Massachusetts Department of Transportation Department of Transportation Massachusetts Bay...

Massachusetts Department of Transportation Massachusetts Bay Transportation Authority

State Implementation Plan – Transit Commitments 2012 Status Report

Agency Responses to Public Comments

Submitted to the Massachusetts Department of Environmental Protection

January 23, 2013 For questions on this document, please contact: Massachusetts Department of Transportation Office of Transportation Planning 10 Park Plaza, Room 4150 Boston, Massachusetts 02116 [email protected] (857) 368-9800

Ten Park Plaza, Suite 4160, Boston, MA 02116

Tel: 857-368-4636, TDD: 617-973-7306

www.mass.gov/massdot Leading the Nation in Transportation Excellence

January 23, 2013 Kenneth L. Kimmell Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Dear Commissioner Kimmell:

Pursuant to Section 7 of amended 310 CMR 7.36, Transit System Improvements, please find enclosed our responses to public comments on the annual Status Report on transit projects required under the revised State Implementation Plan (submitted to the Department of Environmental Protection on July 22, 2012). Section 7 requires the Massachusetts Department of Transportation to file a summary of all public comments and written responses to those comments within 120 days of the public meeting also required by Section 7. A public meeting was held by DEP on September 18, 2012.

This status report will be made publicly available on the MassDOT website at

http://www.massdot.state.ma.us/SIP. If you have any questions or concerns or if we can be of assistance, please do not

hesitate to contact me at (857) 368-8865 or [email protected].

Sincerely,

David J. Mohler Executive Director Office of Transportation Planning

cc: U.S. Environmental Protection Agency, Region 1 Boston Region Metropolitan Planning Organization

http://www.massdot.state.ma.us/SIP

mailto:[email protected]

Ten Park Plaza, Suite 4160, Boston, MA 02116

Tel: 857-368-4636, TDD: 617-973-7306

www.mass.gov/massdot Leading the Nation in Transportation Excellence

State Implementation Plan – Transit Commitments

2012 Annual Status Report

Agency Responses to Public Comments

I. MassDOT Certification II. List of Public Comments Received

III. Agency Responses to Public Comments

IV. 2012 Annual Status Report

V. Public Comments a. Oral Testimony b. Emails & Letters

COMMONWEALTH OF MASSACHUSETTS

MASSACHUSETTS DEPARTMENT OF TRANSPORTATION

OFFICE OF TRANSPORTATION PLANNING

MEMORANDUM

TO: Kenneth L. Kimmell

Commissioner

Department of Environmental Protection

FROM: David J. Mohler

Executive Director

MassDOT Office of Transportation Planning

DATE: January 23, 2013

RE: 310 CMR 7.36 (7)(c)

This memo is intended to fulfill the reporting requirements of 310 CMR 7.36 (7)(c), in which the

Massachusetts Department of Transportation must attest that:

MassDOT has provided complete information for all requirements of 310 CMR 7.36 (7)(a).

MassDOT has provided complete information about any actual or known potential need and

reasons to delay any project required by 310 CMR 7.36(2)(f) through (j).

MassDOT has provided complete information about any actual or known potential need and

reasons for a project substitution pursuant to 310 CMR 7.36(4)(b).

MassDOT has provided complete information on the interim offset projects implemented or

proposed to be implemented pursuant to 310 CMR 7.36(4)(b) and (5)(g)4.

I certify that all of the information listed above has been provided and that MassDOT has, to the best of

its ability, fulfilled all public process and reporting requirements described in 310 CMR 7.36 (7).

__________________________________________

David J. Mohler

Executive Director

MassDOT Office of Transportation Planning

Comments Received on the MassDOT 2012 Annual SIP Status Report (by format and date)

Date Title First Name Last Name Affiliation Additional Authors9/18/2012 Bill Deignan City of Cambridge9/18/2012 Stephen Kaiser Association of Cambridge Neighborhoods9/18/2012 Ken Krause9/18/2012 Staff Attorney Rafael Mares Conservation Law Foundation9/18/2012 Alan Moore Friends of the Community Path9/18/2012 Representative Denise Provost Massachusetts House of Representatives9/18/2012 Ellin Reisner Somerville Transportation Equity Partnership9/18/2012 Carolyn Rosen Green Line Advisory Committee for Medford9/18/2012 William Wood Green Line Advisory Committee for Medford9/18/2012 Wig Zamore

Date Title First Name Last Name Affiliation Additional Authors

9/18/2012 Green Line Advisory Committee for MedfordCarolyn Rosen, William Wood, Neil Osborne, Gwen Blackburn, Paul Morrissey, Mary Anne Adduci, Henry Milorin, Bernie Green, Felix Blackburn

9/18/2012 Ellin Reisner Somerville Transportation Equity Partnership9/23/2012 President Neil Osborne Mystic Valley Area Branch NAACP9/24/2012 Staff Attorney Rafael Mares Conservation Law Foundation9/25/2012 Friends of the Community Path Alan Moore, Lynn Weissman9/25/2012 President Richard Dimino A Better City9/25/2012 Ken Krause9/25/2012 Paul Morrissey Aero Cycle9/25/2012 Representative Denise Provost Massachusetts House of Representatives9/25/2012 Ellin Reisner Vig Kishnamurthy, Jim McGinnis, Karen Molloy9/25/2012 Fred Salvucci

Oral Testimony

Written Testimony

Massachusetts Department of Transportation Massachusetts Bay Transportation Authority

State Implementation Plan - Transit Commitments

2012 Annual Status Report Agency Responses to Public Comments

Submitted to the Massachusetts Department of Environmental Protection

January 23, 2013

For questions on this document, please contact: Massachusetts Department of Transportation Office of Transportation Planning 10 Park Plaza, Room 4150 Boston, Massachusetts 02116 [email protected] (857) 368-9800

Massachusetts Department of Transportation January 23, 2013

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INTRODUCTION This document summarizes and responds to public comments received by the Massachusetts Department of Transportation (MassDOT) on the State Implementation Plan-Transit Commitments 2012 Annual Status Report (the Status Report) submitted to the Massachusetts Department of Environmental Protection (DEP) on July 2, 2012 in order to fulfill the requirements of 310 CMR 7.36, Transit System Improvements. The Status Report detailed the status of four public transit projects – listed below – required of MassDOT under 310 CMR 7.36. The projects are:

Fairmount Line Improvement Project Construction of 1,000 New Commuter Parking Spaces Red Line/Blue Line Connector - Final Design Green Line Extension to Somerville and Medford

MassDOT accepted public comments on the Status Report through September 24, 2012, following a public meeting (September 18, 2012) at which staff from MassDOT presented an overview of the contents of the Status Report and members of the public asked questions and provided feedback and comments. The majority of the comments received by MassDOT pertained to the extension of the Green Line to Somerville and Medford, although comments were also received on the other State Implementation Plan (SIP) projects, as well as on other non-SIP issues. MassDOT has reviewed all of the comments received – they are appended here in full, as is a list of all of the submitting individuals and organizations – and has grouped and summarized them so as to capture the salient ideas while reducing redundancy and overlap. In this document, indication of the authorship of each comment has been omitted. Each year, MassDOT receives comments and questions in response to the Status Report that are similar to comments and questions received in past years. When that happens, MassDOT will often refer the commentator back to an earlier response or, if the issue has changed in some meaningful way, will clarify and update earlier responses as appropriate. Throughout this document, the SIP regulation (310 CMR 7.36) is referenced. Additional information and detail on the regulation (310 CMR 7.36) can be viewed at: http://www.massdot.state.ma.us/SIP. Project Updates For the latest status of the SIP projects, please see the most recent monthly SIP status reports, which can be found online at: http://www.massdot.state.ma.us/SIP. Public Input The projects described in the Status Report each have public input processes associated with them, but the public process associated with the SIP itself provides an additional opportunity for MassDOT and the MBTA to hear from interested individuals and organizations about the




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progress and direction of our projects. This is a valuable reminder that our projects serve real people in real communities, and we strive to shape our efforts to meet the needs of the users of the transportation network, both present and future. At the same time, the framework of the SIP obliges us to retain a regional perspective and to understand that the portfolio of projects mandated under the SIP is intended to work together to bring benefits to the Boston Metropolitan Region as a whole. Furthermore, MassDOT and the MBTA must always be sensitive to the overall constrained fiscal climate of both the MBTA and the Commonwealth. Interim Offset Mitigation Measure Recommendations Many of the comment letters submitted in response to the Status Report included suggestions for interim offset mitigation measures to compensate for the delayed implementation of the Green Line Extension project and the Fairmount Line Improvement Project. MassDOT appreciates that there is substantial public interest in the selection of appropriate interim mitigation measures. The proposed measures for the Green Line Extension project are being considered by MassDOT and will be discussed as part of a separate public process. More information about the ongoing process of determining appropriate mitigation for the Green Line Extension project can be found at: http://www.greenlineextension.org/documents.html. Project Completion As discussed in the annual report and monthly status reports, MassDOT considers the requirement to construct 1,000 new parking spaces as part of 310 CMR 7.36 to have been completed with the opening of Wonderland Garage on June 30, 2012. Comments from the annual report are addressed in this document, but MassDOT will cease reporting on the parking space commitment going forward.

http://www.greenlineextension.org/documents.html


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I. GENERAL COMMENTS The failure to modernize all Blue Line stations is a continuing violation of the SIP, which

required that Blue Line station modernization be completed by 2008. MassDOT previously addressed this issue in 2010. See: http://www.eot.state.ma.us/downloads/sip/SIP_CommentResponses011110.pdf.

DEP is unable to effectively police MassDOT on the implementation of the SIP projects. MassDOT previously addressed this issue in 2011: MassDOT feels that the partnership currently in place between the two agencies is an effective one for advancing the SIP projects during a challenging fiscal time.

SIP projects should be funded by the Commonwealth, not by the MBTA. As the SIP projects are commitments of the Commonwealth, they are funded using Commonwealth funds (not MBTA funds). The Massachusetts Legislature has authorized MassDOT to create and use an account funded with Commonwealth bond monies to support the costs of the SIP projects. Funds dedicated to the MBTA, whether state or federal, are not used to support the capital costs of the SIP projects.

Investment in the SIP projects comes at the expense of the service quality and system-wide condition of existing MBTA infrastructure. MassDOT previously addressed this issue in 2011: The use of non-MBTA Commonwealth monies to fund the development and implementation of the SIP projects means that no existing MBTA funds are diverted from routine investment in the core MBTA system to support the expansions called for in the SIP.

We remain concerned about the escalation of project delays, and the lack of urgency expended by MassDOT in addressing these delays. MassDOT and the MBTA have been, and continue to work tirelessly to complete the elements of the SIP commitment, and to minimize delays. At this point, many elements are fully complete, including the entire 1,000 parking space commitment, and several new elements of the Fairmount corridor. Many of the project delays have been caused by circumstances outside of MassDOT’s control, such as the ongoing neighborhood discussion about station locations at Blue Hill Avenue. While the Green Line Extension is significantly delayed, MassDOT and the MBTA have been upfront and open about the sources and effects of the delay, and are working as expeditiously as possible to begin service. In Summer 2011, responding to a program-wide risk assessment that extended the project’s completion date to the 2018-2020

http://www.eot.state.ma.us/downloads/sip/SIP_CommentResponses011110.pdf


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timeframe from the previously anticipated late 2015 completion date, the GLX team proposed and then implemented a project phasing plan that:

(1) Commenced construction in 2012, (2) Established an interim completion target of Green Line service operation

from the relocated Lechmere Station to new stations at Union Square and Washington Street in Somerville,

(3) Targeted final completion of the project in 2018 – 2020, depending on the project’s ability to mitigate the identified risks to cost and schedule, and

(4) Proposed the use of a Construction Manager/General Contractor (CM/GC) approach on latter phases of the project to provide flexibility in meeting and overcoming the identified risks in a timely manner. This approach required legislative, MBTA Board and Office of Inspector General approval.

Since then, the project awarded (in December 2012) its first construction contract, received key FTA environmental (Finding of No Significant Impact) and process (Permission to Enter Preliminary Engineering) approvals, commenced the procurement of a CM/GC (after an extended series of approval steps), and issued a Notice to Proceed for GLX Advanced Preliminary Engineer/Final Designer. The interim completion date for item 2 (above) remains on track for early 2017, even as the final FTA funding approval (Full Funding Grant Approval) is, according to the current FTA roadmap, not expected until February 2015 (It is possible that some limited work activities can be permitted to proceed prior to the Grant Approval, with FTA concurrence). Finally, overall completion remains on-schedule to complete in the 2018-2020 timeframe. MassDOT and the MBTA are working towards program milestones while maintaining required compliance with the FTA’s approval dates to maintain the possibility of federal funding participation.

The proposed Green Line Extension terminus at College Avenue in Medford does not meet the SIP requirement for the Green Line to be extended to ‘Medford Hillside.’ MassDOT and the MBTA are therefore in violation of the SIP. MassDOT previously addressed this issue in 2011: As we have stated before, MassDOT and the MBTA feel confident not only that College Avenue offers the best balance of benefits and impacts of any potential station location in the immediate area of ‘Medford Hillside,’ but that it also fulfills the commitment by the Commonwealth for the Green Line Extension to reach ‘Medford Hillside’ and to serve the ‘Medford Hillside’ neighborhood. MassDOT believes that a terminus at College Avenue not only serves the ‘Medford Hillside’ area but also promises to draw riders to the Green Line and create a sense of place at the new station. In addition, the impacts of the station can be effectively mitigated at that location, a location which has the support of the City of Medford (unlike other proposed locations in the area). Furthermore, the need to acquire property at this location is minimal.


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The current design for the College Avenue Station acknowledges its role as a gateway to both the adjacent Medford residential neighborhoods and to Tufts University. The station will create an active use at the intersection of Boston and College Avenues, incorporating a South-facing plaza that will provide a gathering place for neighbors, students and transit riders. The scale of the station headhouse will respect the character of the residential buildings in nearby neighborhoods with its modest size and simple detail. A pedestrian walkway will link the Station’s entry plaza to the nearby Burget Avenue neighborhood, and an accessible drop-off/pick-up area will be located along the Boston Avenue edge. The selection of materials for fencing, walls, paving and limited seating and planted areas will be sensitive to the area’s context and will be utilized to reinforce the location of station entry points and support overall wayfinding in the station area. The position of MassDOT and the MBTA on the ‘Medford Hillside’ issue is supported and has been reinforced by multiple regulatory agencies responsible for overseeing the SIP, including the Massachusetts Department of Environmental Protection. The current project configuration has also been embraced by the Federal Highway Administration, Federal Transit Administration, and U.S. Environmental Protection Agency in their approval of the Regional Transportation Plan for the Boston Region Metropolitan Organization (November 30, 2011). For all of these reasons, we believe that a College Avenue terminus meets the goals and intentions of the SIP. The Green Line Extension to Union Square and to College Avenue is the Green Line Extension that MassDOT and the MBTA are implementing now. In addition, the Boston Region MPO voted in June 2012 to add funding to design of the Mystic Valley Parkway/Route 16 station. This funding becomes available in 2016, and MassDOT and the MBTA will begin working on this effort as that timeframe draws closer.

Vehicle Miles Traveled (VMT) is not the best measure of air quality conformity. Consider using Vehicle Hours Traveled (VHT) instead. MassDOT previously addressed this issue in 2011: The current state of the practice for calculating on-road emissions, and the only method currently approved by the relevant state and federal environmental agencies (DEP and the U.S. Environmental Protection Agency), is to use the US EPA Mobile 6.2 emissions modeling software. Mobile 6.2 makes use of inputs developed locally by DEP. The Mobile 6.2 method involves using estimates of vehicle miles of travel (VMT) and the corresponding MOBILE 6 emission factor, as mapped according to speed, roadway type, vehicle type, and time period. Mobile 6.2 is used to generate a ‘look up’ table mapped to the congested speed and other pertinent characteristics of roadway segments and incorporate that information into its emissions calculations. Emissions are then


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calculated by multiplying the VMT data by an emissions factor as shown in the following equation:

Emissions = VMT * EF * K Where: Emissions = emissions in tons by roadway type and vehicle type VMT = vehicle miles traveled by roadway type and vehicle type EF = emission factor in grams/mile by roadway type and vehicle type K = conversion factor

Vehicle Hours of Travel (VHT) is a function of both the VMT and the congested speed on a particular roadway segment. The congested speed is used to determine a vehicles path through the roadway system and the resulting VMT generated along that path is measured on a segment by segment basis. Thus, a calculation of VMT indirectly includes a calculation of VHT in the analysis of emissions. However, based on the current regulatory guidance and the available emissions modeling software, we are obligated to use VMT and congested speeds as independent factors as the means to develop emissions estimates. The method of estimating VMT by the factors listed above has been used since 1978 and will continue to be used by US EPA in their new emissions model called ‘MOVES.’ Barring any new guidance from US EPA and/or DEP, the Boston Region Metropolitan Planning Organization will continue to use this method, which is widely applied and has been thoroughly tested.


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II. FAIRMOUNT LINE IMPROVEMENT PROJECT [We] respectfully request that DEP require the inclusion of a reduction of fares as one of

the interim emission offset measures to counter the negative impacts of the delays in the implementation of the Fairmount Line Improvement project. As part of the process of identifying appropriate interim offset measures for the Fairmount Line Improvement project, MassDOT analyzed the impacts on regional air quality of reducing existing fares for the Fairmount and Readville stations on the Fairmount Line. While the air quality impacts were indeed positive and beneficial and the reduction would have made sense in certain ways, the associated reduction in fare revenue for the MBTA system made it untenable as an interim emission offset measure for MassDOT to propose. Furthermore, another concern for the MBTA is that such a localized modification of fare policy could result in an inconsistent fare structure on the Commuter Rail system, something the MBTA has worked hard to avoid. MassDOT prepared a Petition to Delay and an Interim Emission Offset Plan for the Fairmount Line Improvement Project, to be implemented for the duration of the delay. Both the Petition and Offset Plan were submitted to DEP, and posted to MassDOT’s SIP website. MassDOT estimated the reduced emissions expected to be generated by the implementation of the new Fairmont Line stations. MassDOT and the MBTA, in consultation with Fairmount Line stakeholders, identified a set of potential interim emission reduction offset measures that would meet the emissions reduction targets. On January 2, 2012, the offset measures were implemented: additional trips via a dedicated shuttle on the CT3 bus route between Andrew Station and Boston Medical Center; and increased weekday frequency on the Route 31 bus. These measures are still ongoing, and will continue during the length of the delay.


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III. CONSTRUCTION OF 1,000 NEW PARKING SPACES In order to comply with the SIP requirement, one thousand additional parking spaces

have to be constructed rather than merely provided. MassDOT previously addressed this issue in 2011: MassDOT recognizes that the text of the SIP regulation (310 CMR 7.36) uses the term ‘construction’ to refer to the creation of 1,000 new park and ride parking spaces. However, the intention of the SIP regulation is to provide transportation alternatives that make it possible for individuals to travel in such a way that will reduce the overall production of air pollutants. The point of providing 1,000 new park and ride parking spaces is to encourage greater use of the public transit network by encouraging motorists to park their cars at remote locations and then board public transit to complete their trips. Whether the spaces are ‘constructed’ or ‘provided’ matters much less than whether they exist and serve their purpose, which is the focus of MassDOT’s efforts. There are many benefits to providing surface-level parking lots rather than major parking structures that require substantial construction: parking lots are less expensive, more flexible, avoid many of the negative environmental impacts associated with the construction of a parking garage, and can provide the opportunity for future higher-use development on the same sites, development that could be adjacent to public transit nodes and could provide underground or other types of parking.

Due to the multi-use nature of the Waterfront Square development at Wonderland, the number of parking spaces actually available for users of the MBTA’s public transit system will be smaller than predicted and promised, and therefore too small to contribute to SIP compliance. MassDOT understands this concern, and has been proactive in addressing it. The MBTA has worked closely with the private developer over the lifespan of this project, and has entered into an agreement that specifies the number of spaces that will be available for transit users. As the plans for the private development around Wonderland Station are not yet finalized, nor is the private development project in construction, this agreement will not be an issue for the short-term. Over the long-term and to ensure that the spaces dedicated for MBTA users are, in fact, reserved and available for MBTA riders, the MBTA and private developer will enforce the agreement within the garage, through signage, dedicated spaces and internal gates. Similar situations have been handled at numerous other MBTA parking facilities, including Lynn Station, Route 128 Station and Mystic Center (Wellington).


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IV. RED LINE/BLUE LINE CONNECTOR MassDOT and the MBTA should build the Red Line/Blue Line Connector project.

MassDOT previously addressed this issue in 2011: The Red Line/Blue Line Connector project is an idea that has been studied repeatedly over the past several decades. The project has merit, and would provide meaningful benefits both for residents and employees on the north side of Boston and for users of the central subway system, who would experience a reduction in system-wide congestion due to the newly-created connection. MassDOT supported the inclusion of final design of the Red Line/Blue Line Connector as a SIP commitment both as a way to further the understanding of the details of the project – last rigorously studied in the 1980s – and in the hope that funding to construct the project might become available during the period of design development. MassDOT has completed conceptual design and a Draft Environmental Impact Report for the project. However, construction funding has not become available and, in fact, the financial situation facing MassDOT and the MBTA has worsened in the intervening years. As a result, construction funding for the Red Line/Blue Line Connector has not been included in any of the required planning/funding documents prepared by MassDOT/MBTA and the Boston Region Metropolitan Planning Organization, as it would need to be in order for the project to advance. Couple this with the fact that fully engineering a project as complex as the Red Line/Blue Line Connector is an expensive undertaking in and of itself, and that to do so in a way that is divorced from a construction procurement strategy is problematic at best and impossible at worst, and MassDOT feels that it can no longer pursue the project. For these reasons, MassDOT is requesting that DEP relieve it from the obligation to fully design the Red Line/Blue Line Connector.

