Transportation Plan, c/o CTPS
10 Park Plaza Room 2150
Boston, MA 02116
Via e-mail
January 5, 2000
Re: Comment on Boston MPO Transportation Plan 2000-2025
To the reviewers:
The Alliance of Boston Neighborhoods is an association of community civic organizations, formed to promote genuine public process and to participate in decision-making on issues of city-wide importance. We submit the following comments on the Draft Transportation Plan for the Boston Region 2000-2025.
Chapter 1 Process and Policies
The Draft speaks of a "public involvement program that went beyond traditional measures" to assess the effect of proposed transportation policies on under-served populations. However, attendance at both the environmental justice sessions and the general public meetings was quite low. The public meeting at the Boston Public Library on December 5, 2000 was attended by a handful of people, well outnumbered by staff. It was scheduled at the same time as the MBTA Capital Investment Program public meeting, and with insufficient public notification. The environmental justice forum at the Boston Public Library was also very poorly attended. Sign-in sheets for public meetings, as well as written and verbal comments to date, should be presented by the MPO together with the Plan submittal. The MPO needs to do more effective outreach, with information not only about meeting dates but about the role of this Plan in obtaining Federal funding and the core importance of equity in the Federal requirements.
By contrast, the hearings on the MBTA fare increases, which I attended, drew hundreds of participants, who commented extensively on service needs. Absent such broad-based attendance at their own hearings, the MPO should obtain transcripts of the fare hearings, and include them in the comment record for this round. They contain ample information about fairness in allocating costs and benefits. The sign-in sheets and comment letters for those hearings should be used to expand the MPO mailing list for meeting announcements. I attach the Alliance comment letter submitted at those hearings.
The Draft also does not yet respond to previous public input, notably the Recertification comment letter submitted by Alternatives for Community and Environment.
The MPO convened a sub-signatory meeting on December 27 to review public comments. Since the comment deadline is January 5, how will public comments submitted after December 27 be considered?
Guiding Principles and Strategies for Plan 2000:
The Draft says, "Sprawling development is wasteful of
limited infrastructure dollars and detrimental to the
quality of life which is an essential component of our
economic competitiveness." It is a reversal of the proper
order of principles to define quality of life as a means to
economic competitiveness. Quality of life should be the
goal, and economic activity the means. The economy must
serve the society, and not the other way around. This is
not a mere semantic quibble, but invokes the essential
foundation for the Plan. As the Draft Plan stands,
economics take priority over quality of life equitably
distributed--i.e., environmental justice.
The document goes on, "Consequently, this Plan attempts to be generally consistent with the adopted land use plan for the Boston region." Currently, municipal plans are causing sprawling development, not reigning it in. The MPO must work proactively to shape land use plans, as well as transportation plans, in order to change current development patterns, not accommodate them.
We recommend restructuring the proposed Policies as follows:
Policy 1 (Draft Policy 8)
Public involvement is key in all
transportation planning. Transportation is not a remote,
academic area of planning; it affects every person's life,
every day. People have very specific needs, and constant
communication is essential to assure that the system is
responsive and supportive to all aspects of the region's
activity. Indeed, it is impossible to make good policies
without meaningful public involvement. The MPO will arrive
at a legitimate Plan only if this policy is the basis for
planning.
- Policy 1 (Draft Policy 6)
Environmental justice and resource allocation equity should be the first substantive priority, to ensure that transportation system benefits and burdens are shared equitably. Mobility is essential to all aspects of life: work, education and training, child care, health care, civic life, recreation, access to goods and services. Inequities in transportation fundamentally curtail other opportunities for individual, family and community well-being. This is why the Federal requirement for environmental justice is so appropriate and so vital. It is well known that low-income and minority communities have been short-changed on transportation benefits. They have also been forced to bear the "externalized costs" incurred by more privileged communities. These include environmental pollution, occupation of neighborhood land for uses (e.g., parking garages) benefiting others, and subordination of urban transit to suburban investments when budgets are constrained. - Policy 2 (Draft Policy 4)
Environmental sustainability is co-equal to social equity, and indeed is integrally related. A system where every beneficiary oftransportation must actually bear the environmental burdens will be most likely be designed to minimize those burdens, which are currently shunted to others. The environmental sustainability criterion encompasses not only direct pollution impacts, but the many other impacts of poor transportation and development planning on open space preservation, energy efficiency, aquifer, habitat and biodiversity protection, etc. - Policy 3 (Draft Policy 9)
Integration of transportation and land use policies are essential for more efficient use of transportation resources, and more synergistic and compact use of land, promoting environmental sustainability. The MPO must both "target transportation investments to areas identified in local and regional plans as suitable for concentrated development," and also work with local governments to plan land use consideringtransportation options. The action items listed are good ones toward this goal. - Policy 4 (Draft Policies 3 and 5)
Providing transportation options and integrating modes, for both people and freight, comprise a related set of concerns.
