-7.9
G-7.10
G-7.11
G-7.12
G-7.13
G-7.14
G-7.15
G-7.16
G-7.17
G-7.17
G-7.18
G-7.19
G-7.20
G-7.21
G-7.22
G-7.22
G-7.22
G-7.23
Letter G-8
G-8.1
G-8.1
G-8.1
G-8.2
G-8.2
G-8.2
G-8.3
G-8.4
G-8.5
G-8.6
G-8.7
G-8.5
G-8.8
G-8.9
G-8.10
G-8.10
G-8.10
G-8.10
G-8.10
G-8.10
G-8.11
G-8.11
G-8.11
G-8.12
G-8.12
Letter G-9
G-9.1
G-9.1
G-9.2
G-9.3
Letter G-10
G-10.1
G-10.1
G-10.1
G-10.2
G-10.2
G-10.3
G-10.3
G-10.4
G-10.4
G-10.4
G-10.5
G-10.6
G-10.7
G-10.6
G-10.6
G-10.6
G-10.8
G-10.9
G-10.9
G-10.9
G-10.10
G-10.11
G-10.12
G-10.9
G-10.12
G-10.2
Letter G-11
G-11.1
G-11.2
G-11.3
G-11.4
G-11.5
G-11.6
G-11.7
G-11.8
G-11.9
G-11.10
G-11.11
Letter G-12
G-12.1
G-12.1
G-12.1
G-12.1
G-12.2
G-12.2
G-12.2
G-12.1
G-12.1
G-12.1
G-12.3
G-12.3
G-12.1
G-12.4
G-12.1
G-12.1
G-12.5
G-12.4
G-12.6
G-12.7
G-12.7
Letter H-1
H-1.1
H-1.1
H-1.2
H-1.3
H-1.4
Letter H-2
H-2.1
H-2.2
Letter H-3
H-3.1
H-3.1
Letter I-1
I-1.1
I-1.2
I-1.4
I-1.3
I-1.4
I-1.5
Letter I-2
I-2.1
I-2.2
I-2.3
I-2.3
I-2.4
I-2.4
I-2.5
I-2.5
I-2.6
I-2.6
I-2.7
I-2.7
I-2.7
I-2.8
I-2.9
I-2.10
I-2.10
I-2.11
I-2.11
I-2.11
I-2.11
I-2.11
I-2.12
I-2.12
I-2.13
I-2.13
I-2.13
I-2.14
I-2.14
I-2.15
I-2.16
I-2.16
I-2.16
I-2.17
I-2.10
I-2.3
I-2.4
I-2.17
Letter I-3
Letter I-4
I-4.1
I-4.1
Letter I-5
I-5.1
I-5.1
I-5.1
Letter I-6
I-6.1
I-6.2
I-6.3
I-6.3
Letter I-7
I-7.1
I-7.2
I-7.2
I-7.3
I-7.4
I-7.5
I-7.6
Letter I-8
I-8.1
I-8.1
I-8.1
Letter I-9
I-9.1
I-9.2
I-9.3
I-9.4
I-9.4
I-9.4
I-9.5
I-9.5
I-9.6
Letter I-10
I-10.1
I-10.1
I-10.2
I-10.2
I-10.3
I-10.3
I-10.4
I-10.4
I-10.4
I-10.4
I-10.5
I-10.5
I-10.5
I-10.5
I-10.5
I-10.5
I-10.6
I-10.6
I-10.7
I-10.8
I-10.8
I-10.8
I-10.9
I-10.9
I-10.9
I-10.10
I-10.11
I-10.12
I-10.12
I-10.13
I-10.14
I-10.14
I-10.15
I-10.15
I-10.16
I-10.16
Letter I-11
I-11.1
I-11.2
I-11.3
I-11.4
I-11.5
I-11.6
I-11.7
I-11.8
I-11.9
I-11.10
I-11.11
I-11.12
I-11.13
I-11.14
I-11.15
I-11.16
I-11.16
I-11.16
I-11.17
I-11.18
I-11.19
I-11.20
Letter I-12
I-12.1
I-12.1
I-12.2
I-12.2
I-12.2
Letter I-13
I-13.1
I-13.1
I-13.1
I-13.2
I-13.3
I-13.4
I-13.5
I-13.5
I-13.6
Letter I-14
I-14.1
I-14.1
I-14.2
I-14.3
I-14.3
I-14.4
I-14.4
I-14.5
Letter I-15
I-15.1
I-15.1
I-15.2
I-15.2
I-15.2
I-15.2
I-15.3
Letter I-16
I-16.1
I-16.2
Letter I-17
I-17.1
I-17.2