MassDOT and the MBTA should prepare the Red Line/Blue Line Connector to be ‘shovel-ready.’ MassDOT previously addressed this issue in 2011: The term ‘shovel-readiness’ entered standard parlance during the implementation of the American Recovery & Reinvestment Act in 2009. Conceptually, shovel-ready means that an infrastructure project is fully ready for construction – all designs done, all right-of-way purchased, all environmental clearances obtained, all public support in place – and is simply waiting for the availability of funding. In reality, this is a quite difficult (and not necessarily prudent) strategy for the public sector to pursue for a project like the Red Line/Blue Line Connector. The investment of time and resources required to make a project of the scope and complexity of the Red Line/Blue Line Connector shovel-ready is substantial, with monetary costs in the tens of millions of dollars or more. There are also opportunity costs, as those funds can’t then be used to advance other projects. There are also regulatory consequences, as permits can expire and regulations and


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design requirements can change, making designs stale before a project is built. Lastly, there are public consequences, as the premature purchase of private property – particularly property that may wind up not being used, if a project is never built – can have real and negative impacts on businesses and residents and the urban environment. For all of these reasons, MassDOT is cautious about preparing a project like the Red Line/Blue Line Connector to a ‘shovel-ready’ level. A project like the Red Line/Blue Line Connector simply requires too many years of nurturing and dedicated project development to be brought to the ‘shovel-ready’ stage without the commitment of sustained funding over the course of years. Furthermore, the costs of a project like the Red Line/Blue Line Connector will always be too large for the capacity of a discretionary program of the type for which ‘shovel-readiness’ is a meaningful evaluation criterion.

Given that MassDOT agreed to include final design of the Red Line/Blue Line Connector as a commitment in the State Implementation Plan, MassDOT should not now be allowed to argue that the commitment lacks measurable benefits. MassDOT has responded to this concern on multiple occasions, and the agency’s position on this issue has not changed. As noted in an earlier response, MassDOT agreed to the inclusion of final design of the Red Line/Blue Line Connector as a SIP commitment as a way to further the understanding of the details of the project and to better position the project should construction funding become available. Inclusion of the final design commitment in the SIP clearly has had planning benefits, as MassDOT now has a much clearer understanding of the challenges and opportunities presented by this very complex urban tunneling project. Given what MassDOT knows now, however, it would arguably have been prudent to not agree to include the Red Line/Blue Line design commitment among the other SIP projects. The financial situation faced by the Commonwealth, MassDOT, and the MBTA has only worsened since the SIP regulation was last amended, and it is now clear that further engineering and construction funding will not be available in the foreseeable future to make the Red Line/Blue Line Connector a reality. The lack of demonstrable air quality benefits associated with the final design of the Red Line/Blue Line Connector—a fact that requires little in the way of argument for support—is not MassDOT’s rationale for requesting that DEP relieve it of the commitment. The rationale is that MassDOT believes that it is irresponsible to devote scarce public resources at a time of such great need to the design of a project for which MassDOT and the MBTA clearly do not have the financial capacity to implement over the next two decades.

MassDOT is overestimating or purposefully inflating the costs of completing design for the Red Line/Blue Line Connector intentionally in order to justify the proposed removal from the SIP.


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MassDOT previously addressed this issue in 2011: This is not correct. The cost projections for final design and construction of the Red Line/Blue Line Connector were prepared by a capable team of technical professionals as part of the development of the Draft Environmental Impact Report. This work represented the first time in more than two decades that the costs for the project had been estimated in a detailed and comprehensive way; previous estimates had simply been inflations of earlier estimates, crudely projected into the future. The current cost estimate for the Red Line/Blue Line Connector may seem high to those who are accustomed to earlier estimates, but they reflect contemporary professional standards. Furthermore, the experience of MassDOT and the MBTA indicates that many projects can come in over their original cost estimates, not under. MassDOT did not manipulate the process of estimating the costs.

In particular, MassDOT should link the design or construction of the Red Line/Blue Line Connector to the proposed casino developments at Suffolk Downs, encouraging or forcing any casino developer to undertake the project. Under Massachusetts’ gaming facilities law, proponents must negotiate a Memorandum of Understanding (MOU) with host municipalities which would include a mitigation package. The mitigation proposals are intended to reduce negative impacts—in the case of the transportation network, the increased demand on the system. The resulting host community MOU is then voted on by residents of the host municipality. In the case of proposals in the City of Boston, only the host ward votes on the agreement. MassDOT does have a role under MEPA in guiding transportation mitigation for development project impacts. The scale of the Red Line/Blue Line Connector – projected to cost $748 million – makes it unsuitable as a mitigation project for a private development. MassDOT therefore will not recommend that any casino developer fund the construction cost of the Red Line/Blue Line Connector. MassDOT’s role is also limited to discussing potential mitigation projects with a proponent—the MOU and the mitigation projects included are ultimately the product of a negotiation between the developer and the host community (City of Boston) and those voting on the MOU (residents of affected wards).

Like the Red Line/Blue Line Connector, few planning projects have funding “at any point in the next 20 years”. Yet planning continues on other, unfunded, projects. Why is the Red Line/Blue Line Connector being treated differently by MassDOT? Significant planning work has already been conducted on the Red Line/Blue Line Connector. From this point forward, the work would focus much more on actual design and engineering work, which would have a limited shelf life should funding for its construction not materialize soon. While work continues on a few other major transit


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projects (such as South Coast Rail and South Station Expansion) which do not have full funding commitments for construction, the work on both of those projects is still focused primarily on planning rather than design. Both of those projects have also been recipients of significant grant funds from the federal government which has allowed MassDOT to advance specific project elements.

MassDEP should require MassDOT to identify substitution projects to compensate for the Red Line/Blue Line Connector if it is not being built. Alternatively, MassDEP should require MassDOT to appropriate $26 million (the difference between the original $29 million estimate to complete design for the Red Line/Blue Line Connector and the $3 million already spent on the project) toward interim offset projects for other SIP commitments. In July 2011 MassDOT submitted a request to MassDEP to relieve MassDOT of the commitment to complete final design on the Red/Blue Connector given that 1) there was no funding available to implement the project in the foreseeable future, which would call into question the value of advancing designs that would have to be revisited within a few years anyway, and 2) the design of Red/Blue itself has no measurable air quality benefit. MassDEP is considering this request, and held public hearings to solicit comments during summer 2012. Based on MassDOT’s position, as described in the request, MassDOT believes that no additional resources should be required to be invested on the Red Line/Blue Line Connector project. MassDEP has not yet issued a decision on MassDOT’s request.

Construction of the Red Line/Blue Line Connector should be included in the construction contract of the Green Line Extension project, as a way to gain efficiencies, and potentially as an interim offset measure to the Green Line Extension project delays. MassDOT previously addressed this issue in 2011: Leaving aside the contractual complexities of the mechanics of trying to accomplish this, the Red Line/Blue Line Connector will not be on the same construction schedule as the Green Line Extension project, for which ground has just been broken. Furthermore, the fundamental problem of financing the construction of the Red Line/Blue Line Connector remains, which prohibits it from serving as an interim offset measure for the Green Line Extension project.


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V. GREEN LINE EXTENSION TO SOMERVILLE AND MEDFORD MassDOT is violating the SIP regulations by not providing details related to the

continued delays of the Green Line Extension Project. MassDOT always strives to provide the most accurate and up-to-date information possible on its programs and projects. For the SIP projects, MassDOT submits monthly reports to the Boston Region Metropolitan Planning Organization, as well as to the Federal Highway Administration and the Federal Transit Administration, on the status of the four outstanding SIP projects. In those documents, MassDOT reports the most timely available status information for each of the projects. MassDOT endeavors to report as accurately as possible, and we generally do not report on changes in a project status until we are completely confident that the change is certain and meaningful. The monthly status reports are available at: http://www.massdot.state.ma.us/SIP.

The Commonwealth does not provide enough information about the funding plan for the Green Line Extension project. [We] renew our request for MassDOT to complete, and make publically available, a detailed funding plan for the project. The funding strategy for the Green Line Extension remains the same as it has been throughout the project: to pursue federal funding through the federal New Starts discretionary funding program – a competitive program for which the Commonwealth must apply for funding – and to match that funding with Commonwealth dollars. MassDOT and the MBTA are pleased that the Green Line Extension project has been selected by the FTA for approval into Preliminary Engineering. As part of the application to FTA for Preliminary Engineering, MassDOT was required to present a plan to resolve the MBTA’s structural deficit and provide the capital funds for the Project. In turn, this would allow FTA to participate in funding a portion of the Green Line Extension project. The latest Green Line Extension project financial plan, submitted to the FTA, can be found at the following project website: http://www.greenlineextension.org/docs_FTA_NewStarts.html. In addition, MassDOT recently released a statewide transportation finance plan, which would, in part, support the Green Line Extension project. The plan can be found at: http://www.massdot.state.ma.us/Portals/0/docs/infoCenter/docs_materials/TheWayForward_Jan13.pdf. In addition to federal funding, MassDOT and the MBTA will use Commonwealth funds to support the design and construction of the Green Line Extension project. These funds will be raised with the backing of authorizations made to support the State Implementation Plan (SIP) projects in Transportation Bond Bills of the past several years. At present, MassDOT has $624 million available in active Transportation Bond Bill authorizations for the SIP projects. This value does not account for the monies


http://www.greenlineextension.org/docs_FTA_NewStarts.html

http://www.massdot.state.ma.us/Portals/0/docs/infoCenter/docs_materials/TheWayForward_Jan13.pdf

http://www.massdot.state.ma.us/Portals/0/docs/infoCenter/docs_materials/TheWayForward_Jan13.pdf


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encumbered to support current projects to date. MassDOT will seek additional Transportation Bond Bill authorization to cover the costs of the Green Line Extension project, as well as other SIP projects as necessary.

MassDOT should consider phasing the implementation of the Green Line Extension project, with clear goals and milestones. As discussed previously, MassDOT and the MBTA are implementing a phased approach to deliver the Green Line Extension project to the communities of Cambridge, Somerville and Medford. The first Phase has been awarded for construction and the rehabilitation and widening of two bridges and the demolition of a tire warehouse which has commenced in late 2012. The second Phase, extending service from North Station/Science Park to the relocated Lechmere station and on to Union Square and Washington Street in Somerville, will start full construction in early 2015 (after the FTA has issued its determination of funding for the project) and complete construction in early 2017, followed by a period of operational testing before passenger service commences. Phase 4, extending from Washington Street Station to the College Ave Station in Medford will also commence in early 2015, but the narrow corridor, the work adjacent to the active commuter rail and the sequencing of bridge construction to minimize community impacts will likely extend this phase until 2018, followed by a period of testing prior to providing service. Finally, a vehicle storage and maintenance facility will be constructed in East Somerville to support this portion of the Green Line system. This phasing approach is intended to minimize risks to cost and schedule and deliver portions of the project as soon as possible to these communities while not jeopardizing opportunities for federal financial participation.

Many local residents and important underserved populations have been unable to participate in the Green Line Extension decision process. Since the inception of the project in 2006, the Green Line Extension project team has made public participation a top priority. As much as possible, information has been provided about the project to the public; the team has sought public input and used it to modify project plans, designs, and overall direction of the project. MassDOT and the MBTA take seriously public expectations for the quality of our work and hold ourselves to the high standards set for us by the public; and we are genuinely interested in and enjoy interaction with the public. That being said, it is always challenging to reach certain populations: new immigrants, those with limited English proficiency, those without access to the internet, and those who are unable or unwilling to participate in public meetings. MassDOT staff members are aware of these challenges, and always strive to broaden the circle of outreach in


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order to include more voices in our planning processes. We will continue with our efforts, and welcome ideas and suggestions from local community members.

The current phasing plan of the Green Line Extension project leaves out Gilman Square Station from Phase 2/2A. Gilman Square should be accelerated as it is the highest projected ridership station. The current travel forecast model estimates the daily ridership at Gilman Square Station in 2030 to be 3,930 boardings. The estimated ridership at Union Square Station in 2030 is 3,570 boardings, which is similar to Gilman Square Station. These two stations have the next highest ridership projection, following the relocated Lechmere Station with 8,820 daily boardings. While ridership is an important measure of service needs, and the whole GLX corridor serves highly dense communities, the current phasing plan for the GLX implementation was developed by MassDOT and the MBTA based on a number of factors and risks related to the agency’s technical and operating characteristics, the actual work required to provide service to each location and the financial resources available. The complexity of corridor development to provide Green Line service between Washington Street and Gilman Square Stations is substantially different than the area from Lechmere to Washington. This is primarily due to the fact that the corridor has to be widened to accommodate the additional tracks and the station, which involves the reconstruction of at least the Medford Street and the School Street Bridges, extensive utility work and drainage work both on the bridges and in the corridor, retaining wall and noise wall work and the relocation of the Commuter Rail tracks to clear the area to build the new GLX platform and tracks. Also considered was the need to relocate an existing NSTAR substation at Gilman and the required additional traction power substation in the area. It was also determined that additional vehicles would be required to maintain headways and support the extended Green Line service to Gilman Square Station, where they are not required to support the extension of service to Washington and Union. When considering each of these elements and the time required to implement them, there was therefore no ability to commit to delivering the extension service to Gilman Station as part of Phase 2/2A and in the same time frame as service to Washington and Union.

Not enough is being done to mitigate the construction impacts of the Green Line Extension and the rehabilitation of roadway bridges in the area. This will severely hamper east-west travel in the project corridor. MassDOT is fully aware of various roadway/bridge projects whose construction work is scheduled to be undertaken between 2012 and 2016 (or later) in the project area. Due to close geographical proximities and overlapping schedules, MassDOT has initiated, in collaboration with the City of Somerville, an effort to coordinate these projects so that the overall construction impacts to the communities can be minimized. The Green Line


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Extension project also has construction activities scheduled during this period, including the Phase 1 construction package, (the widening of the two early rail bridges and a building demolition), which received a Notice to Proceed in December 2012. The Green Line Extension project team has been a participant in the coordination that has occurred on these roadway and bridge projects. Key projects in the vicinity of the GLX project include, but are not limited to: rehabilitation of Cross Street Bridge; replacement of Route 28 over Gilman Street; repairs to the McCarty Overpass; construction of a portion of the Somerville Community Path; reconstruction of Beacon Street; and streetscape improvements on Broadway. Coordination will continue as the Green Line Extension project design advances and construction work will be planned in a manner that minimizes community disruption and recognizes the team’s principles of maintaining the project area’s major traffic access and avoiding the closures of two adjacent bridges at the same time. An example of this effort is the Phase 1 package for the GLX that includes a contract provision requiring the contractor’s active participation in project coordination efforts.

The Green Line Extension project will affect the Medford community negatively through

real estate speculation. Public transit investments like the Green Line Extension project can, over time, influence local economies in ways both positive and negative. For all of the benefits brought by increased access to public transit – greater mobility for residents and workers of all incomes, greater access to employment and other services, and cleaner transportation than that offered by automobiles – some negative effects can also be felt. These can include an increase in the cost of rental properties in neighborhoods with immediate access to new public transit services. These negative effects can be offset by proactive municipal policies, however, including: policies to stabilize rents, increase the supply of affordable housing, and implement progressive taxation policies that encourage targeted growth and density. Concerns among some Medford residents about displacement are reasonable, and can be addressed through effective, thoughtful collaboration among residents, community groups, and municipal officials. MassDOT supported work by the Metropolitan Area Planning Council to research and review issues of potential future gentrification in Medford, particularly around the future site of a Green Line station at Route 16. The results of the work can be found at: http://mapc.org/green-line-extension.

Cleaning up the diesel locomotives through Somerville and Medford will do more for local health and quality of life in Medford than will the Green Line Extension. At present, the MBTA uses ultra-low sulfur diesel fuel on all commuter rail vehicles. In addition, the MBTA is in the process of adding head-end power to one-third of its locomotive fleet. These units will allow these locomotives to run more cleanly, with

http://mapc.org/green-line-extension


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fewer emissions and less fuel, while also bringing them into compliance with US EPA Tier II standards, some of the strictest air quality standards in existence for locomotives. Additionally, existing locomotives have been rebuilt, as part of the MBTA’s mid-life overhaul program, with existing engines rebuilt to new standards and new emission levels, resulting in fewer emissions, as well as more efficient operations of the engines. As part of the fleet upgrade, the MBTA has added Auto Assisted Shutoff Systems which prohibit a locomotive from idling for more than 30 minutes after its use. This is particularly critical in Somerville as locomotives are stored and maintained at the Commuter Rail Maintenance Facility (CRMF). Lastly, the MBTA has purchased and is awaiting delivery of 25 new locomotives which will replace older locomotives. These new engines meet, and in some cases exceed, EPA standards for emissions and will be some of the cleanest engines available. Although these improvements (i.e., new locomotives, head end power upgrades, shutoff systems) will provide air quality benefits in the entire commuter rail service area, and particularly in Somerville. The air quality benefit of the Green Line Extension project will continue to outweigh any improvements in commuter rail emissions, however, through the auto diversions induced by the project.

The Green Line Extension project has not completed a robust air quality impact analysis. Analysis of local impacts is required by the Massachusetts Air Pollution Control Regulations. Diesel trains from the commuter rail will emit air contaminants into environmental justice communities and the project adds to that burden by not remedying that current situation. MassDOT has failed to determine local air quality data. Diesel exhaust emissions from engines used during construction must be added to the environmental analysis, as was mandated in the EENF, but not completed in the EA. The environmental analysis prepared for the project pursuant to the National Environmental Policy Act (NEPA) and the Massachusetts Environmental Policy Act (MEPA) was prepared in accordance with all state and federal air quality regulations and all appropriate standards. The analysis methodology was reviewed and commented on by MassDEP as well as the US EPA. MassDOT is confident that the air quality analysis performed for the project meets or exceeds state and federal air quality standards. As for diesel exhaust emissions during construction, the requirement in the environmental document was to meet DEP standards for retrofitting construction equipment and to DEP anti-idling regulations. These construction retrofit and anti-idling provisions have also been reinforced in MassDOT’s recently released GreenDOT Implementation Plan.

Over the last year, the Green Line Extension project team has fallen short in engaging the Design Working Group in a meaningful way. How can we expect that to change over the next year?


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The Green Line Extension (GLX) Project team last met with the Design Working Group (DWG) on November 15, 2012. At that meeting, an update on the design progress was made and the DWG was introduced to key staff from AECOM/HNTB, who will be completing design work for the GLX. The next meeting of the DWG will be scheduled for early 2013, at which time a more detailed program of public involvement and DWG meetings to support the development of designs for the project over the coming year will be discussed. Beginning in December 2011, the GLX Project team hosted a series of four station area workshops to present progress on designs made since the previous station workshop meetings were held in June 2011. Community input was gathered at these workshops to inform design development. An additional meeting to introduce design progress for retaining walls and noise barriers was held in May of 2011. An update on designs for the Community Path was held on December of 2012, following up on a presentation made in September 2011. All of these well-attended public meetings provided input from community members and local residents, including many members of the Design Working Group.

MassDOT is pushing the Green Line Extension simply to promote the expansion of a well-

connected entity in Tufts University. MassDOT previously addressed this issue in 2011: MassDOT and the MBTA do not show favoritism or provide special access or advantages to any group involved with the Green Line Extension project, as evidenced by the number of MassDOT and MBTA decisions about the Green Line Extension project that have angered or disappointed so-called special interest groups. That being said, the challenge of equitably and consistently involving all interested stakeholders – particularly those who aren’t sophisticated in the ways of public participation and advocacy – is a real one, and one that MassDOT and the MBTA struggle with on many of our projects. We rely not only on our own resources and knowledge but also on those of established local groups to make and sustain important contacts with abutters and other relevant stakeholders. Only with their involvement can we endeavor to make sure that the Green Line Extension project is founded on the needs and aspirations of a diverse group of individuals and local communities. MassDOT and the MBTA make good faith efforts to involve a broad range of stakeholders and individuals in its planning processes. MassDOT and the MBTA have no bias toward or against any individuals or groups, based on income, education, or other characteristics. Furthermore, the relationship between MassDOT and the MBTA and Tufts University is limited to appropriate discussions about the design and location of the future College Avenue station.

Interim Offset Measures for the Green Line Extension project’s delay must be implemented in the project corridor of Cambridge, Somerville, and Medford.


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MassDOT previously addressed this issue in 2010: The purpose of the State Implementation Plan in general, and the specific projects affiliated with the SIP in particular, is to improve regional air quality. MassDOT will focus on enacting interim offset measures in the most prudent way possible to meet regional air quality goals. However, in making decisions on interim offset measures, MassDOT will attempt, whenever reasonable, to identify measures that would also improve air quality directly in the project corridors associated with the delayed implementation of any projects.

In presenting the summary of potential interim offset measures, MassDOT dismissed virtually all of them for one reason or another, before any modeling was completed. Why were so many worthwhile projects ignored? Too many appropriate mitigation measures are prematurely scoped out due to the lack of support from the MBTA and MassDOT. The position of limiting peak-period service expansion handicaps the potential to provide meaningful mitigation, and could potentially be overcome with contracted services. Specifically, the following offset measure was not fully evaluated by MassDOT, and requires further consideration in the interim offset mitigation process:

o Signal prioritization for buses in the GLX corridor o Green Line services to Lechmere at 3-minute peak headways o Improved pedestrian connections in the GLX corridor o Removing the elevated portions of the McGrath Highway o Instituting free Hubway memberships for corridor residents o Construction of part of the Mystic Valley Reservation Master Plan, specifically the

mutli-use path from Harvard Avenue to the Malden Bridge o Plan for the Urban Ring, and implement early-action transportation

improvements in the Urban Ring corridor, specifically via new bus routes between Kendall and Sullivan stations

o Grand Junction corridor rail service to improve connectivity in Cambridge o Construction of the Red Line/Blue Line Connector

MassDOT received many recommendations for potential interim offset mitigation measures for the Green Line Extension project, and qualitatively evaluated all of them against a series of criteria. The criteria spoke to issues of practicality, operational viability, cost, potential to improve air quality, potential for municipal support, and timing of implementation. In particular, MassDOT is working closely with the MBTA to determine whether there are mitigation measures that the MBTA could implement given its existing operating constraints. It is true that many of the recommendations – both those submitted by the public and those developed by MassDOT – scored poorly in this qualitative evaluation, pointing to the challenge of effectively providing equivalent short-term compensation for the myriad benefits to be brought by the Green Line Extension project. MassDOT is continuing to work to develop viable mitigation measures, and will make any new


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information available to the public. All information to date, including the qualitative evaluation, is available at: http://www.greenlineextension.org/documents.html.

The full design and construction of the extension of the Somerville Community Path should be included in the costs and scope of the Green Line Extension project, or included as an interim offset measure for the delay. This includes the “missing link” between Inner Belt and Northpoint/Lechmere. MassDOT has long committed to developing final designs of the Somerville Community Path extension between Lowell Street in Somerville and Inner Belt Road in Somerville. This has been done in collaboration with the City of Somerville and advocates for the Path, so that the final design of the Path extension will be effectively integrated with the Green Line Extension. MassDOT will also fund the construction of infrastructure that must be shared between the Green Line Extension and the Path, including retaining walls and bridge structures. However, MassDOT is unable to take on the additional costs and responsibility associated with constructing the Community Path extension at this time.