Draft Policy 1 Support the economic vitality of
the Boston region...
If the above four policies are carried out,
the transportation system will support economic vitality in
an equitable way. A specific policy that puts priority on
projects and areas of highest economic "competitiveness"
and "productivity," on projects that "improve services in
and to centers of economic activity," will tend to funnel
resources to areas that are already privileged and well
represented politically. The desirable action items listed
in this policy can be re-categorized in policies 2-4
above.
Draft Policy 7 Emphasize maintenance and
modernization of existing system in efficient state of
repair...rather than building new
infrastructure....
We disagree with this policy. We strongly object to the
MPO's intent to "prioritize projects [that] maintain and
improve existing infrastructure rather than projects that
build new infrastructure." This is a "backward looking"
policy to which "forward funding" has been calibrated, and
it dooms the transit system on which sustainable urban
development depends to a status quo without progress.
Obviously, the system requires maintenance and periodic upgrades, but this is a long-term plan, and such an item seems self-evident and routine. Maintenance of services in a sufficient state of repair is not an item that merits a position in a policy statement -- unless it is intended to lower public expectations. We need a Plan that recognizes the critical need to vastly expand the public transit system to support the kind of city and regional growth that is occurring, expected and desired.
Draft Policy 2 Ensuring safety and security of transportation system users is not in itself a "policy" for a long-term plan. It is self-evident that safety is an integral consideration for any public service, and should be part of every policy above.
Chapter 2 Physical and Environmental
Conditions:
Concentrated Development Centers:
Transit-Oriented Development must be defined not only as
near mass transit, but dependent on mass transit. That is,
a high-density development near a train station which still
builds a parking garage is transit-adjacent, but not
transit-oriented. The city of Boston is filling with TOD's
which include huge garages, and Telecom City, cited as an
example of a TOD, is actually a vast sprawling low-density
suburban-style industrial park, without a jobs/housing
balance, without a mixed-use walkable urban fabric, with
huge parking facilities, and with very little orientation
to the Orange Line near-by.
Demographics of the Region:
Since the 10-year census was just completed, the 25-year
plan should be based on new census data, even if it
requires a delay in finalization.
Chapter 5 Transit System:
Silver Line:
The description of the Silver Line as a Bus Rapid Transit
system is erroneous, as the bus will not meet Federal
definitions of BRT. This is merely a bus route, regardless
of euphemistic names implying that it is part of the rapid
transit system. The tunnel connecting this bus to the South
Boston waterfront will cost over $700 million, and is a
distant and uncertain prospect. I believe a clean
(non-diesel) dual-mode vehicle for Transitway use from
South Station to the World Trade Center has not yet been
identified. The capacity and efficiency of this Silver Line
are expected to be grossly insufficient for transit needs
to the developing waterfront, and those developers are
planning to meet their needs with fleets of private
(diesel) shuttle buses.
It is interesting that the Draft mentions the long history of replacement of rail lines with buses. The attrition of fast, dependable rail and replacement with buses mired in growing car traffic continues to this day, disproportionately disadvantaging low-income neighborhoods. The Silver Line is nothing more than such a disinvestment in mobility for communities of color.
Park-and-Ride Facilities:
The Draft discusses political resistance by communities
along the commuter rail lines, who refuse to host
ever-growing parking facilities which destroy their quality
of life and environment. This concern is legitimate; the
spread of parking lots and garages has destroyed the
historic character and natural environment of many
rail-line towns. We must recognize the impossibility of
meeting endless parking demand by providing parking, and
look to planning closer, denser settlement patterns that
can be served by bus/jitney lines -- or pedestrian
sidewalks --connecting to rail stations.
