July 13, l999
Robert Durand, Secretary
Executive Office of Environmental Affairs
Attention: MEPA Office, William Gage
100 Cambridge Street, Room 2000
Boston, MA 02202
fax 727-1598
RE: EOEA # 11707, NPC, Washington Street Silver Line
Transit Service
EOEA # 6826, NPC/Response to Comments, South Boston Piers
Transitway
The Alliance of Boston Neighborhoods is an umbrella organization concerned with meaningful public process and with planning matters of city-wide importance. We have both substantive and process-related comments on this document.
Since public transit is the key to a sustainable future for the Boston region, we support any integration of transportation corridors that would improve city-wide transit connections. However, each of these projects has been fraught with complications, and their combination presents enormous challenges, few of which appear resolved within this NPC. The MBTA states in the submittal cover letter to MEPA that it has succeeded in "filing one document which serves to close out both MEPA filings," and which "presents for public comment a comprehensive view of how the two projects inter-relate"; however, we see project pieces, still uncertain, fragmented and inconsistent. This integrated system is much more than the sum of its parts, both in potential for good and in problems presented.
- Vehicle Technologies
The voluminous NPC document gives little specific information about the kinds of vehicles to be used in the Washington Street/Tremont Street tunnel segments. It states only that "extensive public participation" and "community consensus" have selected the "Preferred Alternative" -- a mysterious unknown that was favored over light rail. However, the community has, for over a decade, fought for light rail, and opposition has come from a small faction concerned mainly with motoring speed and loss of parking spaces. In fact, only rail would serve the key corridor transit function: a direct connection to Boston's subway system.
The MBTA has been determined not to give the Washington Street community the kind of transit that would fulfill the l974 legal commitment for "equal or better replacement service." Boston's most transit-dependent inner-city neighborhoods have long been victims of "disinvestment," both public and private, and one look at a map of the Boston transit system starkly reveals the geographic correlation between race/income and quality of transit service. In addition, current Federal preference for bus transit (despite its many operational, urban design and environmental problems) retains and reinforces car priority on city streets. This strategy parallels local planning policy which supports building large parking garages and roadway "improvements" that will vastly increase the region's automobile burden in the coming years.
The "flexibility" of the bus mode is repeatedly cited as the chief criterion for choice. Indeed, the bus is too flexible; it is insecure. For example, bus routes can easily be changed or dropped, or frequency decreased, if budgets are to be cut or if privatized contracts seek efficiencies. As the documents says: "The use of ITS technologies provide the opportunity to adjust headways in a systematic fashion based on the occurrence of parking-related congestion." Such "adjustments" will further discourage transit use and add cars to the roads. Thus, the MBTA preserves the car-prioritycharacter of Washington Street at the expense of the corridor's transit riders, and reserves it for use as a highway.
- Vehicle Compatibility System-wide
The integrated Silver Line places a new constraint on the Washington Street portion. First, the existing Green Line tunnel to Boylston Station that would be linked to the proposed Washington Street service is made for rail, and reconstruction to accept buses would not only be extremely costly, but would preclude future connection to the subway system. The question may already be moot, as easements to the access portals are not being preserved by the MBTA. Second, CNG, the alternative fuel the MBTA seems to prefer, cannot be used or even carried in tunnels. The technology for the Piers Transitway is to be a rubber-tired vehicle of some kind, following an as yet undetermined surface route through the South Boston waterfront area. The Logan AITC is another technologically and operationally uncertain link in the "one-seat ride" from Dudley to the airport.
For a one-seat ride throughout, don't all the segments have to use the same vehicle? (And is the Dudley-Airport connection a high priority service for the Washington corridor community? We understand that what the community needs is a good connection to the downtown and the rest of the subway system.) Are the new and existing tunnels interdependent, or can either be built without the other? That is: Is the MBTA committed to both building the new Transitway tunnel to connect the Seaport/BCEC to the Back Bay via the Green Line transfer, and also to reactivating the existing Tremont Street tunnel to connect Washington Street to the subway system? Might the former be done without the latter, once again leaving the Washington corridor neighborhoods "in the back of the bus"?
- Costs
If buses were once favored as cheaper vehicles, the MBTA search for 60-foot, low-floor, articulated, "clean"-fuel buses has made light rail the cheaper and more reliable vehicle, in capital outlay, per-rider-mile, and life-cycle cost. Further, the Tremont Street tunnel is now proposed to be included in the plan; the Sierra Club, in its August l998 comment letter, cites an earlier MBTA ENF submittal (#8464) estimating that it would be far cheaper to build an LRV line all the way to Dudley, than to reconstruct the existing Green Line tunnel connection segment for bus use. If the MBTA is serious about this integrated system, this issue alone should reopen the discussion regarding the Washington Street vehicle choice.