Connections on the southern end of the proposed Path extension have been discussed extensively with the City of Somerville and with Path advocates, and MassDOT understands both the desire to extend the Path into the Lechmere area and long-standing municipal goals to develop the Inner Belt area of Somerville with greater density and more employment. At this point, MassDOT is unable to take on the financial responsibility for building a bridge connection (often called the “Urban Ring Bridge” or “Northpoint/Inner Belt Bridge”) between the Inner Belt neighborhood and the Northpoint/Lechmere neighborhood, but MassDOT believes that such a connection could have meaningful transportation and economic benefits and hopes to continue to work with the cities of Somerville and Cambridge on this issue. Information about the qualitative evaluation of these recommendations can all be found at: http://www.greenlineextension.org/documents.html.

DEP should ask MassDOT to clarify its plans, formalize a schedule, and devote planning

resources to the Mystic Valley Parkway station, corresponding with the Boston MPO’s decision to fund the station. MassDOT has been consistent in its support of an ultimate terminus from the Green Line Extension at Mystic Valley Parkway/Route 16, but has proposed that this final segment of the project be planned and constructed as a later phase. This is the case for financial reasons – the Commonwealth simply cannot afford it at this point – but also for planning and policy reasons. MassDOT learned a wealth of lessons from the release of the Draft Environmental Impact Report (DEIR), and feels that there is still a meaningful lack of consensus for a station at Mystic Valley Parkway/Route 16. We hope to continue to work and develop such consensus for this potential station area. In the recent past,




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that has involved supporting the process undertaken by the Metropolitan Area Planning Council which helped to detail some of the local issues around the station, and identify some further recommendations. Since the release of the MAPC report and findings, the Boston Region MPO has voted to include Congestion Mitigation and Air Quality funds (originally designated as highway funds but ‘flexed’ to transit projects) for the 2016 planning year as part of the most recent regional Transportation Improvement Program. This will allow for further design and environmental work to be undertaken at that time. MassDOT and the MBTA will engage in that process at the appropriate time. In the intervening period, MassDOT will not commit to a Mystic Valley Parkway / Route 16 terminus as an interim offset measure for any project delay. Committing to Route 16 would be against the stated aims of interim offset measures, and would be infeasible to complete in the timeframe necessary by the SIP regulations.

MassDOT and the Boston MPO have moved to proceed with the Route 16 Station design and planning without true environmental studies. As noted above, the Boston MPO, in 2012, ‘flexed’ money for the design and permitting of the Mystic Valley Parkway / Route 16 station, with the intention of work being undertaken in 2016. Through these efforts, all required environmental and design steps will be completed in order to have a fully-permitted station design. This is a common path for the design and permitting of major infrastructure projects, and MassDOT is not attempting to subvert or ignore any pertinent regulations.

[We] remain opposed to needlessly expending limited public resources on studying and then building an extension [to Route 16] that will encroach on neighbors and further invite unwanted development to the city. This is analogous to the West End redevelopment that displaced an entire neighborhood. MassDOT understands and acknowledges the continued lack of consensus around the need for and impacts of a Mystic Valley Parkway / Route 16 station. Many of those local issues were discussed at length in the MAPC process around the station area. However, it is important to state clearly that MassDOT intends not to take or remove any residences in the process of designing or building any part of the Green Line Extension. For this reason, and many others, the Green Line Extension project is not analogous to redevelopment of Boston’s West End, and any comparisons to that effort are misguided and inappropriate, serving only to confuse and stifle public discussion.

State Implementation Plan Public Meeting

Department of Environmental Protection and the Massachusetts Department of Transportation

September 18, 2012 – 1:30pm to 2:30pm and 5:00pm to 6:15pm

Mass DEP

One Winter Street

Washington Street Conference Center

Boston, MA

Attendees at Afternoon Session:

Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of

Environmental Protection (DEP)

Christine Kirby, Director of Transportation Program, Department of Environmental Protection

David Mohler, Executive Director, Office of Transportation Planning, Massachusetts

Department of Transportation (MassDOT)

Bill Deignan, City of Cambridge

Stephen Kaiser, Association of Cambridge Neighborhoods

Maureen Kelly, Central Transportation Planning Staff

Rafael Mares, Conservation Law Foundation

Anne McGahan, Central Transportation Planning Staff

Alan Moore, Friends of the Community Path, Somerville resident

Denise Provost, State Representative

Wig Zamore, Somerville resident

Attendees at Evening Session:

Nancy Seidman, Assistant Commissioner, Bureau of Waste Prevention, Department of

Environmental Protection

Christine Kirby, Director of Transportation Program, Department of Environmental Protection

David Mohler, Executive Director, Office of Transportation Planning, Massachusetts

Department of Transportation

Maureen Kelly, Central Transportation Planning Staff

Ken Krause, Medford Resident

Anne McGahan, Central Transportation Planning Staff

Ellin Reisner, Somerville Transportation Equity Partnership, Somerville resident

Carolyn Rosen, Green Line Advisory Group of Medford

Dr. William Wood, Green Line Advisory Group of Medford


Introduction

Nancy Seidman, Assistant Commissioner, MassDEP opened the public meetings on MassDOT’s

annual status report on the commonwealth’s State Implementation Plan (SIP). MassDEP requires

MassDOT to report annually on its progress for implementing uncompleted SIP projects under

its authority pursuant to M.G.L. Chapter 111, Sections 142A through 142M, subsection (7) of

310 CMR 7.36, the Transit System Improvements regulation. MassDEP is seeking public

comment on the annual update and status report for these transit projects.

Within 120 days of this meeting, MassDOT is required to summarize and respond to public

comments. Within 60 days of the summary and response, MassDEP must then determine

whether the public process requirements of the regulation have been met. Written comments will

be accepted until 5:00 PM on September 25, 2012. Comments should be submitted to Kate

Fichter, MassDOT, Office of Transportation Planning, Room 4150, Ten Park Plaza, Boston, MA

02116 or [email protected], and Jerome Grafe, MassDEP, Bureau of Waste

Prevention, Boston, MA 02018 or [email protected].

This meeting was originally scheduled for September 6, but was rescheduled so as not to conflict

with the primary elections.

Attendees were asked to limit their spoken comments to five minutes.

MassDEP held a public hearing on September 13 regarding MassDOT’s request to amend the

SIP to remove the requirement to complete the design of the Red/Blue Line Connector project.

The public comment period closes on September 24 at 5PM.

MassDEP issued a certification letter on the 2011 SIP report on March 15, 2012.

MassDEP has approved MassDOT’s petition to delay the Fairmount Line Improvement project.

Status Report

David Mohler, Executive Director of MassDOT’s Office of Transportation Planning, provided a

summary of the status on the SIP projects.

The Fairmount Line Improvement project was required to be complete by December 31, 2011.

The project includes the construction of four new MBTA stations and the reconstruction of two

stations. The Morton Street and Upham’s Corner Stations are complete and open. The Four

Corners Station is 80% complete and expected to be complete in April 2013. The Talbot Station

is 90% complete and expected to be complete in January 2013. Newmarket Station is 70%

complete and expected to be complete in June 2013.

Blue Hill Avenue Station is being designed. The project was at the 60% design stage in 2009. As

a result of concerns expressed by neighbors and abutters to the station, MassDOT is submitting

its designs for a peer review. The station will probably not be open until 2015. MassDOT has

implemented two projects to mitigate for the delay: a new shuttle bus between Andrew Square

and the Boston Medical Center, and increased to frequency of MBTA bus route 31.

The 1,000 New Park and Ride Parking Spaces project is complete. MassDOT was required to

construct 1,000 new parking spaces in the Boston MPO region by December 31, 2011.



Wonderland Garage opened on June 30, 2012, six months behind schedule. To mitigate for the

delay, MassDOT increased Saturday service on MBTA bus route 111.

MassDOT was required to complete the final design of the Red/Blue Line Connector project by

December 31, 2011. MassDOT is petitioning MassDEP to remove this requirement from the SIP.

MassDOT is required to complete the Green Line Extension to Medford Hillside with a spur to

Union Square in Somerville by December 31, 2014. State environmental review has been

completed and the federal government has issued a Finding of No Significant Impact (FONSI).

The Federal Transit Administration (FTA) gave approval to enter into preliminary engineering

under the New Starts Program on the condition that MassDOT be able to solve its transit

underfunding problem. MassDOT has selected a firm to conduct the preliminary design work.

The MBTA is reviewing proposals for Green Line vehicle construction and expects to present a

recommendation to the MassDOT Board this fall. MassDOT has hired a relocation consultant for

right-of-way work.

The Green Line Extension project will be conducted in four phases. Phase 1 is the widening of

the Harvard Street Bridge in Medford and the Medford Street Bridge in Somerville, and the

demolition of the building at 21 Water Street in Cambridge. Phases 2 and 2A involve the

relocation of Lechmere Station and construction of the Union Square spur. The second phases

are expected to be complete by mid-2017. Phase 3 is the construction of a maintenance and

storage yard. Phase 4 will provide service from Washington Street to College Avenue. The

Construction Manager/General Contractor (CM/GC) delivery method will be used. The project

cost estimate is $1.1 billion exclusive of finance charges. Projects to mitigate for the delay are

being selected.

Oral Testimony – Afternoon Session

Denise Provost, State Representative

Rep. Provost expressed dismay about the prospect of the elimination of the Red/Blue Line

Connector project from the SIP. She then advocated for the Green Line Extension project

emphasizing the importance of the project for Somerville residents to get justice and for access

to good transit, for improving air quality, and for improving the region’s economy.

She expressed concern about efforts in the legislature to stop the expansion of the transit system

and the Green Line Extension project, and she expressed the need to recommit to the expansion

of the transit system. She referenced the Global Warming Solutions Act and noted that cities in

the urban core have lower emissions contributions than those in the suburbs, and that transit

expansion would allow other communities to reduce their emissions. She also referenced the

state’s Healthy Transportation Compact and called for a health analysis to be conducted for the

Green Line Extension project. Lastly, she explained how the Green Line Extension would allow

for an increase in availability of work force housing as Somerville is zoned for density.

Rafael Mares, Conservation Law Foundation

Mr. Mares suggested that the deadline for the Red/Blue Line Connector project be extended

rather than eliminating the project from the SIP.

He expressed satisfaction with the progress of the Fairmount Line Improvement project and

asked that an eye be kept on delays so that the project can be completed. He noted that the SIP

requires measures to increase service and ridership on the Fairmount line.

He also expressed satisfaction that interim offset measures have been put in place for the 1,000

New Park and Ride Parking Spaces project. He urged DEP to require MassDOT to report on this

project next year. He expressed concern that MassDOT has no measures in place to ensure that

only MBTA customers can use the South Garage at the Wonderland Garage. He also questioned

whether the requirement to create 1,000 new parking spaces has been fulfilled since not all the

spaces are new ones.

He asked that MassDOT also continue to report on the Blue Line Modernization project. He

noted that the Government Center Station has not yet been modernized.

He stated that the public should continue to be involved in the development of the interim offset

projects for the Green Line Extension project.

Stephen Kaiser, Association of Cambridge Neighborhoods

Mr. Kaiser referenced the laws governing the SIP process and gave a reminder that government

is for the common good of the people, not for the profit of any individual or class (as noted in the

Article 7 of the Declaration of Independence). He called on the government representatives to be

wary of actions that will use public funds for the benefit of private developers.

He cited a study by the Urban Land Institute that reported that the MBTA system is already at

capacity. He cautioned that the system cannot support the additional riders that would result

from development. He stated that developers should pay to support that extra transit capacity,

since they are the beneficiaries of the development.

He stated that the air quality goals for the MBTA should focus on running the system efficiently

and providing as much service as possible. He expressed concern that funding capital projects

will detract from that goal. He noted that MassDOT has $26 million worth of debt.

He suggested that the requirement to complete the Red/Blue Line Connector project be replaced

with a requirement that MassDOT report its budget (capital and operating) to DEP. This

information could be used to monitor whether any new project would result in failures of the

transit system.

Alan Moore, Friends of the Community Path, Somerville Resident

Mr. Moore expressed thanks to the DEP for requiring the Green Line Extension project in the

SIP, to EOEEA secretaries for ensuring that the Community Path project was not precluded, to

former MassDOT secretaries for including the Community Path to Inner Belt in the Green Line

Extension design contract, and to MassDOT and the MBTA for agreeing to build some shared

infrastructure between the two facilities.

He noted that the Community Path will deliver more riders to the MBTA stations and thereby

reduce emissions. He called for the Community Path to be constructed along with the Green Line

Extension to minimize costs. He suggested that the project be used to mitigate for delays in the

Green Line Extension project. He also requested that MassDOT design the Community Path

between the Inner Belt area and Cambridge.

Bill Deignan, City of Cambridge

Mr. Deignan commented on the Green Line Extension project and expressed the City of

Cambridge’s support for the project. He suggested that interim offset projects should allow for

transit capacity increase, and that MassDOT should concentrate on making peak hour

improvements and enhance bus connections. He also suggested that consideration be given to

expanding the Hubway bike share program. Lastly, he expressed support for building a bridge to

North Point as part of the Green Line Extension project.


Mr. Zamore responded to a couple of points made by previous commenters. He noted that there

is a jobs deficit in Somerville that correlates with a fiscal deficit, and he expressed his hope that

transit would be used to develop a better balance between jobs and the work force. He also

expressed that everyone should pay their share for transit and proposed that broad-based

measures be employed, such as a gas tax or diesel tax.

He then discussed the SIP as a means to improve air quality, particularly with regard to ozone

and particulate matter. He discussed the failure of the U.S. EPA to institute health protective

standards with regard to these pollutants. He said that the next ozone standards will have to take

into account mortality associated with ozone.

He submitted documentation regarding health protective standards, a study on air quality

monitoring in Somerville, and a Canadian study on particulate matter.

Oral Testimony – Evening Session

During Ms. Seidman’s opening remarks two attendees made comments regarding the time

allotted for attendees to speak. Dr. William Wood requested additional speaking time due to his

health issues. Carolyn Rosen stated that the public notice for the meeting did not specify that

members of the public would have only five minutes of speaking time. She also noted that

someone who attended the afternoon session was in attendance at this evening session, and that

he would be getting a total of 10 minutes of speaking time. Dr. Wood asked for 20 minutes of

speaking time, and the panel accommodated his request.

Ellin Reisner, Somerville Transportation Equity Partnership, Somerville resident

Ms. Reisner expressed appreciation to the MBTA staff for reaching a milestone on the design

and engineering of the Green Line Extension project. She called for the commonwealth to move

forward on the interim offset projects and emphasized that mitigation becomes more important

the longer the project is delayed. She advocated for building the extension to Route 16.

She recommended that DEP direct MassDOT to complete the design and construction of the

Community Path from North Point to the Inner Belt, an environmental justice community. She

stated that the Community Path meets the sustainable transportation goals of the federal

government and the commonwealth. She expressed frustration that MassDOT is not meeting is

own sustainability goals.

She expressed support for roadway improvements in the Brick Bottom and Inner Belt area and

for bus service from Sullivan Square to Lechmere, Kendall, and the Longwood Medical Area.

Lastly, she expressed disappointment that the Red/Blue Line Connector project is not moving

forward as the project would reduce car ridership.


Mr. Zamore expressed agreement with Ms. Reisner’s comments, though he said that he would

prefer light rail in the urban core rather than buses. He then spoke about health issues associated

with air pollution.

He noted that the World Health Organization has declared diesel emissions to be a Class 1

carcinogen, a fact, he said, which does not support the intense use of diesel vehicles in the urban

core. He provided the panel with various studies that report on the associations between

transportation emissions and heart attacks and with mortality associated with living in proximity

to highways. Due to health impacts from emissions, he advised against putting bicycle

accommodations on arterial highways. Rather he suggested choosing routes for bicycles that are

on less heavily traveled streets.

He expressed support for extending the Green Line to Route 16 and for completing the

Community Path.

He noted that the Fairmount Line Improvement project is problematic because it will expose a

population in a densely-settled area to diesel emissions.

Ken Krause, Medford Resident

Mr. Krause recognized the progress that has been made on the Green Line Improvement project

and the Boston Region MPO’s commitment to extending the project to Route 16. He noted that

DEP should be aware that the Harvard Street Bridge project, which is part of Phase 1, will

address a flooding issue. He expressed his hope that DEP will continue to be an advocate of the

project and for getting funding for the project.

He discussed the need for the project considering traffic congestion problems in the Medford

area. He noted that the Green Line Extension project’s DEIR identifies the intersection of Mystic

Valley Parkway and Boston Avenue as having the second largest traffic count in the project area.

He expressed some disappointment with the interim offset projects (further detailed in written

comments) and with the removal of the Red/Blue Line Connector project from the SIP. He noted

that a potential funding source for the latter could come from the development of the casino in

Revere. If the project is removed from the SIP, he said that the $50 million designated for the

project should be directed toward interim offset projects for the Green Line Extension project.

Carolyn Rosen, Green Line Advisory Group of Medford (GLAM)

Ms. Rosen expressed opposition to the Green Line Extension project to Route 16. She remarked

that Congressman Capuano voiced concerns about state’s ability to pay for the project and she

said that the commonwealth has no funding to build the project beyond Lechmere and North

Point.

She noted that the NAACP is also opposed to the Route 16 terminus and that the group has stated

that position at an Boston Region MPO meeting. She claimed that the MPO discriminated by

holding a meeting to discuss the project financing that only white project proponents attended.

She also expressed her belief that the disabled and environmental justice community in Medford

is being marginalized from design working group.

She stated that the FONSI for the Green Line Extension project should be challenged because it

is based on old air quality data. She expressed concerns about particulate pollution from diesel

vehicles and noise pollution, and she called for environmental studies to be done. She referred to

the work of Dr. Marlene Warner, an environmental advisor to GLAM.

Ms. Rosen submitted written documentation.

Dr. William Wood, Green Line Advisory Group of Medford

Dr. Wood spoke regarding the Green Line Extension project and called for civil rights issues to

be addressed. He expressed opposition to extending the line beyond College Avenue to Route 16.

The extension to Route 16 would benefit Tufts University the most while destroying the oldest

African-American community in America, he said.

He called for a study on particulate pollution and a human rights study, and he called for the

project to be delayed until the state gets a report on the human rights element. He referred to the

work of Dr. Marlene Warner, an environmental advisor to GLAM.

He discounted the “highest and best use theory” as not proven an not considering low or

moderate income workers or blue collar workers.

He stated that the project would benefit developers, universities, and the political career of the

mayor of Somerville. He warned that the project would be “another Big Dig.”

Dr. Wood stated that he would be filing a complaint against the Boston Region MPO because he

believes that the MPO held meetings at which funding decisions were made, that did not involve

project opponents. He believes that opponents were only invited to meetings after the funding

decision had been made. He remarked that there will be significant opposition, including from

himself, to obtaining the necessary funding for the project.

He also voiced a complaint about DEP’s public notice for this meeting and stated that he was not

offered appropriate accommodation. He accused the agencies of not following FTA’s rules.

EXECUTIVE OFFICE OF TRANSPORTATION TRANSIT COMMITMENT

SUBMISSIONS ASSOCIATED WITH THE STATE IMPLEMENTATION PLAN

PUBLIC HEARING DATED SEPTEMBER 18, 2012

DEPT. OF ENVIRONMENTAL PROTECTION and

MASSACHUSETTS OFFICE OF TRANSPORTATION

SUBMITTED BY

Green Line Advisory Committee for Medford (GLAM) c/o 25 Bussell Road

Medford, Mass. 02155

SUBMITTED TO

Katherine Fichter

Mass. Dept. of Transportation Office of Transportation Planning

Room 4150 Ten Park Plaza

Boston, Mass. 02116 [email protected]

and

Mr. Jerome Grafe

Mass DEP Bureau of Waste Prevention

One Winter Street Boston, Mass. 02018

[email protected]

September 18, 2012



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Public Comments on State Implementation Plan - Transit Commitments 2012 Annual Status Report

These public comments written and submitted by the Green Line Advisory Committee for Medford (GLAM) are focused on that portion of the Transit System Improvements pertaining to the transit system known as the Green Line extension from Lechmere to Medford Hillside. These comments are based upon documents known as the State Implementation Plan –Transit Commitments 2012 Annual Status Report. Based upon our participation within the Mass DOT citizen participation process over the last year, these public comments are essentially our report card on Mass DOT and the proposed Green Line project process. GLAM’s comments build upon our observations and experiences since our comments regarding the 2011 Annual Status Report. Our public comments submitted on September 18, 2012 are as follows: In a recent article on the proposed Green Line expansion project in the Metro Boston newspaper, August 21, 2012, Congressman Michael Capuano is noted as being skeptical about the commitment of the Commonwealth concerning the building of this project. When questioned as to whether the project would be completed on time, Congressman Capuano is quoted as stating in his well known direct style, “I’m willing to take a bet right now that there will not be a Green Line station here (meaning Union Square) in 2017. . . I mean they’re making promises to everybody and I don’t see how they can keep them all.” And he should know as he sits on the Congressional Transportation Committee at the federal level.

This quote comes soon after Congressman Capuano’s Somerville Journal column of June 22, 2012 where he states: "The options are clear - either we roll the dice for an all-or-nothing approach and hope the legislature and future governors are committed to the GLX, or we work thoughtfully within the funding limitations we now know are real and get the biggest-bang-for-our-buck in a way that preserves all future possibilities for GLX." In response to the Congressman’s position of going against conventional political rhetoric and proposing a step toward progress, a major proponent group, Somerville Transportation Equity Partnership (STEP) instead announces “The State can't simply decide not to build it. We shouldn't give an inch.” In other words, STEP assumes the all or nothing approach. Is Congressman Capuano being the unreasonable man while STEP takes the reasonable position of Too Big to Fail?