However, there is no recognition of the same impact on inner city neighborhoods. The Draft states that limited park-and-ride facilities lead commuters to drive into the city rather than to take the train. No mention is made of the parking spaces being built for their convenience at the end of that drive, destroying the quality of life and environment for the half-million residents of the city. The explosion of parking capacity under way in Boston (25,000 new parking spaces in the pipeline, on top of the existing 60,000 commercial and 100,000 "accessory" spaces) is not acknowledged as a determinant of traffic or as an enabler of sprawling development patterns. The "safety valve" that the city is providing by filling with garages isdevastating both the urban and suburban communities. The growing parking capacity of the urban core must become a central focus of the MPO. Alternative scenarios for land uses must project consequences of allowing this trend to continue vs freezes on urban parking construction.
Conclusion:
We protest as short-sighted, illogical and discriminatory
the Blue Ribbon Panel's conclusion that "expansion, while
necessary to satisfy the transit demands of the region,
must in the future take a back seat to maintenance of the
existing system." The environmental, social, and economic
health of the urban core and the metro region is directly
dependent on expansion of transit capacity to meet
projected development. It is foolish to conclude otherwise
unless the MBTA wishes to be an instrument of growth
stultification, or the State administration aspires to make
Boston, the cradle of public transit, a miasma of polluted,
congested highways like the cities of the south and west,
where people sprawl in far-flung communities and spend half
their time driving to and from devastated, unlivable city
centers and cookie-cutter suburban "edge cities."
There is no justification for this conclusion in the Draft. There is no reason given for devoting "fully 70% of all capital available to the MBTA to maintenance." And moreover, there is no reason for the fiscal constraints EOTC has chosen to impose on this Plan, particularly in this time of government surplus. The proper way to begin the forward funding era is to determine what transit is needed to support a 21st century Boston, and to allocate public funding streams to build that system. Instead, the revenue stream has been carefully calibrated to support only the most minimal upkeep of the system. And most of this austerity budget will benefit drivers, not transit riders, violating the principle tenet of the Transportation Equity Act.
The Conclusion states that "the demand for transit will grow over the next 25 years." The Draft acknowledges that "The central subway system will be experiencing dramatic growth, with the greatest challenge coming to the Red Line and the Green Line central subway." However, no mention is made of plans to meet that challenge. Then the Draft goes on, "This demand is especially pronounced in the need for additional capacity of both north and south-side commuter rail infrastructure." For commuter rail, the Draft proceeds to lay out specifics: commuter rail parking spaces, rolling stock, bi-level commuter cars. Environmental justice is not considered in the choice of challenges to be met.
The Draft then posits a need for improved bus service. Bus service may work in the suburbs, but the city needs rail -- a full network of light-rail tracks to serve the metro core in an environmentally sustainable and socially equitable way. Bus service is being used to avoid capital investment in rapid-transit rail.
The last paragraph of the Draft says, "The work on the 2001-2025 Transportation Plan will need to focus on these two areas to see what projects are best suited to further complement the existing transit system in the region." What two areas are being referenced?
Finally, the Draft mentions the Urban Ring and North-South Rail Link "to be further explored." Will they be explored in the final Plan?
Chapter 9 Forecast of 1995 Base Case and 2025
Build Scenarios:
Changes in Transit Ridership:
The Draft states that the growth in transit ridership, both
urban and suburban, does not model the effects of
constrained supply of capacity of rail and of park-and-ride
spaces. The Tables 9-1 -- 9-6 are simply demand projections
based on demographics, but actual behavior will depend on
added availability of transit infrastructure. The final
Plan should explicitly project the transit shortfalls or
"constraints." These shortfalls should be quantified by the
model, and help to inform the Plan in terms of new capital
investment needed. The model should show a constrained
version, indicating how much more car traffic and air
pollution will result if the needed transit is not
provided.
The final Plan should also correct what the Draft calls a "disequilibrium" in projections, by modeling the probable impacts of transportation investments made, and not made, on the demographic future and development of the region. This model should project the impacts of parkingcapacity built and not built in the city of Boston and other municipalities, since the availability of parking capacity is the key determinant of travelmode choices, and as both roads and transit become increasingly congested, of residential and economic development siting decisions.
