October 29, 2001
Ms. LeAndrea Dames
MEPA
251 Causeway Street, 9th floor
Boston, MA 02114
Via e-mail:
Re: "Circumferential Transportation Improvements in the Urban Ring Corridor Expanded Environmental Notification Form (ENF)," July 2001
Dear Ms. Dames:
The Alliance of Boston Neighborhoods is an umbrella organization of neighborhood civic associations, promoting informed citizen engagement in issues of city-wide importance. We have the following comments regarding the MBTA's submittal on the Urban Ring.
Our concerns are for sustainability and environmental justice. The Urban Ring has long been hailed as a key to both: to reduce car use in the region in favor of public transit, to shape land development in more sustainable patterns, and to better serve the long disadvantaged and heavily transit-dependent communities of the Ring corridor. Over the years of planning, the Ring has been increasingly fashioned by the MBTA as a relief system for congested core radial lines, and to save "in-and-out" travel time for suburban transit commuters and clients of major "trip generators," largely the institutions in the corridor.
The Ring has also been fashioned as a circuit of bus routes, under the rubric of "Bus Rapid Transit," presumably to conform to the current Federal preference for bus technologies over rail. As it stands, the Ring project would begin with a basically "no-build" phase, consisting of minor improvements of the current bus system. Phase 2 would focus on more buses, some of which would travel in marked but not physically separated rights of way, using a proposed vehicle (60' articulated low-floor CNG bus) that to date does not exist in tested and commercially available form; new capital investment would be budgeted for commuter rail stations. Not until Phase 3, projected for completion in 2015, would new rail be built in the corridor, and then primarily in the eastern institutional segments.
We believe that this phasing and distribution of transit resources will risk indefinite delay in the rail component, waste resources on buses and road-building that will have little social or environmental benefit , and under-serve the residents of the corridor . Many residents have expressed their expectation that the Ring will become, after all the years of work invested in it by people all over Boston, a collection of buses, a stealth highway, and in effect, the inner belt, complete with a Turnpike ramp, reincarnated for commuters and other visitors to the city . The Ring as presented is seen by community people as a way to spend transit funds on highways.
Therefore, we recommend the following:
Phases I and II should be eliminated. The Urban Ring should be built directly as a rail project, phased if necessary.
Phase I, Transportation System Management, should simply become the adjustment of the current transit system to best support the chosen rail network.
Phase II does not merit the estimated half-billion-dollar investment of money, nor the half-decade of time allotted to it. During this time, enormous -- and irreversible -- environmental damage will be done by an increasingly car-dependent regional development pattern of land-devouring sprawl. The current development and transportation trends cannot be changed without a real transit system for the 21st century: a rail system.
The budget for a full rail system should be established, and State and Federal funding should be sought for it; it may be constructed in phases if necessary. Our State and Federal governments have supported an investment of some $15 billion in a project encompassing a few miles of highway that will, it is widely acknowledged, be obsolete when it opens. It is time to put commensurate investment into rapid transit. The environmental, economic and social benefits of a full-rail Phase 3 will be immediate, enormous, and enduring. The MBTA estimates of mode shift from automobiles to transit reveal clearly the different magnitude of impact to be achieved by bus vs rail.
The design of a rail, not bus, Ring should be the subject of the MBTA's EIR/EIS study. The study should examine very explicitly and clearly the following:
- The land use planning modifications
implemented by the Ring communities, documenting
exactly how they are -- or should be -- limiting parking
capacity, clustering development density, and mixing land
uses to create jobs/housing balances, walkable
neighborhoods, etc. Federal and State funding of each
community's transportation projects should be directly
dependent on sustainable development that meets these
criteria. Currently, the City of Boston, and its
neighbors, are building parking garages at unprecedented
rates, even within walking distance of transit stations.
We note the inclusion of Everett's Telecom City, a
single-use, sprawling office park with some 5500-6000
parking spaces; Somerville's big-box-in-asphalt Assembly
Square Revitalization Plan; Cambridge's Kendall Square,
an example of suburbanization from within, and Boston's
garage-based projects and plans, exempted by their
"accessory" classification from the City's so-called
"parking freeze," as illustrations of "Plans and Policies
Consistent" with the transit-promoting goals of the Urban
Ring. Development projects continue to build garages and
strip our communities of powerful transit constituencies;
the spiral of transit disinvesment will in turn continue
to spur car-oriented development within the city core and
sprawl outside it. The Ring investment must be used to
support, and require, real transit-oriented development
in all the corridor communities.
- The environmental impacts of a rail Ring on
regional travel mode shifts must be carefully
projected, with the broadest definition of
"environmental," and full accounting for all the
"multiplier effects" of environmental benefits. These
impacts must be account for the land use changes the Ring
would support. Aside from vehicle emission impacts on air
and water quality, the environmental impacts of dense,
clustered transit-based development with respect to open
space, water, soil, habitats, historic landscapes and
livable urban centers should be quantified. The MIS shows
the vast difference in mode shift from car to transit
that could be achieved by rail rather than bus. Curbing
car use is the single most important key to sustainable
development, to smart growth and smart road and transit
planning, and to transit constituency-building.
- Environmental justice must be served by the Urban Ring. The MBTA has documented the lower incomes in the corridor, and the higher transit dependency. But the design so far has focused on suburban commuters and clients of the institutions and other employment centers in the corridor. After years of requests from the neighborhoods, Phase 2 as proposed still shows a bus line bypassing Dudley Square, a major transportation hub on the Washington Street Corridor. Phase 3 shows an extension to Dudley, a segment which, even if it were built, would not serve to connect Dudley Square with other destinations desired by the community, such as Upham's Corner. The corridor communities are "Environmental Justice" communities, long suffering transportation and economic development disinvestment. Their needs -- both for travel into downtown and around the city, and for reverse commuting to suburban jobs -- must be a top priority. The Ring must not repeat the past highway practices of simply burdening them with the costs of more convenient work, shopping, and health care travel for suburbanites. The analysis of this element of Ring planning should be coordinated with the work of the MPO Environmental Justice committee.
We urge the Federal and State agencies involved in transportation planning for this region to instruct the MBTA to proceed directly to the rail phase. As stated above, the project should proceed to propose rail alternatives that prioritize support for the transit-dependent communities of the Ring corridor. It should document the land use planning improvements made by the Compact Communities, and estimate all environmental impacts broadly defined. The project should also study a no-build option, to demonstrate the damaging environmental consequences of failing to build this rail corridor.
Sincerely,
Shirley Kressel
President, Alliance of Boston Neighborhoods
Cc: Peter Calcaterra, Project Manager, MBTA
Richard Doyle, Regional Administrator, FTA