As George Bernard Shaw once pointed out:

"The reasonable man adapts himself to the world: the unreasonable one

persists in trying to adapt the world to himself. Therefore all progress depends on the unreasonable man." George Bernard Shaw

Should we equivocate about those things we know cannot be done? Should proponents and agencies such as Mass DOT mislead the public and let politics override what can and cannot be accomplished in economic bad times? It is not hard to go out on a limb of going all the way to College Avenue and have yourself chopped off by reasonable

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politics and those who view themselves as reasonable, thereby, hindering true progress on the proposed Green Line. Yes, the SIP depends on finances that are never really clear. Nor is the SIP really clear because Mass DOT is trying to be reasonable instead of unreasonable. Does this reasonableness lead to a truthful SIP year after year? We quote another writer, Shakespeare, “To Be or Not to Be”. The SIP is like the literary argument about George Bernard Shaw versus Shakespeare. Which is really right and in that argument whose eyes do you see literature through? In this case being reasonable is what the SIP is trying to say which never reaches the mark of reality because it never can predict the financial situation. Instead the SIP appears like a chicken running around with its head cut off since it is forced by politics to be an all encompassing project. Unfortunately the politics has led the unreasonable man to oppose this type of politics since it should be about the art of compromise and transparency. Instead you have to understand the subtext of what the SIP does not say, which Congressman Capuano has surely picked up in his assessment of the proposed Green Line project. If Republicans win the election, this project may be out the window. For the unreasonable man, this is reasonable. There is confusion between the theoretical and the reality. Though a plan can change reality cannot. The SIP is not completely looking at reality and it would be a better document if it was more realistic and compromising since actions at the MPO, in conjunction with the SIP, are trying to put Route 16 Mystic Valley Parkway (Route 16/MVP) into the SIP year after year. The local chapter of the NAACP in the proposed Green Line area has joined the argument in full context of what the Green Line will do if actions continue, as at the MPO, to discriminate against people. Yet you see nothing in the plan to end discrimination as is now being investigated by the Federal Transit Administration (FTA) or in the end of environmental studies. In fact, it is not clear how you stack up one of the oldest environmental justice groups in the country against the so-called social equity analysis of Mass DOT. Something based in unreasonable becomes more reasonable when you recognize fully what is taking place. How the state and FTA Region I can say a final Environmental Impact Statement does not need to be done is a contradiction and should be in contention by environmentalist. Yet it takes the unreasonable to bring out the facts that the data is so old that in other professions they would throw out the process. Constant updating of data is necessary to give a reasonable assumption. Yet it is only the unreasonable person stating this. Again, Shaw’s unreasonable man makes change happen, not a manipulated political body that is in investigation of not following its own policies. This is the disgrace of the reasonable report of the SIP. We, at GLAM, represent people from both political parties, independents, the environmental justice and disability populations, as well as, small business owners. We have observed in the last seven years how the art of political compromise is not followed to accomplish the project of the proposed Green Line to College Avenue. Yet, there is no deterrent by the state for doing this. We, the unreasonable, feel uncomfortable that the reasonable people are at our door step. As Congressman Capuano has said, you could lose it all (referring to the Green Line Expansion) if you do not compromise.

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After the presidential elections, we will know what will follow for funding. As some GLAM members are elected members of their respective political party at the local and state level, we know and understand politics. We believe the state administration and Mass DOT should report the reality versus the theoretical concerning the proposed Green Line Extension and other SIP projects. Instead of letting politics run the SIP, it should be the reality running the SIP. Because of the political foothold concerning the proposed Green Line project within the SIP, born out of a Memorandum of Understanding between the Conservation Law Foundation and Mass DOT without consulting the public, this SIP project is becoming a political boondoggle much like the Big Dig with an environmental assessment that holds no one accountable and no consequences or penalties if environmental or social equity degradation occurs. This is inexcusable according to professionals in equity studies. Mass DOT and Mass DEP owe a responsibility to the taxpayers of this state not to return to the ways of the Big Dig. FTA Region I has determined that a further environmental impact statement is not warranted because an environmental assessment has been done. An environmental assessment that is based upon:

A. old air quality data, now three years old, as evidenced by a November 2, 2011 Mass DEP letter to Mass DOT offered as response to public comments within the EA process. A document our independent environmental reviewer, Dr. Marlene Warner who serves on the Houston Galveston Area Council ‘s Environmental Health committee and its Air Quality subdivision, calls full of holes and written more on political motivation. We hereby state that Dr. Warner is not connected to the Massachusetts political sphere. She is independent and continues to be independent for GLAM, who wishes an independent, objective study. Not so for the Somerville/Tufts interest. Yet, the environmentalist of Medford and Somerville run from the issue, even though one of their own, Wig Zamore, goes on about particulates in Somerville after GLAM reports on the particulate problem as stated by the California Air Resource board and as other studies from New York point to the same problem.

This document supposedly offers “Emission reduction offsets" but does not account for pcbs and other carcinogens in the air from vehicles. Nor is there an accounting for separation of diesel particulates from ambient air quality measures. Diesel fumes cause cancer, asthma and COPD, and result in lost work days and school days. Yet there is no separation of these particulates in air quality studies. The scope of an EA should extend to all aspects of a project that are likely, directly or indirectly, to cause damage to the environment, 301 CMR - 11.06 (9), which by definition includes any actual or probable impairment (other than insignificant) to a natural resource, including air pollution, 301 CMR - 11.02. Such scope is authorized by the requirements for the contents of an EA at 301 CMR - 11.07 (6) and should apply to this project. Yet, Mass DOT in its infinite arrogance has decided that diesel particulate impact is outside the proponent’s Proposed Action. Mass DOT is using what is known as Semi-Transitive thought defined as embracing the vision of change through simplistic approaches of discrete acts that disassociate themselves from larger social structures and process impacts shaping transit and land use within the region that

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may perpetuate injustices based upon cumulative effects. 1 Semi-Transitive thought is the reasonable way of planning that is tied to the status quo of political power structures. On the other hand the unreasonable man unmasks this antiquated thought process by using a more progressive critical social consciousness process in planning by utilizing enlightened awareness of tangible social and environmental structures that affect the community. They include resource allocations, planning, and decision-making policies, as well as less tangible structures such as values and beliefs that influence perceptions as to what is possible, appropriate, and desirable in environmental sustainability and in achieving social equity.2 Mass. DOT and the state are falling behind in new thoughts on environmental planning and social equity, using the reasonable instead of the unreasonable, the latter which precipitates the real change. This statement of critical social consciousness represents the true environmentalist versus those who exploit the environmental issues for financial gain. This project required an enhanced analysis because the diesel trains from the commuter rail emit air contaminants into environmental justice communities that suffer statistically significant high rates of diseases that could be caused or exacerbated by those air contaminants. Such analyses are also required because residents already suffer from unhealthy levels of diesel particulate matter in the air and the project would add to that burden by not remedying the current situation. In performing the analysis for the Green Line, Mass DOT has failed to determine local air quality data. The project proponent should have determined air pollution data local to the project that would have a local impact. By failing to do so, it failed to assess potential environmental impacts, or to identify mitigation measures that could be taken for those in the environmental justice and disability communities. Analysis of local impacts, taking into account local air conditions, is required by the Massachusetts Air Pollution Control Regulations, which prohibit emissions of air contaminants that alone or in combination with other air contaminants cause a condition of air pollution. 310 CMR - 7.01(1). Air pollution means the presence in the ambient air space of one or more air contaminants or combinations thereof in such concentrations and of such duration as to cause a nuisance, be injurious, or be on the basis of current information, potentially injurious to human or animal life, to vegetation, or to property, or unreasonably interfere with the comfortable enjoyment of life and property or the conduct of business in the area of concern and surrounding areas. It is not enough to compare the emissions to state and metropolitan area standards.

B. Mass DOT has denied the need for Public Health studies of the impact of diesel

upon communities, specifically those in the environmental justice and disability populations. Their answer is they have no responsibility beyond the Proposed

1 Kyle, D. Brown, Ph.D., Justice in the Context of Environmental Sustainability, Implications,

InformeDesign, Vol 6, Issue 11. 2 Critical social consciousness was coined by Brazilian Educator Paolo Freire as he outlined stages of

critical social consciousness. In the context of Environmental Sustainability the citizen through the

planning process can increasingly see themselves as embedded in a historic social context defined by

relationships of power, oppression, and privilege.

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Action. They say so, so it must be true. Yet the movement of commuter rails closer to homes is part of the proposed action. Diesel exhaust emissions from diesel engines used during construction must be added to the toxic burden considered for resident species, including vulnerable humans. This was mandated in the EENF and was not done in the EA.

The question is why is this not being done? Is it economics since the delay in the project allows time to perform such study? Or may it have to do with the magnitude required for a lawsuit? Then it must be that planners know more than environmentalists. In years to come this Massachusetts project could become as well known as other programs that were created to hurt the environmental justice and disability communities (i.e. the Tuskegee experiment (health issues) and the West End urban development project (displacement and health issues). Both incidences are well documented for their social injustice.

C. The Executive Office of Environmental Affairs (EOEA), Environmental Justice

Policy (EJ Policy) aims to ensure that high minority, non-English speaking, and low income neighborhoods have a strong voice in environmental decision-making; receive the full protection of existing environmental rules and regulations, and have increased access to investments that will enhance their quality of life by restoring degraded natural resources, enhancing open space, and building the urban park network. In so doing, it recognizes that low income and communities of color in Massachusetts suffer a hugely disproportionate amount of environmental harm. These groups have all ready documented their concern.

As documented in the report, Unequal Exposure to Ecological Hazards 2005: Environmental Injustices in the Commonwealth of Massachusetts, by Professors D Faber and E Krieg, environmentally hazardous sites and facilities are disproportionately located in communities of color and working class communities in Massachusetts, placing residents of those communities at substantially greater risk of exposure to environmental health hazards. You do not find authentic representation of these voices on the GLX Design Working Group, a group of proponents hand picked by Mass DOT to advocate mitigation for the community. Yet when Mass DOT, the reasonable person, had the chance to appoint the environmental justice community such as the President of the local branch of the NAACP representing the impact area or those from the disability community living near the impact area who applied to sit on this working group, Mass DOT denied these appointments. The current Green Line Design Working group showed little expertise or concern for anything but pushing through this project in the experience of GLAM members who attended each GLX Design Working group meeting and their subcommittee meetings. The disparity of representation on the GLX Design Working group is illustrated in this example. Two families live across the street from each other. One is white and was appointed to sit on the GLX Design Working group. The other is an African American and President of the local chapter of the NAACP, who application for appointment was denied for the GLX Design Working group by Mass DOT. The majority of people recognize that the white person is a member of a political family. How was discrimination helped in this situation? A right delayed, is a right denied (Martin Luther King, Jr.) Where were the politicians in this situation, Senator Jehlen,

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Rep. Sciortino, Rep. Garballey? They were being reasonable in not spelling out their position on this kind of discrimination. The NAACP chapter recognizes it as discrimination since no African American was appointed to the GLX Design group. The state, even after being told of this situation, continues to support the effort, another reasonable decision. This white appointee never walked across the street and invited the NAACP President to be involved in this project in over 20 years of planning of this project. This same man, non disabled man, has told the disability community that he knows all about disabilities because he is a planner. This man as a member of other groups has tried to represent the disability community and has denied authentic representation of this community in those projects, especially those with legal standing in a historical project where laws and regulations require their participation. Yet, the state upholds that type of discrimination, again the reasonable man. When does the state stop using politics and start using the concept of the unreasonable man who seeks changes in the inequitable application of environmental justice and disability rights. In the 1950’s and 1960’s this type of denial of rights and participation was called discrimination. Yet, Mass DOT has accepted this as reasonable action. And the GLX Design Working Group has shown its ugly head when accepting the kind of equity study as presented by Mass DOT. Yet, the equity study based on old data around fare rates and service levels does not state that an elderly person living at Capen Court on Route 16 can pay $4.00 on paratransit, called The Ride, to get to a) proposed Route 16 station (if ever done), b) to College Avenue (when completed) or c) to Davis Square (Red Line) and then have to pay the extra dollars to take light rail to get on the T for health care appointments. But students on reduced discount fare programs can pay much less as well as college students through college discount programs. Here is an example of how the GLX Design Work group conducts itself. At a subcommittee meeting held by this group in November 2010 at the VNA in Somerville, the public was asked to submit prior written public comments to be addressed in the subcommittee meeting agenda, which GLAM did. When attending the meeting as chair of GLAM and a person with a disability, but not a member of the GLX Design Work Group subcommittee, I observed the following. The meeting was delayed in commencing because the GLX Design Work Group chair showed up over 20 minutes late to the meeting and then proceeded to continue to delay the meeting for another 15 minutes by fiddling with set up of computer equipment she brought to the meeting. There appeared to be no sound system in the room. Once the meeting proceeded The GLX Design Group chair set her own agenda and the public comments that were asked to be presented to this group on station design principles were never considered or discussed within the agenda. To use an analogy it was if the child had been given the keys to candy store and the public was not invited to share in the process. This also is an inequity factor as a result of Mass DOT’s inability to appoint people of differing view points that would ensure greater objective representation in advocacy of the community. Again the unreasonable doubter was the environmental justice and disability community. As chair of GLAM, I was appalled at the recognized politics of leaving out crucial groups that it was once stated this project was going to help.

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These examples give unreasonable people the sense that we are looking only at university expansion, supported by university students, and that the state is pushing out and marginalizing the person with a disability or the person from the environmental justice community. The unreasonable person can see this goal by the state, especially when the Chronicle of Higher Education predicts a 25% increase in university intake from overseas to the U.S. university population. This planning action can cause frustration of disparate impact in populations being tossed from their life time homes, as in the situation of the West End urban development project. Where does this leave equity and the mitigation of taking property at today’s prices and not at tomorrow’s prices. The West Medford environmental justice and disability community see this environmental burden as they are marginalized around issues of gentrification and displacement, all ready rearing its ugly head in Somerville over the fight about affordable housing in Union Square and in environmental concern of undue burden. We, who are unreasonable people, want an explanation of how, what, when and where in looking at disparate impact and in achieving equitable means. We, who want to participate, have had to take the slings and arrows for asking these kinds of questions. And now all we have to do is look at the current situation in Somerville and the fight over affordable housing, which represents nothing less than the legacy of the West End, Kendall Square and Davis Square in social and racial inequity. The West End has been well documented in its disparate impact while the Red Line extension from Harvard Square to Davis Square resulting in inequity, documented by Reconnecting America and in Professor Charles Olgetree’s book, Presumed Guilty, on the Professor Gates arrest case.

D. Mass DOT claims the GLX Design Working group as part of its Public

Involvement Plan and in their FTA EA response to public comments they state the Design Working group has been meeting quarterly. But in looking at our records and on the Mass DOT greenline website, this group has not met in over a year.

E. We also find misrepresentation in the social equity study that Mass DOT included

in the EA. They claim that fare increases and services are equal for the environmental justice and disability community, again using old data from 2011. Yet they were fully aware in preparing their response to public comments in January 10, 2012 that they would be increasing fares and making service reductions, particularly the jump in paratransit fares upon the elderly and disability community. Our understanding from the Disability Policy Consortium, of which we are a member, that paratransit ridership has seen an unofficial drop of 20% in ridership within the first three weeks of July when rate increases took affect. This means that the elderly and disability community are once again being isolated within their community. In the midst of a compliance review audit, where is the transportation reform of this progressive administration? Unreasonable doubters see a reform that is worst in disparity impact than before the reform. The Green Line project seems to be more about planners and private developers and university expansionism than it is about the people of the state.

This issue needs to be addressed in an updated social equity analysis and expanded upon as discussed earlier in these comments. Social equity studies should also

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incorporate the fact that expansion of transit brings more cost in operation, maintenance and capital spending. None of these factors were evident in analysis documentation Mass DOT provided to justify their position of equitable distribution. These are a few of the many fallacies we have seen within the EA process. And we do believe that there is conflict of interest when the technical assistance of the FTA Region I also is allowed to sign off on the Environmental Assessment. Therefore, we believe that this EA on this project must be taken to a higher level of review by those who have no political vested interested in this project. When a proponent can state that construction noise will be mitigated by piles of soil excavation without acknowledging environmental consequences of whether that soil is contaminate or will wash into the stormwater management system, there is something clearly wrong with this environmental picture. Conclusion If there is one thing we can agree with Mass DOT on, that is that Route 16 is not Medford Hillside and is not part of the mandated commitment under the SIP. But GLAM is aware that the MPO and Mass DOT has approved the paper movement of money into the TIP for 2016 to fund the station design and planning of a Route 16 site without true environmental studies. Even if this station design and planning is to occur, the environmental and disability community have a role which has been denied by Mass DOT and its planners. This is what unreasonable people think since history has proven it correct that these communities have been disenfranchised and marginalized from their proper roles. We understand this is an attempt by proponents and Mass DOT to manipulate the political system for their benefit and that the proponents will likely in this SIP process push for Route 16 to become a mandated destination. But Mass DEP should be aware that we have contended to the FTA Office of Civil Rights that MPO violated the intent of the 23 CFR 450.212 (Public Involvement) in its April 19th meeting where they voted upon these funds by encouraging invitation only of white proponents while leaving out those constituencies and other interested parties who will be impacted by this Route 16 station and may have opposing or other points of view. These populations include the environmental justice and disability communities that will be impacted by diesel particulates, large traffic and parking problems and other issues. The impact of contamination that could occur if piles of dirt are allowed in construction to seep to the Mystic River. The impact to historical canals under the land that could occur. Therefore we support the Mystic Valley Regional chapter of the NAACP in its opposition to the Route 16 site based on the marginalization of this community and that environmental studies must be requested and done within the MPO and Mass DOT process even though new “unqualified” experts at Mass DOT and the MPO can state we don’t need an final environmental impact assessment. The question arises where is the true environmentalist in speaking out about these issues of Route 16 as they speak to particulate issues in Somerville. Have some environmentalist lost their way for the gain in economics and for status in a university? These questions need to be answered. Yet, the reasonable person contends they need no final environmental study. Therefore, GLAM can also claim you do not need the MPO, the Mass DOT and the kind of reform we have seen, which is no reform.

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We have asked once before in this forum where is the reform in this administration? Where are the environment checks and balances? When these checks and balances do not happen, disruption happens. Where are the environmental justice and disability checks and balances in equity studies that take into consideration all the factors, not just what Mass DOT wants to show in their discrete studies of disassociation of larger social structures and process impacts? According to 23 CFR 450.212, a federal regulation, “Public involvement processes shall be proactive and provide complete information, timely public notice, full public access to key decisions, and opportunities for early and continuing involvement.” GLAM contends that the environmental justice and disability community’s voices were marginalized within the MPO Route 16 process against regulation 23 CFR 450.212.6.a “A process for seeking out and considering the needs of those traditionally underserved by existing transportation systems, such as low-income and minority households which may face challenges accessing employment and other amenities.” We also understand that the FTA has provided only a medium rating for this project to College Avenue due to the significant instability of the MBTA finances. The Patrick administration and Mass DOT have proposed to the FTA in our opinion a hypothetical financial plan that is not based in political reality of these uncertain economic times. We also know that the FTA based upon the civil rights compliance review we precipitated around Title VI and ADA has found deficiencies, just as we have found additional civil rights deficiencies around the MPO process of which we have notified the FTA. And the FTA is requiring these issues be addressed as part of the mitigation of this project in the background as its letter points out. But these deficiencies pointed out to Mass DOT over and over again through the Green Line process by GLAM were only addressed by forcing the issue at a higher level of scrutiny at the federal level and moving it out of the region. We conclude that this also is an option when reviewing the lack of true environmental assessment concerning the Green Line project and the continual lack of a proper social equity analysis. Although the pretty language that Mass DOT uses around social equity sounds good, the intent is in the action and we believe that intent is lacking in the environmental assessment. As we doubters and unreasonable people have noted before in the political situation, projects like the proposed Green Line create the disrespect for planning, the disrespect for financial planning and transit planning as the state uses and abuses the system. Unlike Mass DOT or the MPO, GLAM does not discriminate. Hence, we have operatives from the Republican Party who see what we see. Operatives in the Democratic Party who see what we see as well as other groups such as the NAACP chapter and other disability groups. Whom do you think is causing the most disruption in government, these people or the Commonwealth of Massachusetts? Do you think these political people will not bring up these very issues in the next four years, no matter who is President? This situation can lead to a tremendous disruption between the body of politics and groups of people who support the environment, the environmental justice and disability communities in working toward cooperation and compromise. Believe us, we understand this very well. We are stating that you are creating the problem by your reasonableness in not using up to date data and purveying of discrimination. No one is stating they cannot support this project to College Avenue. We are saying you are delaying the project and it is time to correct the problems for those unreasonable

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problems count and you should be mitigating those problems with the planners and the people. After College Avenue you are burdening unduly the very people you claim you are supporting, yet we cannot find any of these people participating in Mass DOT’s process. Even the Regional Transit Advisory Council did not ask for input from these people, the unreasonable or the NAACP. Again, discrimination by the MPO and Mass DOT who like a friendlier crowd as they state in a meeting after the disability community left the room of one of their meetings. Or the discrimination conducted by the MPO recently in inviting only proponents to their meeting on the proposed Green Line/Rte 16 while the abutters, environmental justice and disability communities were omitted, justifying their position using an outdated minor petition made by supporters many years ago. A broadly defined petition that did not mention or address social equity issues pertaining to the environmental justice and disability community even though these issues were plainly out there to be addressed. Mass DOT is well aware there are groups of business people in Medford not in support of this project and who voted against this project at a meeting Mass DOT attended. Just as they are aware that the NAACP chapter has its grave concerns and do not support the Route 16 station. But in Mass DOT’s view, the only representation to be considered in Medford is only those who support this type of discriminatory effort. Yet, no one addresses the MBTA car barn issue in Haines Square Medford, one of the oldest unresolved environmental problems in the city between the MBTA and Medford. But it is so important that we reach Tufts University that all else does not matter. The excuse that the legal court has mandated the proposed Green Line Extension does not seem to hold regard when speaking to other SIP projects such as the Fairmont Line or the extension to Jamaica Plan or the Red Line/Blue Line connector. Is the future more discrimination as pertains to the proposed Green Line project? It surely looks that way and discrimination is reinforced through infrastructure projects for university expansionism programs that are not necessarily inclusive of the environmental justice or disability populations within their student bodies. Nor do these projects represent the intellectual arguments used by the environmental justice or disability community concerning the pushing out of these populations. This SIP project continues to keep out and weed out the process for groups that are the unreasonable people seeking change and progress and doubters asking for the truth. Instead of saying how do we protect from the onslaught, government agencies like Mass DOT create the chaos of continuing social inequity. This is where true educational scholarship needs to apply. These comments are respectfully submitted by GLAM and have been approved by its Executive Committee, listed at the end of this document, at its board meeting of August 15, 2012. Carolyn Rosen Chairperson GLAM

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Respectfully Submitted by:

Ms. Carolyn Rosen, MBA, MTS ADA Coordinator/CFO Chairperson of GLAM Elected member of the Medford Democratic Party and officer Member of the Zonta Club of Medford 25 Bussell Road Medford, Mass. 02155

Ms. Mary Anne Adduci

Secretary of GLAM Board of Director of Arthur D. Little

Alumni Association 2 North Street


William Wood, M.S., M. Ed., Ph.D. Retired Business Owner, Wood & Associates Elected Medford Democratic Party member and Ward Chair Kiwanis Club board member Disability Advocate 25 Bussell Road Medford, Mass. 02155

Mr. Henry Milorin Elected Member of the Medford

Democratic Party Disability Advocate

8 Temple Street Medford, Mass. 02155

Neil Osborne, Esq. President of NAACP Mystic Valley Area Branch 122 Boston Avenue Medford, Mass. 02155

Mr. Bernie Green Chairperson of the Medford

Republican Party Former Elected state representative

for the state Republican Party 608 Main Street


Gwen Blackburn Retired Dir. Of Multi-Cultural Dept. SPED & Harassment liaison, Civil Rights Officer Medford Public Schools 233 Arlington St. Medford, Mass. 02155

Mr. Felix Blackburn EEO/Affirmative Action Officer

State Transportation Authority, Retired Commission Member of the Medford

Traffic Commission 233 Arlington Street


Paul Morrissey Business owner, Aerocycle 642 Boston Avenue Medford, Mass. 02155

From: Neil OsborneTo: Fichter, Katherine (DOT); [email protected].

us; Subject: NAACP Public Comment Greenline ExtensionDate: Sunday, September 23, 2012 1:24:28 PM

I am the President of the Mystic Valley Area Branch of the NAACP. As the local entity of the National Association for the Advancement of Colored People the Mystic Valley branch services the cities and towns of Medford, Arlington, Malden, Everett, Winchester and Woburn. The primary mission of the NAACP and the Mystic Valley branch locally is to ensure the political, educational, social and economic equality of rights of all person and to eliminate racial hatred and racial discrimination. I am compelled to comment on the continued un-addressed concerns of my fellow West Medford neighbors about needlessly extending the Greenline all the way down to Route 16. Historically, West Medford has maintained a high concentration of African American households. Our West Medford community has always been a vibrant open and diverse community. The Mystic Valley Area NAACP remains opposed to needlessly expending limited resources on studying then building an extension that will encroach on the property of neighbors and further invite unwanted development in the part of the city with a historically high concentration of African American families. It is important for the planners involved in this Greenline extension project to know and understand that a majority of the African American community does not welcome the Greenline at Route 16. We ask the question who is in a better position to absorb the burdens of the Greenline terminus? We see terminating the Greenline at College avenue as a better solution for the Medford community then forcing this process on West Medford. If you would like to discuss our position further please feel free to contract me directly at 617-482-1160 or you may want to speak with members directly which can also be arranged. I hope you find this correspondence helpful as we felt compelled to share how unwanted this project is viewed in our community.


mailto:/O=MASSDOT/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=Katherine.Fichter



Neil Osborne, Pres. Mystic Valley Area Branch NAACP

September 24, 2012

Katherine S. Fichter Jerome Grafe

Massachusetts Department of Transportation Massachusetts Department of Environmental

Office of Transportation Planning Protection

10 Park Plaza, Room 4150 Bureau of Waste Prevention

Boston, Massachusetts 02116 One Winter Street

Boston, MA 02108

RE: 2012 State Implementation Plan Transit Commitments Status Report

Dear Ms. Fichter and Mr. Grafe:

The Conservation Law Foundation (“CLF”) has reviewed the State Implementation Plan

(“SIP”) Transit Commitments Status Report filed on July 2, 2012 (“2012 SIP Status Report”).

We are pleased that the Commonwealth continues to advance SIP projects and appreciate the

progress that has occurred during the last year. At the same time, however, CLF remains

concerned about the escalation of estimated project delays, particularly those announced last

year, and the lack of sufficient expenditure of funds to ensure that all of the remaining SIP

projects are completed on schedule. The Commonwealth’s legal obligation to complete these

projects is binding under the federal Clean Air Act and pursuant to the settlement agreement in

CLF v. Romney et al., United States District Court for the District of Massachusetts, Civil Action

No. 05-1048 (hereinafter, CLF v. Romney); the projects are crucial to achieving attainment of

ambient air quality standards, and are vital to the health and mobility of the area’s residents.

The SIP requires that status reports be filed annually to ensure that projects do not fall

behind schedule and the necessary steps are taken so that compliance with the Clean Air Act is

not delayed in the event that challenges arise. We urge the Massachusetts Department of

Transportation (“MassDOT” or “Department”), the Massachusetts Department of Environmental

Protection (“DEP”), and the U.S. Environmental Protection Agency (“EPA”) to take all

necessary actions to respond to the delays, reduce them, and avoid the need for additional future

delays. This should include the provision and implementation of detailed and expedited project

schedules, and, where necessary and permissible, identification and implementation of interim

emission reduction offset projects or measures. See 310 CMR 7.36(4). Such interim offset

projects or measures should be identified through a transparent and thorough community public

participation process. In addition, CLF requests that DEP require a mid-year status report to be

filed by MassDOT by December 31, 2012, on the Fairmount Line Improvements, the Green Line

Extension, the construction of 1,000 additional parking spaces, the design of the Red Line/Blue

Line Connector, and the Blue Line Platform Lengthening and Modernization, since all of these

projects are significantly behind schedule. More detailed comments on each of the projects

discussed in the SIP Status Report and the need for interim offset projects or measures are

provided below.

Green Line Extension

Since the 2012 SIP Status Report was released, MassDOT and the MBTA have received

full federal environmental approval for the Green Line Extension project. The Federal Transit

Administration (“FTA”) released a Finding of No Significant Impact (“FONSI”) for the project.

Earlier, in June of 2012, the MBTA also received approval from the FTA for the Green Line

Extension project to enter preliminary engineering. These are big steps towards completion of

this SIP requirement.

Nevertheless, the Green Line Extension project unfortunately continues to be plagued by

delays, which MassDOT has not fully explained. In its 2011 SIP Status Report, MassDOT

reported that the Commonwealth would not meet the SIP deadline of December 31, 2014 for the

Green Line Extension project. MassDOT stated that the new estimates for the delays of the

Green Line Extension project stem from a risk assessment that was performed based on the

results of a FTA Project Management Oversight Consultant Risk Assessment Workshop (“Risk

Assessment”). See 2011 SIP Status Report at 17. In its 2012 SIP Status Report, MassDOT

estimates that service to College Avenue Station will open by July 2019. The Risk Assessment,

however, states in its executive summary that the “schedule risk modeling points to a revenue

service date that could slip from October 2015 to the range of March 2017 to December 2017”

(emphasis added). See Risk Assessment Green Line Extension Report dated August 1, 2011, at

i. MassDOT provides no explanation for the additional nineteen months delay in its petition to

DEP, its 2011 and 2012 SIP status reports, or otherwise, which violates the Transit System

Improvement regulations. See 310 C.M.R. 7.36(4)(c). Regardless of the reporting requirement,

this new timeline is clearly inconsistent with the SIP and the 2006 CLF v. Romney settlement

agreement.

As a result of these delays, the Commonwealth is required to implement interim offset

projects or measures, which are required to achieve emissions reductions equal or greater than

the emissions reductions that would have been achieved had the project not been delayed. See

310 C.M.R. 7.36(4)(b). Since last year’s SIP report, MassDOT has accepted recommendations

for interim offset projects and measures from the public and worked with the Central

Transportation Planning Staff (“CTPS”) and the MBTA to calculate the reductions NMHC, CO,

NOx associated with projects and measures under consideration. MassDOT should continue to

involve the public in the identification and selection of any interim offset projects or measures.

CLF together with other stakeholders, in a letter dated September 22, 2010, provided a list of

suggested interim offset projects and measures to MassDOT. CLF was pleased to see that

MassDOT considered and analyzed many of these suggestions, but unfortunately not all of them.

2

Specifically, the following feasible and effective suggestions were not analyzed: signal

prioritization for buses on high usage streets in Somerville, Medford, and Cambridge; improved

pedestrian crosswalks and signal timing at Monsignor O’Brien Highway and Land/Gilmore

bridge; removing elevated portions of the McGrath highway and converting a portion of the right

of way to bike/bus only lanes; and instituting free or reduced Hubway bicycle memberships for

residents within half a mile of future Green Line stations. These interim offset projects and

measures should be analyzed so that they can be considered as options for implementation.

Ultimately, all interim offset projects and measures should be located in the

neighborhoods that are intended to benefit from emissions reductions attributable to the Green

Line Extension project. While CLF recognizes that keeping the interim offset projects and

measures in the same neighborhoods as the delayed transit commitment is not a legal

requirement of the SIP, we strongly believe that failing to adhere to this approach would be

patently unfair. CLF therefore strongly recommends that all interim offset projects and measures

considered be located in and serve the Somerville, Medford and Cambridge neighborhoods that

are adjacent to the extension of the Green Line. All interim offset projects and measures shall

achieve emission reductions equal to or greater than the emission reductions that would have

been achieved had the project not been delayed.

Repeating last year’s and the previous year’s SIP Status Report omission, the 2012 SIP

Status Report also does not provide adequate information about the Commonwealth’s funding

plan for the Green Line Extension. See 310 C.M.R. 7.36(7). CLF hereby renews, once again, its

request that MassDOT complete and make publicly available a detailed funding plan for the

Green Line Extension Project. The funding plan should cover the fifty percent state match

required if the project receives federal funds through New Starts as well as the complete

projected capital costs of the project in case no federal funding is obtained. The 2012 SIP Status

Report states that while the Green Line Extension project is “in many ways, an excellent

candidate for the New Starts Program,” “the fundamental financial realities facing the MBTA”

are a real hindrance to obtaining federal funding. See 2012 SIP Status Report at 20. It is CLF’s

hope that the Commonwealth in 2013 will address its transportation finance challenges in

general and the MBTA’s budgetary needs specifically.

CLF continues to be troubled by the proposed segmentation of the Green Line Extension

Project, which makes even less sense if one considers MassDOT’s proposed delays of the project

and that the Boston Region Metropolitan Planning Organization has included the segment of the

Green Line Extension between College Avenue and Route 16 in its most recent Transportation

Improvement Program. To comply with the SIP, MassDOT must construct an extension of the

Green Line “from Lechmere Station to Medford Hillside” by December 31, 2014. See 310

C.M.R. 7.36(2)(j)1. The Green Line Extension Project, as proposed, does not comply with the

SIP, since Medford Hillside’s well-documented historical boundaries do not include the location

3

of the proposed terminus at the intersection of College Avenue and Boston Avenue.1

Any

interim offset project or measure selected for the delay the project should therefore include the

full air quality benefits expected from the extension to Route 16.

Fairmount Line Improvement Project

Although significant progress has been made on the construction of the Fairmount Line

Improvement project, e.g., construction of the Talbot Avenue Station and the Talbot and

Woodrow Avenue bridges rehabilitation projects is 90% complete, further delays continue to

proliferate. While last year the MBTA anticipated final completion of the Newmarket Station by

February 2013, the new estimate, August 2013, adds another six months of delay. Likewise, the

Four Corners Station was expected to be open for service by November of 2012 and now is

estimated to be complete six months later, in May of 2013. Last year’s update anticipated

construction of the Blue Hill Avenue Station to start by May of 2012, but as of July of 2012 the

station had only reached the 60% design stage and this year’s update states that “it is unlikely

that the Blue Hill Avenue Station will be completed before 2015 at the earliest.” See 2012 Status

Report at 5.

To this end, MassDOT has implemented two interim offset measures: shuttle bus service

from Andrew Square to Boston Medical Center and increased weekday bus service on the Route

31 bus which serves Mattapan and Dorchester. We were pleased to see that the offset measures

incorporate one of the ideas that the Fairmount/Indigo Line Coalition (the “Coalition”) put

forward (shuttle bus service from Andrew Square to Boston Medical Center) and that both

measures are targeted to benefit the neighborhoods most impacted by the delay in the Fairmount

Line.

At the same time, we were disappointed that the MBTA did not include a fare reduction

on the Fairmount Line during the period of delay as one of the interim emission offset measures,

as was proposed by the Coalition last year. By fare reduction, we refer to making the $2.00

transit fare applicable to the whole line, including the two stations in Hyde Park (Fairmount and

Readville) which now have fares of $5.50 and $6.00 respectively. The Coalition proposed this

offset measure because it would most directly help the people impacted by the delay in the

construction of the stations. Moreover, it would have offered a great opportunity to help market

the Fairmount Line as the stations are being built and work towards increasing ridership, whereas

the increased bus service proposed distracts from the opportunity to promote usage of the

Fairmount Line. Measures to improve service and increase ridership on the Fairmount Line are

1 For a more detailed explanation of this issue, please see CLF’s comments on the Draft and Final Environmental

Impact reports for the project available at

http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.

pdf and at http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf

respectively.

4

http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.pdf

http://www.greenlineextension.org/documents/FinalEIR/Vol2and3/71_GLX_FEIR_V2_CommOrg3of5_20100615.pdf

http://www.greenlineextension.org/documents/FinalEIR/certificate/FEIR_CommentsPart4.pdf

required by the SIP. See 310 CMR 7.36(2)(h)1. CLF therefore respectfully requests that DEP

require the inclusion of the fare reduction as one of the interim emission offset measures to

counter the negative impacts of the delays of the Fairmount Line Improvement Project going

forward, particularly since the completion of the project has been delayed even further.

Construction of 1,000 New Parking Spaces

CLF appreciates that after originally planning to delay the construction of the 1,000 new

parking spaces required by the SIP without implementing an interim offset project or measure, in

response to CLF’s comments, MassDOT provided increased Saturday bus service on MBTA

Route 111. This additional service began on January 7, 2012, the first Saturday following the

December 31, 2011 deadline, and continued until parking at the Wonderland Station was

completed.

CLF, however, cannot agree that the Commonwealth has fulfilled this SIP requirement.

In addition to South Garage at Wonderland, MassDOT is also counting almost four hundred

existing parking spaces in Beverly, Dorchester, Newton and Quincy towards this transit

commitment. To comply with the SIP requirement, however, 1,000 additional parking spaces

have to be constructed rather than merely provided. See 310 CMR 7.36(2)(h)2 (“Before

December 31, 2011, construction of the following facilities shall be completed and opened to full

public use:…1000 new park and ride parking spaces serving commuter transit facilities…”)

(emphasis added). The parking spaces near the Beverly commuter rail station, at least, appear

only to have been opened to the public but were not newly constructed. After CLF pointed out

last year that the MBTA was not listing any parking spaces at the Savin Hill Station on its

website, the MBTA now states that there are eighteen parking spaces. See

http://www.mbta.com/schedules_and_maps/subway/lines/stations/?stopId=14289&lat=42.31109

9&lng=-71.053175 (last visited September 14, 2012). MassDOT, however, is counting twenty

spaces towards the completion of this requirement. See 2012 Status Report at 9.

In addition, CLF continues to remain concerned that due to the multi-use nature of the

Waterfront Square development at Wonderland, the number of parking spaces actually available

for users of the MBTA’s public transit system will be smaller than predicted and therefore too

small to contribute sufficiently to SIP compliance. South Garage was constructed adjacent to the

Waterfront Square development at Revere Beach, which will include new retail outlets,

residential units, offices and a hotel. In addition to the existing public beach, these new

buildings constitute a significant draw for automobile traffic. There is therefore a strong need to

ensure that sufficient parking is reserved for MBTA customers. As planned, South Garage,

unlike the garage planned for the Waterfront Square project, include parking for MBTA

customers, but not all spaces in the garage are reserved for transit riders. See MBTA South

Garage Environmental Assessment (dated January 11, 2010) at 1-2. The only way to ensure that

a parking garage that serves more than just a commuter transit facility consistently has enough

5

http://www.mbta.com/schedules_and_maps/subway/lines/stations/?stopId=14289&lat=42.311099&lng=-71.053175


space available for transit riders is to reserve a specific number of parking spaces for MBTA

customers at all times and implement a system, such as parking ticket validation, which enforces

such restriction. From the MBTA’s website, it appears, however, that no such plans have been

put into place for South Garage. See

http://www.mbta.com/schedules_and_maps/subway/lines/stations/?stopId=15415&lat=42.41396

3&lng=-70.990986. The contribution of sufficient transit commuter parking spaces from South

Garage to meet the SIP requirement can therefore not be guaranteed.

We therefore urge DEP to require MassDOT to address these issues and to continue

report on this requirement in SIP status updates until there is full clarity that this requirement has

been completed.

Blue Line Platform Lengthening and Station Modernization

MassDOT failed to include the Blue Line Platform Lengthening and Station

Modernization project in its 2012 Status Report. CLF disagrees with MassDOT’s continued

claim that its obligations under this SIP commitment are complete by virtue of implementing six-

car train service despite the failure to modernize all Blue Line stations. The SIP requires both

Blue Line platform lengthening and station modernization. See 310 CMR 7.36(2)(g) (“Before

December 31, 2008, construction of the following facility shall be completed and opened to full

public use: Blue Line Platform Lengthening and Modernization.” (emphasis added)).

MassDOT’s failure to report on this commitment therefore violates the law. Furthermore, both

components of this project are necessary to achieve the increased ridership and attendant

improved air quality required under the Clean Air Act through the SIP. Increased ridership is a

function of available capacity, access, and attractiveness of service. Modernization of old,

inaccessible, uncomfortable, and otherwise non-user friendly stations and facilities leads to

increased ridership and thus to improved air quality.2

The failure to modernize all Blue Line stations is a continuing violation of the SIP, which

required that Blue Line station modernization be completed by December 31, 2008. As of

September of 2012, the following stations have been modernized: Aquarium, Beachmont,

Revere Beach, Suffolk Downs, Wood Island, Wonderland, Maverick, and State. The difference

in appearance of the stations that have been completed speaks volumes for the importance of this

requirement.

See, e.g., Stacey Falzarano, Richard Hazlett, and Thomas Adler, Quantifying the Value of Transit Station and

Access Improvements for Chicago’s Rapid Transit System (Transportation Research Board Paper No. 01-2987, Jan.

2001).

6

2



We are pleased that construction at the Orient Heights Station has commenced this year

and continues to be in progress. This project will make the station fully accessible to all

passengers as well as make large scale improvements to modernize the station. The work will

include installation of a new overhead pedestrian bridge, four elevators and two escalators, new

mechanical and power systems, a renovated Train Operations Building and improvements to the

bus access areas. CLF is particularly pleased that the Orient Heights Station Project has been

designed to be consistent with MassDOT′s “GreenDOT” policy and that fencing has been

erected to separate the current work zone from the temporary station, which will allow Orient

Heights to remain open to the public during the lion’s share of the construction period. The

MBTA has indicated that it expects the project to be completed by the spring of 2014.

The delays in modernizing the Orient Heights, Government Center, and Bowdoin Blue

Line stations are significant and the reasons for them largely unspecified. DEP should therefore

require continued status update reports and interim offset projects or measures to compensate for

the delay. MassDOT, in turn, should make every effort to hasten the completion of this overdue

commitment.

CLF remains pleased that all work has been completed to accommodate six-car trains and

that eighty-two new Blue Line vehicles have been in service since September 15, 2008. This is a

major achievement. The increased capacity on the Blue Line is already relieving overcrowding

and improving quality of service for riders. When coupled with full modernization of the Blue

Line, CLF is confident that even more riders will be attracted to the service and this increased

capacity will be well-utilized.

Red Line-Blue Line Connector

The Commonwealth included in its 2008 revised SIP the design of the Red/Blue Line

Connector (“Connector”), recognizing and relying on the associated air quality benefits. Last

year, only three years after the revised SIP was approved, MassDOT denied that the same project

has any merit and sought to remove it from the SIP claiming that it does not help the state meet

national ambient air quality standards. In its request to DEP, MassDOT reasoned that there are

no air quality benefits associated with the design of a transit project, calling it a “purely

procedural requirement,” which begs the question why the Commonwealth would have included

the Connector in the revised SIP in the first instance. In any event, the Commonwealth should

be precluded from arguing now that the design of a transit project has no calculable air quality

benefits.

Moreover, there can be no dispute that there are air quality benefits associated with

designing a transit project. For a transit project to be constructed, it has to be designed first.

Frequently, funding becomes available for a transit project only after it has been designed. As a

result, air quality benefits can be calculated by applying a discounted percentage of those the

7

constructed project would produce. This percentage can take the estimated likelihood of

construction, at the time of the inclusion in the SIP, into consideration. In 2006, the

Commonwealth estimated that the Connector would reduce emissions of carbon monoxide by

156 kilograms, nitrogen oxides by 4 kilograms, and volatile organic compounds by 9 kilograms

per day. See DEIR, Appendix E, at 3-16 and Central Transportation Planning Staff (“CTPS”),

“Description of Modeling Assumptions and Analysis Methodology for the State Implementation

Plan Transit Commitment Projects Current and Proposed Substitutions,” December 28, 2006,

revised March 15, 2007 (“2006 SIP Analysis”). Even if discounted by ninety percent, the design

of the Connector would still provide emission reductions of 15.6 kilograms for carbon monoxide,

0.4 kilograms for nitrogen oxides, and 0.9 kilograms for volatile organic compounds per day.

The fact that these air quality benefits from the Connector were previously not included

in the air quality model for the revised SIP does not make the project any less of an obligation.

The EPA approved the revised SIP expecting that the estimate for the revised SIP is leaving the

Commonwealth some room for error—the Connector helped to create that necessary buffer.

Thus, it is not permissible for the Commonwealth to simply remove that project now.

Ultimately, the SIP must facilitate the Commonwealth’s attainment of compliance with the

NAAQS. Currently, classification and designation status for the 1997 eight hour ozone standard

in Eastern Massachusetts remains moderate non-attainment. See 77 FR 31496 (May 29, 2012).

DEP should therefore reject MassDOT’s flawed logic and should not amend the Transit System

Improvement Regulations, as recently proposed.3

Despite MassDOT’s grim prognosis of the availability of federal funding, increasingly

only projects that are shovel-ready are eligible to apply when federal funding opportunities arise.

Thus designing a transit project, more than anything else, raises its chances of ever being built.

One new opportunity for potential funding, for example, only recently became apparent and, to

the best of our knowledge, the Commonwealth has not pursued it yet. The Commonwealth

should request that the owners and developers of the proposed casino at Suffolk Downs

contribute significantly to the Connector as a condition precedent to proceeding with their

project.