Chapter 10 Recommended Plan:
The Plan seems to be based on "forward funding" for "backward looking." The projects in the Plan are old commitments, in an austerity strategy that will result in a spiral of reduced transit service and consequent reduced demand for service. We hope it is not an omen that the MPO's further planning for additional projects is to based on a Financial Plan titled "Chapter 11."
The "fundamental decision" made by the MPO to invest its capital primarily in maintaining an aging transit system is a fundamental error. The Boston region depends on new transit capacity to thrive, both as a community and as an economic center.
The list of criteria for the Plan, "taken as a whole," is, like the Policies at the beginning, inverted. The inclusion of public involvement must be the genesis of public policy, and should drive both the over-all funding of, and allocations within, the Transportation Plan. Again, Environmental Justice requirements and air quality standards must be primary criteria for the Plan. ADA requirements are not negotiable. The fiscal boundaries for this Plan have not been set properly, and should be re-calibrated to assure that the region does not become a spreading layer of traffic-choked sprawl, gobbling up greenfields while the center is transformed from a living community to a destination office-park/theme park for suburbanites and tourists. The Draft Plan is a regressive one, with grave implications for those who live in and depend on the region.
Table 10-1, Regionally Significant and Other
Large Projects:
This table should have two more columns. One should state
the total cost of each project, so that the full extend of
the MPO's commitment to it is known, in addition to the
column showing Remaining Cost. The second new column should
state how much new capacity the project would add. The MPO
needs to be clear about the impacts of these investments on
the actual service capacity of the system.
In addition, the categories should break out not only Roadway Projects, Transit Projects, and Intermodal Projects, but also Urban and Suburban projects. Thus, the Worcester Commuter Rail, the Greenbush-Old Colony project, and the Additional Park & Ride Spaces would be Suburban Transit. This distinction is important in the discussion of Environmental Justice.
The inclusion of the Arborway Restoration in this Plan is disingenuous, since the MBTA has no intention of restoring the Arborway portion of the Green Line. In fact, the MBTA is currently attempting (over vehement community protest) to begin an "infeasiblity study," to prove that the restoration is impossible, or unnecessary, or both. We have commented at a recent public meeting about the biased study methodology.
The Silver Line Phase B -- NEMC to South Station project must be broken into its two components, which have very different cost implications. There are two tunnel sections involved: There is an existing tunnel, into which a light rail replacement service train could easily run to connect Washington Street into the Green Line subway, but which would have to be reconstructed at considerable expense to retrofit for the bus that the MBTA insists on using instead. This tunnel runs from the Don Bosco portal to Boylston Station, and if retrofitted for bus, would preclude future upgrading of the Washington Street line to light rail. The Sierra Club, in its August l998 comment letter on an earlier MBTA ENF submittal (#8464) estimated 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, so this subway connection, if it is truly intended, is not budget-wise.
The second tunnel portion would be new, connecting Boylston to Chinatown Station and to South Station, where the South Boston Piers Transitway will begin. This tunnel would be even more expensive.
The Plan should specify the cost estimated for each tunnel portion. Many community transit advocates fear that the two are combined so that the MBTA can garner public support for the whole, but build only the new portion. The first piece would be used as the Environmental Justice lever, with the funding requested to "serve" the disadvantaged neighborhoods, and when the project runs over budget, only the new portion would actually be built, connecting the new South Boston developments and convention center to the Back Bay hotels and entertainment venues.
The Draft states that "most of the work of the MPO in the future will be devoted to the maintenance of its existing infrastructure. This is work that does not add capacity to the system but rather extends the life or modernizes the system. Therefore these types of projects are not specifically listedin figure 10-1." If most of the MPO work in the future belongs in the categories described in this section of the Draft (and we fervently hope it does not), we need an itemized list of these projects and their costs.
Future Vision Projects:
This Plan's recommendations are "extremely constrained" due
to a need to "clarify future funding scenarios." This seems
backwards. The Plan should lay out what is needed, so that
funding scenarios can be shaped to support it. It should
model outcomes to regional development if the Rail Link,
the Urban Ring, and other major projects are implemented,
so that appropriate funding can be sought from State and
Federal sources and priorities can be set. It is simply too
dangerous for the region to plan backwards from an
arbitrary budget on something as critically important as
transportation.
We have heard the MBTA state that future capital improvements will have to be funded by private investors and "public-private partnerships." We reject this strategy; it will privatize transit and will privatize planning for both transportation and development. Public transit must remain a public service. Environmental justice depends on that.