- Air Quality Impacts
The evaluation of the new Silver Line is flawed in many ways. In particular, the Air Quality comparison concludes that the Silver Line will provide comparable results to the Orange Line, because it will be "powered by clean-fuel engines that will have lower emissions than the diesel buses currently operating on Washington Street." First, the MBTA cannot pronounce the new buses "comparable" to the Orange Line by comparing future and current buses (section 4.1, Air Quality); the comparison must be between the new buses and the Orange Line, in which case, evaluation results, for CNG- or diesel-use buses, certainly will not be comparable. Second, no buses have been chosen, and none are available that meet all the system needs. How can emissions for a non-existent vehicle be compared and victory declared? In fact, no air quality study is presented to support this pronouncement.
- Congestion Impacts
The proposed Washington Street bus service causes unresolved congestion and turn-around problems in both Chinatown and downtown Boston, and the South Boston Piers Transitway project presents unresolved routing problems around the Convention Center and the TW Tunnel. The document simply announces that "the Silver Line will reduce traffic congestion along the corridor." However, no data are given to support this conclusion.
- System Capacity:
The most significant flaw in the evaluation is the absence of "capacity" as a criterion. Both the South Boston Waterfront area and the Washington Street Corridor will be poorly served by the MBTA proposal; indeed, it is clear that transportation will become the major limiting factor on the enormous development opportunities anticipated in both areas. No adequate ridership study has been done for either half, and none at all for the integrated system. Capacity will be the key to transit in Boston -- and most of the system, current and anticipated, is, or is about to become, quantitatively and qualitatively inadequate.
- Vehicle Storage and Maintenance Facilities
Apparently, the Silver Line buses are now proposed to be stored and maintained in South Boston. The exact location is not certain, and community reaction is not revealed by this NPC. Even if such a vast and utilitarian facility can be placed in a freshly developing, highly valued district, the benefit of storing the entire fleet, including CNG buses, at one site is unclear, and will result in many vehicle miles of dead-heading to/from the Washington Street corridor. Have the air quality and other impacts been assessed?
The creation of a new Arborway Maintenance Facility for CNG buses is an odd piece in this puzzle. Is this neighborhood to be the repository for the rest of the "overall fleet system"-- vehicles that are not even to be used on the new corridor? Why is the entire Bartlett Street garage to be closed altogether just because it is over-capacity; why not relocate the excess buses, and keep storage more dispersed to reduce deadheading and large-scale disruption of community fabric? (We are astonished to learn that the MBTA ran Bartlett's excess buses all night through the winters to prevent freezing, in an area of extraordinary respiratory disease rates -- and in flagrant violation of City 5-minute idling laws.)
Other questions abound, regarding Arborway restoration, bus turn-around routes, bicycle accommodation, pedestrian/vehicular conflicts, system phasing, street re/construction phasing, and many other topics. It is impossible to finalize comments on a planning process so incomplete.
The MBTA, far from closing the process, appears to be very much in flux. Despite a lengthy history of filings, comments, and meetings, this Notice of Project Change/Response to Comments is not adequate in assessing either the capabilities of the integrated system, or its environmental, safety, and public realm impacts.
We request that a full Environmental Impact Report be required for the project as currently proposed, considering all projected development conditions and necessary financial commitments.
Before the MBTA submits an EIR, we believe another step is necessary. In the interests of full public participation, an extensive public hearing should be held on the full Silver Line, to give all parties an opportunity to bring forth current information, express concerns, ask questions, and present recommendations. The integrated Silver Line puts previous decisions into a new light, and poses new questions, which have not been answered by any document to date. This hearing, which should be recorded in detail, transcribed and widely distributed, should be held before a State body appropriate to provide a broad forum, and to pose critical questions. If MEPA itself will not hold such a public hearing, the State Joint Committee on Transportation would be an appropriate entity. The legislature's consideration of proposed forward-funding of the MBTA provides an opportune moment for this Committee to provide a higher level of leadership for this very significant project. Forward-funding can become a disciplinary tool toward the kind of proactive planning that is essential if sustainable development is to occur.
We await with great interest the MBTA's response to all of these questions and comments. And we look forward to an announcement of one or more public hearings, where the many voices of transit riders and other community stakeholders, public policy makers, and transportation experts can be heard in a comprehensive discussion of all the issues, both technical and social.
Sincerely,
Shirley Kressel, President
Alliance of Boston Neighborhoods
cc: John DeVillars, Environmental Protection Agency
Gordon J. Linton, Administrator, Federal Transit
Administration