It is also worthy to note that, in an attempt to justify its request to simply be relieved from

an important SIP requirement, although only a few years have passed, MassDOT last year

claimed that the cost of designing the Connector has gone up significantly. See MassDOT

Request to Amend Transit System Improvement Regulations dated July 1, 2011 (“Request”) at 3.

MassDOT explained that the design costs, which are typically ten percent of the total

construction costs, have increased because the ultimate construction costs of the project were

estimated to “far outstrip” the cost projections in place at the time that the SIP regulation was

3 CLF has commented separately on the proposed amendment of the Transit System Improvement Regulations both

orally at a September 13, 2012 public hearing and in writing in a letter dated September 14, 2012.

8

promulgated. Id. MassDOT listed a number of factors that may have contributed to an increase

in the estimated cost of the Connector. See id. at 3-4. Among those, MassDOT admitted to

budgeting a much more conservative contingency for the most recent cost estimate, but failed to

disclose that it also included a higher inflation rate. Likewise, MassDOT did not explain that it

used less favorable assumptions to estimate the cost of the Connector than any other transit

project it currently is planning. But without markups, the raw-cost estimate for construction of

the Red Line/Blue Line Connector is about $336 million rather than the $748 million figure

MassDOT relied upon to support its request. See Red Line/Blue Line Connector Project 10%

Design Cost Estimate, Basis of Estimate, at 1. At the time of the SIP revision, in July of 2008,

the Commonwealth’s estimate was $290 million for construction of the project.

Specifically, the total cost estimated for the Connector included a forty percent

contingency (up from a twenty percent contingency applied in earlier planning stages of this

project) and an inflation rate of 4.2% (although construction cost changes currently are under

two percent as is general inflation, and inflation is not expected to increase significantly any time

soon). To make matters worse, these add-ons are not applied equally to every project MassDOT

is planning. As a comparison, for the ongoing South Coast Rail Project, MassDOT applied a

lower contingency (31.70% instead of 40%), a lower inflation rate (3.25% instead of 4.20%), and

a lower design cost estimate (13.44% of present construction cost not including the contingency

instead of 14% of present construction cost plus the contingency which translates into 19.6%

without the contingency). See South Coast Rail, Alternative Description Technical Report at 4-

53 (September 2009). Thus, a careful review of MassDOT’s numbers reveal that the “dramatic

increase” in project costs it describes in its letter is also a result of the application of a

particularly and deliberately conservative budgeting approach for the Red Line/Blue Line

Connector.

Amending the Transit System Improvement Regulations would relieve the

Commonwealth from an obligation to design a critical transit project that has great potential to

help Massachusetts comply with the NAAQS without proposing any other project to take its

place. Any concerns with the lack of immediate funding for this project could be addressed by

either substituting the project or amending the regulations to provide for a deadline extension.

To evaluate any potential substitution, DEP should require MassDOT to remodel the air quality

benefits expected from the projects in the revised SIP and then compare them to those of the

remaining transit system improvement projects without the Connector. For the reasons stated

above, we respectfully request that DEP not amend the Transit System Improvement

Regulations, as currently proposed and require MassDOT to continue to include this project in its

SIP update reports.

9

cc

Conclusion

The projected delays for the Green Line Extension, the Fairmount Line Improvements,

the claim that all the 1,000 additional park and ride parking spaces serving commuter transit

facilities have been constructed, the failure to acknowledge that the Green Line Extension as

planned does not comply with the SIP, the request to eliminate the requirement to design the Red

Line/Blue Line Connector, and the continued delay of the Blue Line Platform Lengthening and

Modernization raise serious concerns regarding the lawfulness of MassDOT’s activities and its

compliance with the SIP. DEP must therefore provide greater oversight and order MassDOT to

comply with all the requirements of the SIP and MassDOT must allocate all needed funding and

take all necessary steps to complete the SIP commitments as quickly as possible.

Thank you for the opportunity to comment.

Sincerely,

Rafael Mares

Staff Attorney

Donald Cooke

Air Technical Unit

US Environmental Protection Agency - Region 1

5 Post Office Square, Suite 100

Mail Code OEP05-2

Boston, MA 02109

10

Kenneth J. Krause

50 Mystic Street Medford, MA 02155 781-396-0920 [email protected]

September 25, 2012

Kate Fichter MassDOT Office of Transportation Planning Room 4150, Ten Park Plaza Boston, MA 02116

Jerome Grafe MassDEP, Bureau of Waste Prevention One Winter Street, 6th Floor Boston, MA 02108

Dear Ms. Fichter and Mr. Grafe,

Thank you for the opportunity to comment on the annual update and status report for transit projects required by 310 CMR 7.36 (2) (f) through (j) that was submitted by the Massachusetts Department of Transportation (MassDOT) to MassDEP on July 2, 2012.

Green Line Extension to Somerville and Medford Unlike the 2011 annual update and status report, which announced another substantial delay in the completion timetable for the Green Line Extension (GLX), the 2012 report summarizes what I would term the most constructive year of work and progress on this project in the eight-plus years I have been engaged as an interested citizen and former advisory group appointee.

While we all would like to see the extension completed before the current mid-2019 estimate, for the first time, I believe the project team has a realistic and achievable construction timetable in place, outlined in the four-phase scenario introduced in the past year. It is encouraging to see firm dates projected for each phase of the GLX timeline, the most exciting of which is the long-awaited start of construction this fall.

Other positive developments as stated in the report are the advanced station designs, including the pedestrian, bicycle and bus networks around them; approval of the CMGC delivery method for certain segments of the project; and the completion of the state environmental review process and progress on the federal level environmental review.

I would also like to commend the HDR/Gilbane consultant team for its professionalism (and candor) in performing its work, and to recognize all parties involved for the smooth and seamless transition of the project from MassDOT’s direction to the MBTA.

Two other positive developments over the last year but not mentioned in the report were:

Kenneth J. Krause - 2012 SIP Annual Report


+ The continued support of the Green Line Extension by the Boston Region Metropolitan Planning Organization—allocating funds not only for the scope of work to Union Square and College Avenue, but also recommitting $190 million to design and construct the final leg of the extension to its permanent terminus at Mystic Valley Parkway, action that had the support of Medford Mayor Michael J. McGlynn at Tufts University, in addition to Somerville Mayor Joseph Curtatone.

+ The year-long Mystic Valley Parkway Community Visioning Process, conducted by the Metropolitan Area Planning Council, which thoroughly and thoughtfully examined the impacts and opportunities surrounding a Green Line station at Route 16 and summarized them in a very readable and useful report that will be a valuable tool for the cities of Medford and Somerville as they analyze potential redevelopment of the area.

The Mystic Valley Parkway station is integral to the state fulfilling its legal requirement to extend the Green Line to Medford Hillside. While the MPO funding designation is critical, it is equally important that planning for the Route 16 station move forward in order to correspond with the detailed funding scheme approved by the MPO for each of federal fiscal years 2016 through 2021:

This is an issue I would like MassDEP to address in the course of approving the 2012 update and annual status report by asking MassDOT for clarity around its plans to formalize its schedule, and devote planning resources, for the Mystic Valley Parkway station.

If there was one area in which I felt the project team fell a bit short in the last year it is in failure to engage the Green Line Extension Design Working Group in any meaningful way. While there were three station workshops conducted, and public meetings on the Phase I construction scheme and on Noise and Retaining Walls, there has not been a


meeting of the Design Working Group since early December 2011. This is a very knowledgeable and capable advisory group, willing and eager to contribute to the success of this project, and it should not be excluded from the process.

With Phase I construction about to begin in a matter of weeks, a new consultant team coming on board to execute final design, and several new and lingering design issues identified in the latest monthly status report (September 20, 2012) for the GLX, it would behoove the project team to have a full Design Working Group meeting as soon as one can be scheduled.

My other criticism regarding the last year’s project developments pertains to MassDOT’s initial analysis and response to public suggestions for Interim Offset Projects that MassDOT must implement for missing the GLX completion deadline of December 31, 2014. In presenting a summary grid of the suggested projects, MassDOT dismissed virtually all of them for one reason or another, even before any modeling for their potential air quality benefits had been done. There were many worthy and feasible projects proposed, two of which I will address in the following section.

Red Line/Blue Line Connector Design As stated in a separate comment letter, I urge MassDEP to reject MassDOT’s request to be relieved of its legal obligation to complete the design of the Red Line/Blue Line Connector. The need to connect the only MBTA heavy rail lines that do not intersect has never been greater. The corridor served by these two lines continues to experience explosive growth, particularly in new jobs and housing that has been created or is under development in Cambridge, South Boston, and East Boston.

More significantly, Suffolk Downs – on the Blue Line in East Boston – is a leading candidate for a casino gambling license that, if granted, would trigger a huge redevelopment of the race track into a resort casino that would attract thousands of visitors and employees daily. (And, according to the September 21, 2012 Boston Herald, a developer also is examining the possibility of South Station – on the Red Line in Boston – as a casino location.)

The introduction of a casino in one of these locations is just one more reason why the Red/Blue Connector design should not be removed from the SIP transit commitments. If anything, this should elevate the importance of the project and jump-start work on the next phase – with the financial support of Suffolk Downs should it be granted a casino license, as is widely expected.

Suffolk Downs officials already have pledged financial support for roadway improvements on Route 1 near the race track, but have overlooked the need to improve public transit service to the area. Meanwhile, other private entities have recently stepped up and offered financial contributions to the creation of commuter rail stations, most notably New Balance Company for its new campus in Brighton, and Raynham Park in Taunton should it receive a slot parlor license. Suffolk Downs should be approached for a similar commitment.


Also, MassDOT’s major reason for asking to be relieved of its SIP Red/Blue requirement – that it has been unable to identify funding to construct the Red/Blue Connector “at any point in the next 20 years” – is not a sound one, in my view. Few projects in that time horizon have a fully identified funding source, yet planning wisely continues on the projects deemed most valuable (which I submit the Red/Blue Connector is one) so they are shovel-ready when funding is secured for them.

Curiously, MassDOT continues to aggressively pursue the South Coast Rail project – with Governor Patrick as recently as last week meeting with EPA officials and others in Washington to try to advance this project past regulatory hurdles – despite the fact that it is neither a SIP Transit Commitment project, nor does it have any construction money appropriated at this time.

My opinion is that the Red/Blue Connector is an immensely valuable project that is integral to the efficiency of the MBTA system and its ability to meet increasing ridership demands, and therefore should not be removed as a SIP requirement.

However, should MassDEP agree with MassDOT’s request to cease work on the Red/Blue Connector, it must require MassDOT to identify substitution projects and commit to building them via inclusion in the SIP. The most logical, practical and environmentally beneficial substitution project to add is construction of the permanent terminus for the Green Line Extension at Mystic Valley Parkway (Route 16).

Not only is this location MassDOT’s Preferred Full Build Alternative for the Green Line Extension and has unanimous support from all major stakeholders, but it is a project – unlike Red/Blue – for which the state has identified a funding source, and not over a 20-year horizon, but in the next eight years, as noted above in reference to the Boston Region MPO’s funding support.

It is imperative that the state align its planning and funding resources so that they are focusing on the same goals (and the same projects). The addition of construction of the Green Line Extension to Route 16 to the SIP would be the perfect substitution project for the elimination of the Red/Blue Connector design (which already had been scaled back from the original SIP commitment, which was for design and construction).

My final suggestion regarding MassDOT’s amendment request is for MassDEP to require MassDOT to appropriate $26 million – the difference between the original $29 million estimate for the Red/Blue Connector design and the $3 million already spent on it – toward the Interim Offset Projects that the state is required to implement as a penalty for missing the deadlines to complete two other SIP projects: the Fairmount Commuter Rail enhancements, and the Green Line Extension.

Specifically, a large portion of this money should be designated to be spent on two Interim Offset Projects in the Green Line Extension corridor:

+ Construction of the multi-use pathway from Harvard Avenue at the West Medford/Arlington line to the Malden Bridge between Somerville and Everett, as described and mapped in the Mystic River Reservation Master Plan of November 2009.


+ Construction of the extension of the Somerville Community Path in all applicable geographic areas contained in Phase I of the Green Line Extension construction, which has a completion timetable concurrent with the deadline for implementation of the Interim Offset Projects (December 31, 2014). In particular, this should include the design and construction of the Community Path from Inner Belt to North Point, where development construction is under way and increasing rapidly. Now is the time to integrate the Community Path in this area.

Both of these projects will provide significant regional mobility and air quality benefits by providing safe, accessible and inviting routes for bicycling and walking (including improved access to transit) that will make these modes an attractive and viable alternative to driving in this badly congested and polluted corridor.

MassDEP’s role Finally, I would like to stress the important role that MassDEP must play in seeing to it that these vital transit projects are completed as soon as possible.

There is a reason the Green Line Extension, unlike quite a few other transportation projects, has survived over the 21 years since it became a SIP commitment and eight-plus years of intense planning: it is a phenomenal project with positive implications for regional mobility, air quality, economic development, and transit equity that become more profound with each passing year.

Just look at the development in progress currently along the GLX corridor, from several buildings at North Point, to Maxwell’s Green at Lowell Street in Somerville, to the expansion of the 200 Boston Avenue building in Medford. These projects are all being executed with the anticipation and expectation of the Green Line Extension becoming a reality. I shudder to think what are roads and air will be like should these and other developments proceed apace, while the Green Line Extension languishes, or worse.

I encourage MassDEP to remain fully engaged in the state’s progress toward fulfilling its obligations of the remaining SIP projects, and also to be a vocal advocate for the state legislature to create a sustainable funding mechanism in support of all of the commonwealth’s many transportation needs, without which, the environmental and health benefits expected from these projects might never be realized.

Thank you for your consideration.

Ken Krause

Ken Krause 50 Mystic St. Medford, MA 02155 781-396-0920

cc: David Mohler, Boston Region MPO Richard Davey, Secretary of Transportation


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TRANSPORTATION • lAND DEVELOPMENT • ENVIRONMENT

33 Broad Street I Suite 300 I Boston, MA 02109 Tel: 617-502-6240 I Fax: 617-502-6236

WWW.AB ETIERCITY. ORG

September 25, 20I2

Kate Fichter Jerome Grafe MassDOT Office of Transportation Planning MassDEP Bureau ofWaste Prevention I 0 Park Plaza, Room 3I70 One Winter Street Boston, MA 02I I6 Boston, MA 020 I8

Via e-mail: [email protected] [email protected]

Re: MassDOT Transit System Improvements: SIP - Transit Commitments, 20 I2 Status Report


On behalf of A Better City (ABC), I am pleased to submit the following comments on the 20I2 status report on transit commitments of the State Implementation Plan. We are particularly focused on the expected delay in implementation of the Green Line Extension Project, which is a critical part of the overall transit system that will serve the region in the future. Air quality benefits associated with this project are an important contribution, along with its transportation improvements. Both sets of benefits should be provided in the near term with implementation of effective offset measures.

A Better City is a membership organization that advocates for sustainable transportation and development policies and projects that achieve high standards of design, support economic development, enhance mobility, and provide environmental benefits.

We remain concerned that the proposed interim emission offset projects being considered for mitigating the delay in Green Line Extension Project implementation do not provide sufficient transportation and other associated benefits in addition to the air quality improvements in the project corridor.

We have reviewed the list.ofproposed measures and the analysis by CTPS. We believe that there are many fine candidates for implementation within the Green Line transit ridership area, with a variety of benefits associated with each measure. One approach to selecting options is to choose measures that will not only provide air quality benefits, but will also address other worthwhile objectives and provide high levels of transportation, economic development, environmental justice, and environmental benefits.

One such measure that deserves further consideration is construction of a bridge between North Point in Cambridge and Inner Belt in Somerville that provides benefits in these areas. The bridge in this location would serve several important functions:

(I) It provides the critical link of the "community path" bicycle trail through Somerville, which has been prioritized as part of Green Line Extension planning, through North Point to the Charles River Basin, which is a very significant element in the "Green" environmental contribution of the Green Line Extension.

(2) It provides for important connectivity from the North Point development to the Inner Belt area of Somerville and Sullivan Square, reducing the pressure on the heavily congested McGrath and O'Brien Highway, and greatly enhancing the economic development potential of the Inner Belt/Brickbottom area.

(3) It provides an efficient path for bus service connecting the Orange Line at Sullivan Square to the Green Line at Lechmere and the Red Line at Kendall, which is a connection identified as important in the Needs Assessment ofthe Boston MPO's recently adopted Regional Transportation Plan. This connection is a "missing link" in the transit network that will provide essential connectivity between the dynamic Kendall Square area, the newly revitalized North Point development at Lechmere, the Inner Belt/Brickbottom area of Somerville, and the regional node at the Orange Line Sullivan Square station, as well as potentially beyond to brownfield areas in Everett and Chelsea. Beyond Chelsea, the corridor will to connect to Logan Airport via the new Chelsea Bridge and the East Boston/Chelsea Bypass Road, currently under construction by Massport.

Completion of this bridge would be another link in the incremental implementation ofthe Urban Ring concept currently in various stages of design and construction in Roxbury, East Boston, and the Fenway. The Urban Ring initiative is vital to the continued expansion of the Boston region's knowledge-based economy. It can also help to reduce congestion in the central subway system recently highlighted as an issue in a study prepared by the Urban Land Institute.

When the State suspended planning on the Urban Ring in January 2010, it was with the explicit commitment to continue to prioritize the Northern Tier, an important segment of the Urban Ring corridor serving the Environmental Justice community in Somerville, Everett, and Chelsea by improving connections to the Orange Line and the Blue Line.

We concur with many comments made in past public hearings and in previous communications from interested parties regarding objectives for the offset measures, including:

• The desire to complete the bridge from Inner Belt Road to North Point to accommodate the community path and bus service along the Urban Ring route.

• Locating interim offset measures in the Green Line Extension corridor. • Reducing headways on MBTA bus routes in the Green Line corridor in Somerville,

Medford, and Cambridge to help reduce vehicle miles traveled. • Using low-emission buses in these and other routes in the area to improve air quality.

ABC believes that the most significant mitigation for Green Line Extension slippage is not only to plan for the Urban Ring, but to actually implement early action transportation improvements in the Urban Ring corridor, at least from Kendall to Sullivan. This can be done in two stages:

( 1) As soon as possible, but in no case later than 2014, institute a new bus service from Kendall Square/MIT Station via Third Street, Binney Street, and First Street to the existing Lechmere Station, and beyond to Sullivan Square Station. Because the North Point Boulevard to Inner Belt link does not yet exist, the component of the new Urban Ring service between Lechmere and Sullivan Square may have to be routed temporarily via O'Brien Highway, Poplar Street, Joy Street, and Washington Street.

(2) Include the construction of the North Point Boulevard to Inner Belt Road Bridge as part of the Green Line Extension design-build construction. It may be possible to have this link completed by December 2014, and MassDOT should make best efforts to achieve this, but it certainly should be achievable prior to December 2016, by which time Secretary Davey has committed to infrastructure completion of the Green Line Extension and operation to Washington Street and Union Square. As soon as the bridge construction

is complete, the Urban Ring early action service between Lechmere and Sullivan Square should be routed over it to achieve superior travel time and access for the Inner Belt/Brickbottom area.

ABC recognizes that MassDOT must continue to conduct additional analysis of the offset options to determine which are expected to be the most effective mitigation to partially offset the air quality impact of the Green Line Extension schedule slippage. We point out that in the CTPS testing of alternatives of the Urban Ring for the November 2008 Revised Draft EIR!Draft EIS, the ridership and associated air quality benefits were significant. In the Urban Ring "Northern Tier" important Environmental Justice benefits were projected by providing improved transit access to an underserved community. The Northern Tier segments also attracted significant ridership and can facilitate the growth of the knowledge economy into brownfield conversion sites.

We suggest that the link in the Urban Ring corridor from Kendall to Lechmere to Sullivan Squares be tested at a range of suitably high frequency headways: 5-10 minutes during peak periods, which we expect would be justified by the high demand and anticipated ridership in that segment.

Other suggested measures such as improving headways on the CT2 and CT3 bus routes are also worthwhile as short term measures that would benefit users in the Green Line transit ridership area and should be evaluated and implemented.

In summary, ABC strongly supports the speedy implementation of the Green Line Extension, with the inclusion of the critical Urban Ring Red Line/Green Line/Orange Line link from Kendall to Lechmere to Sullivan, not just planned for, but actually implemented and operated. This is a key opportunity for MassDOT to demonstrate its commitment to support the 2006 SIP, and honor its recent commitment to the advancing Urban Ring as opportunities present themselves.

Thank you for your consideration of our recommendations.

5780/1 glxlt925

Paul Morrissey

Aero Cycle Co.

642 Boston Ave.

Medford, Ma.02155

781-395-9966

September 25 2012

Katherine Fichter

Mass D.O.T.

Office of Transportation Planning

Room 4150, Ten Park Plaza

Boston, Ma.02116

Jerome Grafe

Mass DEP Bureau of Waste Prevention

One Winter St.

Boston, Ma.02108

Re: SIP Plan- Transit Commitments 2012- Green Line Extension

Dear Ms.Fichter and Mr.Grafe,

I wish to voice my concerns regarding the Green Line expansion plans into Medford.

Due to the MBTA currant fiscal uncertainties I believe that Boston area commuters

would be better served by focusing on improving the system we now have. Deferred

upkeep of equipment and infrastructure denies the current users and potential new

customers of confidence in our transportation system. If we don’t have the funds to keep

our current system running well where are we to find the necessary capital to maintain an

expanded Green Line?

The mandate from 30 years ago to offset the air quality impact of the Big Dig I believe is

in need of review. Automobiles are dramatically smaller and less polluting than when this

initiative was envisioned. I believe studies have shown that the air quality is actually

improving in Medford. How much of an improvement to the health of local Medford

residents would be realized if the thirty year old commuter locomotives that currently

belch diesel particulates were to be upgraded?

Finally, I wish to voice my concerns about the impact this project will have on my

community. The proposed trolley line, I believe, will encourage real estate speculation

that will impact the current residents negatively. Medford currently benefits from a

diverse racial neighborhood makeup that I don’t believe was able to participate in this

decision process.

Thank you for your attention to this issue.