Chapter 11 Financial Plan:
Please explain why the local assessments were set back to
year 2000 levels for the first five years. How much
additional revenue would have accruedif assessments were
raised 2.5% each of the first five years?
Please explain PAYGO funding and New Start funding.
Please explain how the decision was made to allocate one cent of sales, and not more, to MBTA in the Forward Funding plan.
Please explain how the amount and timing of the fare increases were decided.
How much revenue will be lost in the 25 Plan years because fare increases stop growth in ridership (page 132)?
Chapter 12 Environmental Justice
Measures:
Our general comment on environmental justice is that this
critical issue should not be a separate section (at the end
of the Plan) but should be integral to every aspect of the
Plan: public process, policies, existing conditions
analysis, project recommendations, financial planning. Much
information about inequities in funding, service, and
health status is available already, and better measures
will be developed in the coming phase. We hope the final
plan will be reorganized to reflect such integration.
To repeat just a few of the comments made at EJ meetings:
Any measurements of transit access must distinguish rail from bus. Quarter-mile access to a bus stop is not equivalent to quarter-mile access to a subway station. Commuter rail proximity and frequency must also be evaluated differently from that of city center rail, since it serves different needs. Trackless trolley must be considered separately as well.
Car ownership does not have the same meaning in poor and affluent areas. For more affluent people, car ownership is a choice for personal convenience. For low income people, car ownership is a financial burden carried because transit is inadequate for most travel needs.
Residential proximity to a bus stop or even a transit station does not, as you point out, mean that the service is adequate for people's needs, in scheduling, connections, speed or quality. The importance and feasibility of a direct survey was discussed during your meetings, and this is the only reliable way to get meaningful information on the service adequacy and unmet need. The survey should be designed to include respondents from a residential sample, not only from a rider sample, to be sure to include people who do not use transit because it does not meet their needs.
The Conclusion section is far from satisfactory in interpreting the preliminary data about service. The next few months should bring a deeper analysis of the criteria for judging city vs suburban transit adequacy, and a more refined set of measurements. The indicators used do not capture the true picture of environmental justice.
Another piece of information should be included in the
final Plan: Past trends in Boston transit should be
documented, in particular, city subway rail lines that have
been removed and replaced with buses, and rail stations
that have been closed, leapfrogging certain communities
while connecting others to the city center. The gradual
atrophy of the city subway system over the last fifty
years, while the commuter rail network has been increased
to accommodate (and enable) suburban flight, must be
documented carefully for any understanding of environmental
justice. Whole neighborhoods
have been disconnected from the subway system, and left,
literally and figuratively, in the "back of the bus," with
devastating social and economic impacts on thousands of
residents. Their time, spent walking to, waiting for, and
riding buses which crawl through increasingly congested
traffic, must also be factored into the "cost" calculations
of planning decisions. Their curtailed opportunities for
work, recreation, health care, day care, education, and
shopping must be reckoned in "efficiency" assessments.
We ask also that the MPO Plan include a section discussing the previous Plan, and the status of the projects proposed before. Again, the categories should distinguish Urban and Suburban projects.
Chapter 13 Air Quality Conformity
Determination:
Air quality should be measured in specific neighborhoods,
such as Roxbury and South Boston, where diesel buses and
airport traffic, cars and planes, cause extraordinary air
pollution associated with high respiratory and other
disease rates.
The draft Plan discusses VOC, NOx and carbon monoxide, and ozone measurements. Small particulate matter, associated with excess disease and death rates, should be measured as well.
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We have not commented here on all sections of the draft Plan, but we will be providing input on those issues over the course of the coming months. We look forward to seeing the MPO's response to public comments, and to participating in an inclusive and comprehensive planning process during the refinement of the Plan.
Thank you for this opportunity to comment.
Shirley Kressel, President
Alliance of Boston Neighborhoods
cc:
Richard Doyle, Regional Administrator, Federal Transit
Administration
Curtis Davis, MAPC Environmental Justice Committee Member
Veronica Eady, EOEA
Charles Yancey, Boston City Council
Chuck Turner, Boston City Council - John Rumpler, ACE
Karen Wepsic, Federation for Public Transportation
John Deacon, Sierra Club
Bob Terrell, Washington Street Corridor Coalition