I-17.3
I-17.3
I-17.3
I-17.3
I-17.3
I-17.3
I-17.4
I-17.4
I-17.4
I-17.4
I-17.5
I-17.5
I-17.5
I-17.5
I-17.6
I-17.6
I-17.7
I-17.7
I-17.7
I-17.7
I-17.8
I-17.8
I-17.8
I-17.8
I-17.8
I-17.8
I-17.8
I-17.9
I-17.10
I-17.10
I-17.10
I-17.10
I-17.10
I-17.10
I-17.10
I-17.10
I-17.11
I-17.12
I-17.12
I-17.12
I-17.12
I-17.12
I-17.12
I-17.12
I-17.13
I-17.14
I-17.14
I-17.14
I-17.14
I-17.14
I-17.15
I-17.16
I-17.16
I-17.16
I-17.16
I-17.17
I-17.17
I-17.17
I-17.17
I-17.18
I-17.19
I-17.19
I-17.19
I-17.20
I-17.21
I-17.21
I-17.22
I-17.22
I-17.22
I-17.22
I-17.23
I-17.23
I-17.23
I-17.24
I-17.24
I-17.24
I-17.25
I-17.25
I-17.25
I-17.26
I-17.26
I-17.26
I-17.26
I-17.27
I-17.27
I-17.27
I-17.28
I-17.28
I-17.28
I-17.28
I-17.29
I-17.29
I-17.29
I-17.29
I-17.29
I-17.29
I-17.29
I-17.29
I-17.29
I-17.30
I-17.30
I-17.31
I-17.31
I-17.31
I-17.31
I-17.31
I-17.31
I-17.31
I-17.31
I-17.32
Letter I-18
I-18.1
I-18.2
I-18.2
I-18.2
Letter I-19
I-19.1
I-19.2
I-19.3
I-19.4
I-19.5
Letter I-20
List of Comments Received in Support of the Winsor School Board of Trustees and
Director’s Letter (Listed by date included on the letter) 0. 01/13/09 Patricia Murray I-20-1
1. 01/13/09 Deborah Hill Bornheimer 2. 01/13/09 Michelle Riffelmacher 3. 01/13/09 William P. Collatos 4. 01/13/09 Ellen T. Giannuzzi, Esq. 5. 01/13/09 Kimberly Heald Krawshuk 6. 01/13/09 Peggy O’Brien Eysenbach 7. 01/13/09 Bridgitt Evans 8. 01/13/09 Jane Brock­Wilson 9. 01/13/09 Saul J. Pannell 10. 01/13/09 Margaret C. Bell 11. 01/13/09 Sasha E. Polonsky I-20-2
12. 01/14/09 Clarissa J. Marshall 13. 01/14/09 Julia Harrison 14. 01/14/09 Margaret P. Mazzucco 15. 01/14/09 Sharon R. Gorberg 16. 01/14/09 Sloan Sable 17. 01/14/09 Courtney Jackson 18. 01/14/09 Gloria W. Coren 19. 01/14/09 Xiaodong Zhao 20. 01/14/09 Sarah Macauley 21. 01/14/09 Lauren E. Martin 22. 01/14/09 Caitlin Blois 23. 01/14/09 Laura I. Antuna 24. 01/14/09 Jill Valle 25. 01/14/09 Robert J. Walsh 26. 01/14/09 Thomas I. Wensink 27. 01/14/09 Lisa Soltani 28. 01/14/09 Midlaine S. Baker 29. 01/14/09 Robin Ryan 30. 01/14/09 Karen Geromini 31. 01/14/09 Valentina Paez 32. 01/14/09 Laura Bravo Melguizo 33. 01/14/09 James E. Jer­Don 34. 01/14/09 Linda Hansen 35. 01/14/09 Geneva Tiggle 36. 