Sincerely,

Paul Morrissey

The Commonwealth of Massachusetts House of Representatives

State House, Boston, MA 02133-1054

Denise Provost Representative

27th Middlesex District

Committees: Transportation,

Higher Education, Personnel and

Administration, & tate House Room 473B

Boston, MA 02133 Tel. (617) 722-2263

S

September 25, 2012

Kate Fichter

MassDOT, Office of Transportation Planning

Ten Park Plaza, Room 4150

Boston, MA 02116

Jerome Grafe

MassDEP, Bureau of Waste Prevention

1 Winter Street

Boston, MA 02108

Re: State Implementation Plan


Thank you for giving me the opportunity to comment today on the progress being made on the

SIP commitments. While I am dismayed at the prospect of the Red/Blue Line connector being

dropped from the SIP list, the focus of my remarks will be the long-delayed Green Line

Extension (GLX) project, and the choice of appropriate mitigation. I hope to provide a bit of

historical, geographic, and statutory context for thinking about the GLX, and mitigation for its

delay, as legal commitments of the Commonwealth of Massachusetts.

Somerville Air Quality Impacts

During constriction of the “Big Dig,” in its project office near South Station was a model of the

Big Dig infrastructure, superimposed on a regional map. Boston, Cambridge, and other

communities were identified on the map; Somerville’s transportation infrastructure was there

too, but its existence as a place was not acknowledged – an omission that remains emblematic.

Historically, Somerville has served the state as a transportation corridor; for freight, commuter

rail, and motor vehicle traffic. The MBTA is the city’s biggest landowner, with vast rail yards,

and the Boston Engine Terminal (consider the property tax implications of this fact). The

multiple commuter rail lines through the city do not stop. Regional motor vehicle traffic through

the city, on state roads 16, 28, and 38, and on I-93, negatively affects the quality of life, the

quality of air, and hence, public health in Somerville; having so much pavement also creates an

unpleasant heat island effect in summer.

Yet Somerville is in the lowest tier for auto-related annual carbon dioxide emission per

household, in metropolitan Boston (see Urban Land Institute (ULI)’s “The Boston Regional

Challenge” report, page 15). That study notes that “[i]nterestingly, the transportation sector

accounts for 41% of all carbon dioxide (CO2) emissions in Massachusetts, compared to 33%

nationally.” As Somerville Transportation Equity Partnership (STEP) members who are

participating in Tufts Medical School’s CAFEH (Community Assessment of Freeway Exposure

and Health) will have presented evidence to DEP during this hearing process, Somerville suffers

perversely high exposures to tailpipe toxins, and has the negative health outcome data that one

would expect in a community situated in what is perhaps the Boston region’s most heavily

travelled transportation corridor.

Legal Context for SIP Commitments

The “Big Dig” represented massive expansion of roadway capacity for motor vehicles in metro

Boston. Federal funding for the project required commitments for expansion of mass transit,

grounded in the increasing focus on multi-modal transportation that gave rise to the federal

ISTEA transportation funding legislation, and its successors. This evolution of federal

transportation policy away from the primacy of automobile travel, along with the regional air

quality stands of the Clean Air Act, formed the legal context in which the SIP projects were

affirmed as legal commitments.

In the years since the 2006 consent agreement that settled the Conservation Law Foundation

(CLF)’s lawsuit against the Commonwealth for its failure to construct the transit mitigations

associated with the Big Dig, Massachusetts has adopted important legislation that strengthens

these commitments, and that provides a clear framework for choosing delay mitigation projects.

In 2008, Massachusetts passed the Global Warming Solutions Act, which requires that the state’s

greenhouse gas emissions be reduced to 80% of 1990 levels by 2050. As the ULI report notes,

“[o]ne strategy for reducing transportation-related CO2 emissions is to reduce the number and

length of car trips, often measured in vehicle miles traveled (VMT). High-density residential

areas that can support – and are zoned to allow – nearby services, amenities, and employment

have been shown to reduce VMT by 25 to 30%, on average.”

The ULI report’s suggested fast track to reduce transportation-related CO2 emissions describes

Somerville. The most densely-populated cit in New England, its actual density, and potential

capacity, is seen to be even greater when one subtracts the vast rail yards in the east, and the

underdeveloped expanses in the Brickbottom and Boynton Yards areas. Somerville’s zoning

supports not only its high-density housing, but the mix of uses that encourages proximity to

amenities, services, and employment; Somerville’s growth along the expanding railroads during

the 19th

century made it the original transit-oriented development.

But regional passenger rail, and, until the opening of the Davis Square Red Line stop in 1984,

Somerville had no MBTA train service. Completion of the GLX, with a completed Community

Path included as delay mitigation, could rectify the longstanding transit service inequity to which

Somerville has been subjected. It will also result in a project that is completely in alignment with

http://www.nhc.org/media/files/Boston_Regional_Challenge_-_Report_-_Urban_Land_Institute.pdf

http://www.nhc.org/media/files/Boston_Regional_Challenge_-_Report_-_Urban_Land_Institute.pdf

http://www.malegislature.gov/Laws/SessionLaws/Acts/2008/Chapter298

another major piece of post-2006 transportation policy legislation, the Transportation Reform

Act of 2009 (Chapter 25 of the Acts of 2009).

Specifically, Section 33 of that statute establishes a “healthy transportation compact,” which

mandates the cross-silo creation of “a healthy transportation policy.” That policy is one that will

“develop… transportation alternatives that reduce greenhouse gas emissions… and increase

opportunities for physical activities,” including “methods to increase bicycle and pedestrian

travel…” viewed as implementation of the Compact, the GLX and completed Community Path

clearly fulfill and promote its legislative goal.

As the attorney for CLF testified, it would indeed be a great injustice if interim offset measures

for the delay in the GLX were not implemented in the same community as the GLX. Yet it must

be acknowledged that an expedited, complete GLX, and a fully designed and constructed

Community Path will not only benefit the GLX communities. Making Somerville a corridor for

off-road bicycling and walking, as well as for light rail, would be a benefit to the region, and to

the Commonwealth.

Thank you for your consideration of these comments.

Respectfully submitted,

http://www.malegislature.gov/Laws/SessionLaws/Acts/2009/Chapter25

Memo to: Jerome Grafe MassDEP, Bureau of Waste Prevention One Winter Street, 6th Floor Boston, MA 02108


From: Fred Salvucci Subject: Mitigation for Strategies Appropriate for Delay on Green Line Extension Date: Sept 25, 2011

I am writing to comment on the Annual Status Report of transit projects in the State Implementation Plan, and provide my comments on the appropriate actions that should be required of Mass DOT to mitigate damage to the environment caused by the slippage in timetable on the SIP commitments. SIP commitments were entered into in 2006 pursuant to an agreement settling litigation with the Conservation Law Foundation concerning prior slippage on the commitments of the 1993 SIP. Furthermore, MassDOT is also in violation of the more extensive commitments entered between MassDOT predecessor agencies with CLF in 1990, and the conditions attached by the DEP to the ventilation shaft permits of 1991, required for the construction of the Big Dig.

This Green Line Extension was committed to by 2014 in the 2007 SIP (service should have commenced to Medford Hillside by 2011, according to the 1993 SIP). In 2011 MassDOT has announced further slippage to 2018, or even possibly 2020 for the completion of the entire extension. Because of the heightened attention that the Conservation Law Foundation lawsuit settlement has brought, and the prior litany of failures to honor their original commitments and the various Administrative Consent Orders entered into in the late 1990s and early 2000s (which are themselves mitigation for previous failure and slippage) it is all the more important for the DEP to hold MassDOT to a very high standard of mitigation for the delayed delivery of air quality and transit access benefits.

Appropriate mitigation for the Green Line Extension implementation delay • Accelerated Timeline for Green Line Extension Construction and Gilman Street Station The first obligation of MassDOT is to mitigate the extent of the schedule slippage, which will otherwise cause both cost increases because of construction cost inflation, and delay of air quality benefits, service, economic development, and other benefits to Somerville and the region. The July 2012 Memorandum of Understanding between the City of Somerville and MassDOT, which makes a commitment to start construction of the first phase of the extension to Union Square and Washington Street by Spring 2014 and have stations operational by early 2016, is an encouraging development.

Much of the timeline slippage has been self-inflicted by the Commonwealth. Significant delay was caused by the MassDOT effort to locate the maintenance facility at an unacceptable location (Yard

8) and by Mass EOEA insisting on an additional environmental process to address the revised maintenance location. Furthermore, the maintenance facility, while possibly desirable, is not necessary to complete the extension and commence service, nor is the facility an essential element of the extension promised in the SIP. It could be added later if necessary, as long as the appropriate track and switches are put in place to access the area.

Nevertheless, the construction schedule for the GLX, prioritizes the construction of the maintenance facility in phase 3, leaving the construction of the stations beyond Washington Street to the final phase.

MassDOT should instead be required to revise its construction schedule and prioritize the construction GLX stations before the maintenance facility. This should be especially so for the Gilman Street Station, which contributes disproportionately to the air quality benefits of the project since it has the highest projected ridership. MassDOT should be required to construct the GLX at least up to Gilman Street (and ideally all the way to College Ave) in phase 2/2A or phase 3 of the extension, and defer construction of the maintenance facility until this is achieved.

• Inner Belt Road to North Point Boulevard Bridge and Preliminary Urban Ring Service It is clear that there are significant features of the Green Line Extension project that have substantial transit and air quality value, which MassDOT has been proposing to defer, and which should be implemented as part of early action phase 1 and phase 2/2A construction of the GLX. These include the bridge connecting Inner Belt Road to North Point Boulevard, essential to facilitate the Urban Ring connection between Lechmere and Sullivan Square, enable the transit-oriented economic redevelopment of the Inner Belt area, and establish a critical link of the community path and bicycle connection from Alewife through Somerville to the Charles River. This critical link should be built as part of the earliest construction, linking Lechmere to Washington Street and Union Square that has been promised to be in construction by 2014 and completed by 2017. With the staged opening of the GLX to Washington Street and Union Square prior to completion of Medford Hillside, the Urban Ring connection to Sullivan Square can help to mitigate the delay by improving transit and expediting the transit-oriented development, both of which will contribute air quality benefits.

MassDOT should be required to construct this bridge as part of its mitigation obligations, and to model the effectiveness of a CT-4 frequent bus route (3 minutes) as an interim Urban Ring service that will connect Sullivan Square, “old” Lechmere and Kendall.

• Grand Junction Rail Service In 2010, the Commonwealth purchased key rail corridors in order to use them to improve public transportation service, and last year the MassDOT undertook a process to examine the preliminary feasibility of running commuter rail service on the Grand Junction Railroad from Framingham/Worcester to North Station. The results of this effort were the initial findings that Commuter Rail service on the line has the ability to provide additional public transit capacity and reduce auto trips, and associated benefits to air quality. As mitigation for the delay on the GLX, MassDOT should be required to further examine the feasibility of rail service on the Grand Junction. It is recognized that the previous plan faced community opposition in Cambridge due to concerns regarding emissions from trains and competing interests for using the corridor as a walk/bike trail. However, it has since been demonstrated that a community trail and rail service

could both be accommodated in the corridor. Further, MassDOT should be required to work with the CTPS to model an alternate service plan that could be more satisfactory to the community and more beneficial to air quality and transit ridership: providing urban service using DMUs.

It would be appropriate for MassDOT to purchase or lease Diesel Multiple Units (DMUs) and initiate frequent 10 minute service, to make the Grand Junction a truly urban quality rail service. MassDOT should be required to model and test the potential effectiveness of frequent DMU service (as well as the presumable reduced air pollution that should be feasible with “clean diesel” DMUs), along with a sensitivity analysis of different service frequencies for discussion with the city and community groups, and then implement a suitably frequent schedule. If found suitable, DMU service on the Grand Junction could be implemented in as little as two years by late 2014.

Funding for Required Mitigation It is important to recognize that SIP and transit commitments were made by the Commonwealth and MassDOT, not primarily by the MBTA, so that these are financial obligations by the Commonwealth and all its agencies, including MassDOT, Massport, and Administration and Finance, and not only the MBTA. Morally, MassDOT and Mass Administration & Finance are obliged to fund the transit commitments of the Big Dig, which are necessary to achieve the benefits identified in the 1990 SFEIS and the 1991 vent shaft permits. The troubling fiscal condition of the MBTA is no excuse for avoiding the responsibility to provide adequate and meaningful mitigation that involves a substantial and meaningful increase and expansion in public transit service.

The current budget problems at the MBTA have been created by the Commonwealth. The 1964 enabling act that created the MBTA established the understanding that 90% of capital MBTA debt service would be funded by the Commonwealth to enable the expansion and modernization of the system. The so-called “forward funding” budget structure initiated in 2000 has crippled the MBTAs ability to maintain service, expand service and meet its legal commitments for transit expansion, mitigation and SIP requirements.

Fortunately, there are encouraging signs from MassDOT, the Governor, the Secretary of Transportation and Beacon Hill for legislation to restructure and alleviate the transportation funding problem in the Commonwealth. It is essential that DEP take a strong position that any new transportation funding bill release the MBTA of its unfair debt burden, thereby enabling not only the reversal of destructive service cutbacks that hurt air quality, economic development and environmental justice, but also for the MBTA to focus on expanding service and investing in new capital. Again, it must be underscored that the transit mitigation projects agreed to by MassDOT and its predecessors are obligations of the Commonwealth, not MBTA, and that “flexing” of “highway” funds, and “creative finance” options with the support of Administration and Finance must also be available.

SIP projects are supposed to be prioritized over other transportation projects in the TIP and long-range transportation plan. Continued failure to implement is not a legitimate option. DEP should require that any funding bill include a mechanism to ensure that the Commonwealth’s delivers on its responsibility to implement the commitments in the SIP and CLF agreement, with a particular emphasis on the Green Line Extension, the design and construction of the Red-Blue connector as a priority, Urban Ring bus service, and the missing link of the Sliver Line.

Of the many valuable transit improvement projects which are being left in varying states of disarray by MassDOT, the Blue-Red is the one project whose implementation is achievable in a relatively shorter time frame which addresses a critical failure point in the current Boston transit system: namely, the lack of capacity in our core transit system which depends on the convergence of our major radial transit lines in the Boston regional core (Red, Green, and Orange as well as Blue Lines). It is also important to remember that the predecessor to MassDOT committed to having the Blue-Red connector in operation by the year 2000 in the 1991 DEP ventilation shafts permit. It is encouraging to see the recent support to keep the completion of engineering design for the Red-Blue connector in the SIP. However, the appropriate mitigation action is to achieve actual service on the Blue-Red connection at the earliest achievable date, by conducting a value engineering review of the current state of design, preparing design-build procurement documents, and including the Blue-Red connector construction in the Green Line extension project, in order to achieve economy of scale and timely implementation at a reasonable price.

Methodology for Evaluating the Effectiveness of Possible Mitigation Strategies Typically, MassDOT has used a methodology to predict regional air quality impacts based on vehicle miles of travel by autos (VMT). But the methodology is inadequate for evaluating the damage of schedule slippage, particularly for the Green Line extension and the Blue-Red connector.

First, the entire basis of the air quality calculations for the Big Dig was not VMT, but VHT (vehicle hours traveled by auto). VHT is a better indicator of air quality impact, but requires the ability to measure and predict congestion effects of growth in auto use. Because the CTPS methodology predicts traffic volumes which exceed the capacity of key highway facilities, the predictions of the methodology do not properly reflect the fundamentally congested nature of key parts of the highway system. Congestion causes more delay, more VHT, and more air pollution. Therefore, the methodology is inadequate as a tool to model air quality for the purpose of enforcing the SIP or for evaluating conformity. The core of the transit system is similarly predicted to carry significantly more passengers than is possible, underscoring the inadequacy of this methodology. Because of this fundamental flaw in methodology the entire SIP revision proposal should be rejected by DEP. It should be sent back to MassDOT for appropriate modification of the methodology, and reconsideration of the entire proposal based on the revised results.

Secondly, the most significant drivers of VHT are land use, trip distribution, and mode share. Delay in implementing the Blue-Red connector and the Green Line extension affect not only the transit and auto mode share of a fixed set of trips, they affect the distribution of activity and trips being made, as well as land use. For these reasons the methodology used to estimate the damage done to air quality by schedule slippage on transit improvements needs to be based upon a more fundamental review comparing the land use and trip distribution and VHT projected in the 1990 Big Dig FEIS, and the originally assumed transit improvements in the 1990 model, in comparison with what has actually occurred, to measure whether the improvement in air quality predicted for the year 2010 actually occurred or not, the differential air quality impacts as a result of differences identified, and the likely effectiveness of various mitigation strategies.

It is highly likely that using appropriate methodology which identifies the projected state of VHT in the year 2010 according to the Big Dig versus what has actually transpired, the mitigation options suggested in section 1 would be useful but not sufficient to fully mitigate the excessive VHT being generated by the actual measured land use, trip distribution, and VHT, and that additional transit

improvement is required to address the adverse impact of late delivery of transit improvements assumed in the base documents of the 1990 FEIS, the 1991 vent shaft DEP permits, and the 1993 SIP. It would be useful and appropriate to consider the various measures proposed in these original documents, as well as in the various Administrative Consent Orders, such as the Urban Ring and the missing link of the Silver Line, to identify suitable additional mitigation measures to not only achieve the state of performance of the transportation system initially projected to result from the Big Dig, and the resultant state of air quality, but to deal with the new challenges to improve both economic and environmental performance for the next century.

Sincerely,

Fred Salvucci

Friends of the Community Path 112 Belmont Street Somerville, MA 02143 617.776.7769 [email protected] www.pathfriends.org/scp/

September 25, 2012


Jerome Grafe MassDEP, Bureau of Waste Prevention One Winter Street, 6th Floor Boston, MA 02108

Dear Ms. Fichter and Mr. Grafe,

Re: Annual SIP Update and Status Report for Transit Projects

Thank you for the opportunity to comment on the Update and Status Report for Transit Projects As required by 310 CMR 7.36 (2) (f) through (j) that was submitted by the Massachusetts Department of Transportation (MassDOT) to Mass DEP on July 2, 2012.

The Friends of the Community Path is a regional group with over 1200 members. Our mission is to extend the Community Path 2 miles to Cambridge to thereby link the 23-mile Minuteman Bikeway network to the 23-mile Charles River path network, along the coming Green Line Extension (GLX) route, thereby connecting 11 Boston MPO cities and towns.

Our Request: To include, as an Interim Offset Project in the Green Line Extension corridor, final design and construction of the extension of the entire Somerville Community Path (CPX) prior to or together with (as appropriate for the construction schedules) the Green Line Extension construction contract. In particular, this should include both the design and construction (neither which MassDOT has agreed to) of the “missing link” CPX from Inner Belt to North Point, where development construction is under way and increasing rapidly. Because of the time frame of the Phase I GLX work in this area, now is the time to integrate the CPX into the GLX. The CPX will deliver air quality benefits both with the GLX (be bringing riders cost-effectively to the new GKX stations) and independently as an active transportation corridor from the northwest to Cambridge, Boston and the Charles River paths. The CPX is one the projects listed and evaluated as an Interim Offset Project and it received high points for many reasons.

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http://www.pathfriends.org/scp/


We also wish to thank the DEP for continuing to require that the SIP includes the GLX and to thank previous Environmental Affairs secretaries for requiring in environmental impact reports that the GLX not preclude the CPX from being extended.

They’ve done this realizing that the CPX is a connective regional bike/pedestrian project that meets the State’s GreenDOT, Healthy Transportation Compact, and Mode Shift goals; meets SIP requirements; meets Federal Healthy and Sustainable Transportation goals; and is already included on state, regional, and local planning efforts.

We are delighted that MassDOT and the MBTA has agreed to build the shared infrastructure of the GLX and CPX and the Path itself for several hundred feet for station accessibility and emergency egress. However, the CPX must really be constructed together with the GLX to minimize its construction cost. This can be accomplished by making the CPX an integral part of the GLX project and/or as an Interim Offset Project for the GLX delays. Please use your authority to make this happen.

Sincerely,

Lynn Weissman Alan Moore Co-Presidents, Friends of the Community Path

cc: Mayor Joseph Curtatone, City of Somerville Hayes Morrison, City of Somerville Richard Davey, Secretary, MassDOT Somerville Transportation Equity Partnership

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To: Jerome Grafe Kate Fichter MassDEP, Bureau of Waste Prevention MassDOT Office of Transportation Planning One Winter Street, 6th Floor Room 4150, Ten Park Plaza Boston, MA 02108 Boston, MA 02116 Date: Sept 25, 2011 RE: Mitigation for Strategies Appropriate for Delay on Green Line Extension

This memo contains comments on the Annual Status Report of the transit projects in the State Implementation Plan, focusing on the appropriate actions that should be required of MassDOT to mitigate the damage to the ecological, social, and economic environments resulting from slippage in the timetable on the SIP commitment for the Green Line Extension.

Requirement for Mitigation Air Quality The Green Line Extension (GLX) is the most significant air quality mitigation measure remaining from the Central Artery/Third Harbor Tunnel Project. Constructing the GLX is a key component of the Clean Air Act State Implementation Plan (SIP), and therefore, the Commonwealth is legally required by Federal law to build the GLX to Union Square and Medford Hillside and have service operational by 2014. The recent July 26, 2012 Memorandum of Understanding signed between the City of Somerville and MassDOT/MBTA has made a commitment only to begin construction of the first phase of the extension by Spring 2014, and have two operational stations (Union Square and Washington St) by late 2016 or early 2017. Further, it is important to recognize that according to the 1993 SIP service on the GLX to Medford Hillside should have commenced by 2011. This commitment was renegotiated due to the failure of the Commonwealth to make adequate progress toward meeting the promised timeline.

Simply put there has been and continues to be a significant delay in the implementation timeline of the GLX commitment in the SIP, and likewise the failure to deliver anticipated air quality benefits from the project to the people of the Commonwealth. This delay triggers the need to provide interim emission reduction offset measures for the entire period of the delay.

Environmental Justice Equally important as the air quality benefits, the GLX addresses longstanding transportation access and equity issues in the City of Somerville. The proposed GLX right of way occupies the corridor of the former Boston and Lowell Railroad, and the GLX stops at Gilman Square, Lowell St, Ball Square, and College Avenue replace historic service at the Prospect Hill, Winter Hill, Somerville Junction and North Somerville stations.

Furthermore, when plans for Interstate highways and the Inner Belt (I-695) were stopped in the 1970s through Jamaica Plain and Roxbury and replaced with the MBTA Orange Line relocation, in Somerville I-93 was built as an elevated structure and no transit alternatives were provided. Somerville, the most densely populated city in the Commonwealth, still remains significantly underserviced by the MBTA rapid transit network. The regional transit connectivity promised by the GLX is key for enabling access to economic opportunities for Somerville residents, and also for catalyzing economic development and the growth of jobs within the City.

The history of continual delay on the project, the significant air quality benefits of the GLX, and the economic development and environmental justice aspects of the Extension, make it imperative for DEP to hold the MassDOT and the MBTA to a very high standard of mitigation for slippage on the SIP timeline.

Appropriate Mitigation Actions The Green Line Extension project is anticipated to deliver major air quality and transit access benefits, and according to the 2011 Federal Environmental Assessment of the project the GLX accounts for more than 80% of all emissions benefits in the 2009 SIP package of projects. It is not likely that any set of mitigation actions will manage to achieve this level of benefit for air quality and transit access. Therefore, it is all the more important that any set of mitigation measures be focused on actions that provide a substantial and meaningful increase to public transit access within Somerville and the same neighborhoods that would benefit from the GLX.

However, the Green Line Extension SIP Mitigation Inventory released from CTPS and MassDOT on January 23, 2012 is a disappointing document, since the most relevant and appropriate mitigation measures seem to be prematurely scoped-out due to a lack of support from MBTA and/or MassDOT. The MBTA position of limiting peak-period service expansion severely handicaps the potential to provide meaningful mitigation for the GLX delay, however, this limitation can be overcome through the use of contracted services such as the EZRide shuttle equipped with MBTA fare boxes.

MassDOT, the Governor, and the Secretary of Transportation have made it clear to the public that new legislation to address the structural financial challenges facing transportation in the Commonwealth is imminent. It is essential that DEP ensures the required resources to satisfy all legally required SIP commitments and mitigation actions are included in any new transportation funding bill.

Local Area Context Due to the schedule and scope of planned MassDOT construction projects over the next several years, there will likely be severe disruptions to the transportation system in Somerville. Mitigation actions for the GLX delay should be considered in this context, and should help offset these disruptions related to the construction of the Green Line Extension itself as well as other major roadway projects in the surrounding area.Of particular concern is the relationship between GLX construction and work on the Route 28/McGrath Highway corridor.

• Reconstruction of the Washington Street Bridge to accommodate the Green Line tracks will significantly limit access along one of the only corridors linking east and west Somerville across McGrath Highway. The EA/EIS for the GLX has noted this requires mitigation. • Rehabilitation of the Medford Street Bridge to enable the Union Square branch of the GLX has been committed as an early action item but will reduce capacity on this link that is used (as a neighborhood cut-through) for traffic headed to Kendall. • Reconstruction of the Gilman St Bridge and Cross Street Bridge as part of the Accelerated Bridge Program will substantially reduce the capacity of the McGrath corridor to connect origins in north Somerville to destinations in Lechmere and Kendall and Boston – a travel pattern that would be well served by the Green Line Extension.

This context further heightens the critical need for meaningful public transit service as appropriate mitigation action for the GLX implementation delay.

Recommended Actions

1) Sullivan Square to Kendall Square Circumferential Bus Service via Brickbottom to Inner-Belt Embankment Connection

MassDOT should be required to model and test the effectiveness of frequent bus service (4-5 minute frequency) on a new “CT4” route connecting Kendall Square, Lechmere Square, Sullivan Square and Assembly Square. This precursor service to the Urban Ring would provide meaningful transit access to Somerville and an important connection to the employment center in Kendall. This service could be feasibly implemented prior to 2014 using contracted bus operations. Initially, this service can run from Kendall to Lechmere via priority bus lanes on First Street that have been committed to by the City of Cambridge, and then to Sullivan Square via McGrath Highway. In order for this service not to be trapped in traffic related to construction at the Washington/McGrath intersection and under the Washington Street GLX Bridge, the mitigation action should include a roadway connection (at or near Poplar Street) underneath the future GLX viaduct/Lowell Line MBTA tracks to connect the Brickbottom and Inner-Belt neighborhoods. This will enable busses to reach Washington Street east of the GLX construction disruption.

2) North Point Boulevard to Inner-Belt Road Bridge for CT4, future Urban Ring and Community Path MassDOT should be required to construct this bridge as part of its mitigation obligations. Although it has been noted that the bridge may not be ready by Jan 1, 2015 (the first day mitigation will be required), the bridge could be completed by 2016 and constructed as part of the first phase of the GLX which has been committed to by the Commonwealth. Therefore, the bridge would provide mitigation value for several years until the entire GLX is completed by 2020 on the current anticipated schedule. The bridge, which risks being physically precluded if not designed in tandem with the GLX, is essential for enabling an Urban Ring connection between Lechmere and Sullivan Square, for the critical link of the Community Path extension from Somerville to the Charles River, and for supporting the transit-oriented economic development of Inner-Belt and North Point. All of these outcomes contribute air quality and local transit access benefits that are appropriate mitigation measures for the delayed and staged opening of the GLX. The bridge will also be necessary mitigation for the grounding of McGrath Highway and demolition of the McCarthy Viaduct (discussed below).

3) McGrath Highway and Grounding McCarthy Viaduct As mentioned above, the GLX and McGrath Highway corridor should be considered together. MassDOT has made it a matter of policy that the McCarthy Viaduct is an obsolete structure, and has expressed to the public that it is committed to removing the elevated structure and reconceptualizing the McGrath Corridor as an at-grade boulevard. In 2003 the Boston MPO concluded that bicycle travel along the McGrath corridor “is not safe” and that pedestrian crossings under the structure are difficult and lead to circuitous route choices.

These physical conditions have an adverse impact on the desirability of walking and bicycling to access the future Washington Street GLX station. This is particularly troubling since over 90% of the projected ridership to the station will be arriving by walk and bike. The proposed phased opening of the GLX with Washington Street as the line terminus, will also increase the catchment area of people trying to reach the station by walk and bike. The presence of the McCarthy Viaduct and the substandard conditions at grade undermine the ridership of the Green Line Extension. Worse yet, MassDOT is proposing a timeline to remove the McCarthy Viaduct and reconfigure McGrath as an at-grade boulevard only after the GLX station at Washington Street is completed. These construction activities, which will last for years, will significantly disrupt or even cut off access to the Washington St station. Therefore, the existing conditions of McGrath and the future plans for the corridor threaten to set back attaining the transit access and air quality benefits of the project which are already being

substantially delayed. In order to avoid these consequences, MassDOT should be required to do the following:

• As immediate mitigation for the construction disruption related to the rehabilitation of the Medford Street Bridge, MassDOT should be required to close and demolish the Southbound off ramp from the McCarthy Viaduct at Somerville Ave. Doing so will have the dual benefit of reducing the number of vehicles entering the area of reduced capacity surrounding the construction, and also be an early action in the direction of removing the Viaduct.

• MassDOT should be required to redesign the Washington St/McGrath intersection to improve and signalize pedestrian crossings. This action is specified as required mitigation in the EA, however, it should be completed as an early action now to improve access to and usage of existing transit options in the area (MBTA bus lines, CT2, 86, 88, 91).

• MassDOT should be required to redesign the Somerville Ave /McGrath intersection to improve and signalize pedestrian crossings, and to provide a vehicular connection from Somerville Ave to Polar Street to enable better access to Brickbottom and alternative paths to the Washington St / McGrath intersection connecting east and west Somerville. This action is consistent with the goal to ground the McCarthy Viaduct, and should be completed as an early action now to improve access to and usage of existing transit options in the area (MBTA bus lines 80, 87). Currently, access to these bus lines at Poplar St / McGrath Highway requires crossing six lanes of high-speed highway traffic with no pedestrian signal.

• MassDOT should be required to develop a construction, implementation and funding plan for the grounding of the McCarthy Viaduct. This plan should be timed to coincide with the Gilman Street Bridge reconstruction in 2015 which will inevitably reduce the throughput capacity of McGrath Highway by as much as 50%. At this time, the capacity provided by the McCarthy Viaduct will be redundant, and MassDOT should be required to reconfigure the existing surface/frontage roads of McGrath Highway to accommodate the reduced traffic load in the corridor. Preliminary analysis of this configuration has demonstrated its feasibility. With the frontage road system in place and all traffic operating at-grade, MassDOT should be required to demolish the McCarthy Viaduct structure before the 2017 opening date of the Washington Street Station. These actions will greatly enhance the viability and safety of pedestrian and bicycle access to the Washington Street Station, as well as the potential for transit oriented economic development – all of which contribute to improving air quality. Also, this sequence of actions is not inconsistent with, and does not preclude a more comprehensive corridor design process to reconfigure the McGrath Highway as a multi-modal boulevard.

4) Green Line Service to Lechmere at 3 Minute Headway The commitment in the GLX project is to run the two branches of the extension with a 3 minute combined headway to Lechmere station. MassDOT should be required to implement this service improvement to the existing Lechmere station on an immediate timeline as a mitigation measure.

5) Green Line Extension Service to Gilman Street Station The Gilman Street Station on the GLX has the highest forecast ridership, and therefore, contributes a significant share of the air quality benefits of the project. The current construction phasing of the GLX does not include an operational Gilman Street Station until phase 4, but prioritizes the construction of a maintenance facility in phase 3. The maintenance facility, although desirable for the MBTA, it is not a key element of the GLX commitment promised in the SIP nor necessary to commence service up to Gilman Street. Therefore, MassDOT should prioritize the construction of the GLX to Gilman Street in

phase 2/2A or phase 3 of the extension, and defer construction of the maintenance facility until the rest of the extension is completed.

Sincerely,

Vig Krishnamurthy 20 Glenwood Ave, #2 Cambridge, MA, 02139

Ellin Reisner 51 Mt. Vernon St. Somerville, MA, 02145

Jim McGinnis [email protected]

Karen Molloy [email protected]



SIP Transit Project Comments submitted to DEP by Ellin Reisner, resident of Somerville and

member of the Somerville Transportation Equity Partnership on September 18, 2012.

I first want to acknowledge the important milestone that was reached last week when the

MassDOT/MBTA Board of Directors voted funding of $45 million to move the Green Line extension (GLX) project forward with the new contractors AECOM and HNTB working on detailed design and

engineerir:'g including the lechmere, Union Square and Washington Street stations. It is great to

that the project is moving forward and I appreciate the work completed by the MBTA staff and

HDR led design team. Also, although I have not been involved in the Fairmount Line, it is also

good to see this project moving toward completion.

It is important to yet again make clear that the Commonwealth must move forward in implementing the SIP interim replacement projects to meet the air pollution reduction benefits

that the GLX will offset because of the continuing delays in opening the GLX. Initially the GLX was

to open in 2011, and then it was delayed to 2014. Now, we are faced with the opening of service

to Washington St. and Union Square by 2016, with service to College Avenue delayed to 2019. As

the delays mount, the importance of mitigation increases.

Over the past year many people have commented on recommended interim offset projects. Now

is the time to commit to and prepare Interim replacement projects that will provide the required

mitigation between 2014 and the expected opening of the GLX to College Ave. in 2019 and to

Route 16 in a separate project phase. My recommendations address several goals that reduce

mobile pollution and meet sustainability goals.

First, I strongly recommend that Mass DEP direct MassDOT to complete the design and

construction of the Community Path from Inner Belt to North Point in order to complete the

regional bike and community path network from Bedford to downtown Boston that links to the

Charles River paths. This critical section of the path serves an environmental justice neighborhood

that lacks safe bicycle and pedestrian connections both within Somerville and to Boston. The Path

meets sustainable transportation principles of the US DOT I EPA/ HUD partnership the MassDOT's GreenDOT go-als. As an advocate for sustainable transportation that serves all modes it is

troubling and frustrating to continually face the Commonwealth's inconsistency in meeting its own sustainability commitments. This project needs to be made shovel ready as soon as possible.

Secondly, there is an opportunity to increase transit use during the interim years, by constructing

new bridge and roadway connections within Brickbottom/lnner Belt and North Point. A new bus

route connecting Sullivan Station to Lechmere and Kendall Station would prove an attractive

transit alternative that could remove many vehicles from the corridor and provide an economic

stimulus to the region. This route could be started up prior to completion of the bridge and road

work in lnnerbelt/Brickbottom, but would eventually be routed through lnnerbelt/Brickbottom.

Ultimately transportation planning in the region should demonstrate a long term vision for

addressing transit needs with a light rail line in the Grand Junction that would connect all of the

transit lines and highways from Wellington and 193N to MIT/Kendall Square and the Longwood

Medical Area.

I also urge moving forward with planning and design of the Route 16 GLX station to meet the long

term connectivity (including linking bicycle and pedestrian access, economic development and

mobile pollution reductions in the corridor.

I also think that it is a mistake to eliminate the Red/Blue connector as a SIP commitment. The

decision to only develop a design when the SIP commitments were revised was a mistake. While I

know that funding is an inescapable issue, the connector would enable more people to use public

transit to get to jobs and school, reducing auto trips. It would also relieve overcrowding in the

Central subway. Elimination of this project is short sighted, but it needs to not just be a design

project, it needs support for construction.

Lastly, because of Somerville's excessive exposure to diesel pollution from commuter rail,

maintenance of commuter rail at the Boston engine terminal and high volumes ofhighway traffic, I

strongly recommend that the MBTA diesel reduces its use of diesel in the entire MBTA system

and in particular within the Northwest corridor.

Ellin Reisner 51 Mt. Vernon St. Somerville, MA 02145

, . Wig Zamore 13 Highland Ave #3 Somerville MA 02143

Logan Health Study CAC (DPH) Logan Airport CAC (Noise Study) MBTA Rider Oversight Committee MAPC MetroFuture Steering Com. (to 2008) Somerville Transportation Equity Partnership Mystic View Task Force (of Somerville)

617-625-5630

wigzamore@gmail. com

August 31 , 2012

The Honorable Lisa P. Jackson, Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue. N.W. Washington, D. C. 20460

Via Email: [email protected]

Via Email: [email protected]

Re: EPA Proposed PM Rule June 2012 Docket tfo. EPA-HQ-OAR-2007-0492

Dear Administrator Jackson,

Of the six criteria pollutants, Carbon Monoxide was significantly reduced via the catalytic converter after removal of Lead from gasoline, as were Nitrogen Oxides and VOC precursors to Ozone. Sulfur Dioxide has seen significant reduction via stationary source controls and use of lower sulfur coal and diesel. Nevertheless, Particulate Matter (PM) and Ozone remain significant pollutants in the air of many regions.

In fact, during recent EPA criteria pollutant reviews, both PM and Ozone are now associated with greater health effects, including pre-mature mortality, than at any prior time since the creation of the EPA and the Clean Air Act Amendments of 1970. This is largely due to the recent recognition of an Ozone mortality concentration response curve, better exposure assessment for PM health studies and abandonment of the concept of a safe threshold for manmade PM, including PM2.5. As environmental health research has improved, the burdens associated with Ozone and PM, especially those attached to pre-mature mortality thro~h Value of Statistical Life analyses, have increased dramatically even though the air has gradually been getting cleaner in many parts of the US.

When EPA fails to set standards every five years which fully incorporate the latest science, and provide protection to susceptible populations with an adequate margin of safety, the older NAAQS standards fall into attainment through default. This is happening in many areas of the US right now as 1997 Ozone and PM2.5 standards come to meet regional attainment, with the result that abandonment looms for decades of Transportation Control Measures and other parts of State Implementation Plans, even in the face of the scientifically acknowledged increase in recognized health impacts. This is true· for eastern and western Massachusetts. With up to date Ozone and PM standards we would be working furiously on new SIP TCMs. Without them, decades of good work by MA DEP and US EPA may simply go down the drain.



I '

With regard to PM2.5, I would urge you to take the bold step of setting the annual standard at 10 micrograms per cubic meter and the daily at 25. The Lepeule 2012 EHP update to the Harvard Six Cities study found a linear dose response curve down to 8 micrograms and the Crouse 2012 EHP national Canadian PM2.5 analysis found reliable dose response curves, similar to those in the American cohort studies for all cause mortality and for ischemic heart disease mortality, at even lower PM2.5 levels. If you are unable to set the annual standard at 10, please seriously consider a standard of 11. PM2.5 has a robust association with pre-mature mortality differences between metropolitan regions of the US.

With regard to within region air pollution gradients, PM2.5 is not robust. This was first shown by the California Children's Health study as it evolved from a concentration on Ozone and PM2.5 to a concentration on N02 and proximity to large traffic sources. The California Children's Health Study has shown that childhood asthma and lung function are related to mobile pollution, highway and busy local arterial proximities of residences and schools. Similarly, all cause, lung cancer, heart attack, ischemic heart disease and cardiovascular mortality have been shown to be closely related to exposure to traffic in • Germany, Sweden, Norway, Toronto and Vancouver. The Vancouver studies of Gan and Brauer are especially telling as their within city multi-pollutant analyses of PM2.5, N02 and Black Carbon (BC) found significant associations of BC with cardiovascular mortality, nearly significant associations for N02 (another marker for traffic pollution) and no significance at all for PM2.5. In a separate analyses of near highway Vancouver residents, those who lived within 50 meters of a major highway had nearly an order of magnitude higher relative risk of cardiovascular mortality (1.6) than for the interquartile range for BC (1.06). Near highway residential exposures are associated with relative mortality risks similar to those of long term truck drivers and diesel rail engineers. Additionally, Black Carbon has recently been determined by the International Agency for Research on Cancer to be a Class I carcinogen for lung cancer.

As ultrafine particles (equal to or less than 100 nanometers in diameter) contain much larger concentrations of black carbon and air toxics, such as phenanthrene and other PAHs, than do fine or coarse particles, it would be prudent for EPA to declare new standards for ultrafine particles. I would suggest an annual standard of 15,000 UFP per cubic centimeter (lower cut point 5 nanometers) and an hourly standard of 100,000. Until near roadway exposures and health effects are taken seriously by EPA in its standard settings, it will not be possible to incorporate the science of within city exposures into healthy community design and sustainable regional development. Until that happens, "smart growth" will remain pretty dumb. Housing, schools and active playgrounds will continue to be placed in risky locations; bike paths will continue to be built in the middle of or alongside arterial highways notwithstanding that bicyclists' effective dose is 5 or 6 times as high as vehicular or transit passengers due to increased ventilation; and healthy clean transit/walk/bike facilities will not take precedence over diesel rail, continued highway building and excess fossil fuel consumption.

We really need EPA to act responsibly rather than politically in its NMQS PM standard setting. Please come through for us! There is a huge amount of health and quality of life dependent on your actions.

With Great Respect and Thanks,

Wig Zamore

The following articles were appended to this comment. For copies of the articles, please contact Wig Zamore at [email protected]. Luz T. Padro-Martinez, Allison P. Patton, Jeffrey P. Trull, Wig Zamore, Doug Brugge, John L. Durant, “Mobile monitoring of particle number concentration and other traffic-related air pollutants in a near-highway neighborhood over the course of a year, ” Atmospheric Environment 61 (2012): 253-264. Michael Jerrett, Richard T. Burnett, C. Arden Pope III, Kazuhiko Ito, George Thurston, Daniel Krewski, Yuanli Shi, Eugenia Calle, Michael Thun, “Long Term Ozone Exposure and Mortality,” The New England Journal of Medicine 360 (2009): 1085-1095. Jonathan M. Samet, “Clean Air Scientific Advisory Committee Response to Charge Questions on the Reconsideration of the 2008 Ozone National Ambient Air Quality Standards,” letter to Lisa P. Jackson, Administrator, U.S. Environmental Protection Agency, March 30, 2011. Maggie L. Grabow, Scott N. Spak, Tracey Holloway, Brian Stone Jr., Adam C. Mednick, Jonathan A. Patz, “Air Quality and Exercise Related Health Benefits from Reduced Car Travel in the Midwestern United States,” Environmental Health Perspectives 120-1 (2012): 68-76. Luc Int Panis, Bas De Gus, Gregory Vandenbulcke, Hanny Willems, Bart Degraeuwe, Nico Bluex, Vinit Mishra, Isabelle Thomas, Romain Meeusen, “Exposure to particulate matter in traffic: A comparison of cyclists and car passengers,” Atmospheric Environment 44 (2010): 2263-2270. Wen Qi Gan, Lillian Tamburic, Hugh W. Davies, Paul A. Demers, Mieke Koehoorn, Michael Brauer, “Changes in residential proximity to road traffic and the risk of death from coronary heart disease,” Epidemiology 12-5 (2010): 1-8. Wen Qi Gan, Mieke Koehoorn, Hugh W. Davies, Paul A. Demers, Lillian Tamburic, Michael Brauer, “Long-term exposure to traffic-related air pollution and the risk of coronary hearth disease hospitalization and mortality,” Environmental Health Perspectives 119-4 (2011): 501-507. Tim S. Nawrot, Laura Perez, Nino Kunzli, Elke Munters, Benoit Nemery, “Public health importance of triggers of myocardial infarction: a comparative risk assessment,” www.thelancet.com February 24, 2011, DOI: 10.1016/S0140-6736(10)62296-9. Nicholas L. Mills, Hakan Tornqvist, Manuel C. Gonzalez, Elen Vink, Simon D. Robinson, Stefan Soderberg, Nicholas A. Boon, Ken Donaldson, Thomas Sandstrom, Anders Blomberg, David Newby, “Ischemic and thrombotic effects of dilute diesel-exhaust inhalation in men with coronary heart disease,” The New England Journal of Medicine 357-11 (2007): 1075-1082. International Agency for Research on Cancer, “Diesel Engine Exhaust Carcinogenic,” Press Release, June 12, 2012. Donald G. McNeil Jr., “WHO Declares Diesel Fumes Cause Lung Cancer,” New York Times, June 12, 2012.


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International Agency for Research on Cancer Monograph Working Group, “Carcinogenicity of diesel-engine and gasoline engine exhausts and some nitroarenes,” www.thelancet.com June 15, 2012, DOI: 10.1016/S1470-2045(12)70280-2. Dan L. Crouse, Paul A. Peters, Aaron van Donkelaar, Mark S. Goldberg, Paul J. Villeneuve, Orly Brion, Saeeda Khan, Dominic Odwa Atari, Michael Jerrett, C. Arden Pope III, Michael Brauer, Jeffrery R. Brook, Randall V. Martin, David Stieb, Richard Burnett, “Risk of nonaccidental and cardiovascular mortality in relation to long-term exposure to low concentrations of fine particulate matter: A Canadian national-level cohort study,” Environmental Health Perspectives 120-5 (2012): 708-704. Johanna Lepeule, Francine Laden, Douglas Dockery, Joel Schwartz, “Chronic exposure to fine particles and mortality: an extended follow-up on the Harvard six cities study from 1974-2009,” Environmental Health Perspectives 120-7 (2012): 965-970.

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