01/14/09 Maeve McHenry 37. 01/14/09 Jennifer L. Toon 38. 01/14/09 Patricia Carver 39. 01/14/09 Susanna Ryan 40. 01/14/09 Aneiage Van Bean 41. 01/14/09 Jacquelyne E. Arrington 42. 01/14/09 Kate Groetzinger 43. 01/14/09 44. 01/14/09 45. 01/14/09 46. 01/14/09 47. 01/14/09 48. 01/14/09 49. 01/14/09 50. 01/14/09 51. 01/14/09 52. 01/14/09 53. 01/14/09 54. 01/14/09 55. 01/14/09 56. 01/14/09 57. 01/14/09 58. 01/14/09 59. 01/14/09 60. 01/15/09 61. 01/16/09 62. 01/16/09 63. 01/16/09 64. 01/16/09 65. 01/16/09 66. 01/16/09 67. 01/18/09 68. 01/19/09 69. 01/19/09 70. 01/20/09 71. 01/20/09 72. 01/20/09 73. 01/20/09 74. 01/20/09 75. 01/20/09 76. 01/20/09 77. 01/21/09 78. 01/21/09 79. 01/21/09 80. 01/21/09 81. 01/21/09 82. 01/22/09 83. 01/23/09 84. 01/27/09 85. 01/28/09 86. 01/29/09 87. 02/01/09 88. 02/02/09 Alice F. Stern Laura Houlette Jennifer Ciccarelli Sally A. Hatcher Andrea Chase Sharon J. Eby Christophe de Bord Leslie Smith Lisa Taillacq Helen C Goldberg Adelbert Spitzer Roger T. Servison Jane Hoeffel Otte Rebecca Rice Thomas J. Flanagan Libby Parsley LP Nash Perry M. Traquina Eugene H. Pool Tiffany Young Kaitlin K. Yaremchuk* I-20-3
Maria Minkoff Helen Schultz Lauren Conway­Russell Jennifer S. Skeele Marion Kilson Dorian Bowman Lynn Randall Elisabeth Peterson Leslie Bernstein D Higgins Thompson Katherine Lee Cole Michael S. Gordon Kate Connolly Chris A. Kauth Julia C. Livingston Katharine T. Baker­Carr Adrienne M. Penta Emilie Kaulbach Kendall Jennifer Reardon Cheryl Alexander Mark Edwards Pamela S. Henrikson Ethel McFarlan Hamann Susannah Barton Tobin Anne N Robertson 89. 02/02/09 90. 02/03/09 91. 02/04/09 92. 02/04/09 93. 02/04/09 94. 02/04/09 95. 02/08/09 96. 02/08/09 97. 02/08/09 98. 02/08/09 99. 02/12/09 Lee T. Sprague Joseph J. O’Donnell I-20-4
Carol G. Deane* Anne Ruggles Anne Deane I-20-5
John M. Westcott, Jr I-20-6
Al Kerry P. Brennan Zwic Cohee Bridgett Br Cornelia Hurley McPeek Italicized names were not clearly legible.
Letter I-20-1
I-20.1
I-20.1
I-20.2
Letter I-20-2
I-20.1
I-20.1
I-20.2
Letter I-20-3
I-20.1
I-20.1
I-20.2
Letter I-20-4
I-20.1
I-20.1
I-20.2
Letter I-20-5
I-20.1
I-20.1
I-20.2
Letter I-20-6
I-20.1
I-20.1
I-20.2