March 11, 2002
Boston Region Metropolitan Planning Organization
10 Park Plaza, Suite 2150
Boston, MA 02116
Attn: Anne McGahan
via e-mail
RE: Boston Region MPO Public Involvement Program for Regional Transportation Plan
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 have participated in the MPO Environmental Justice Committee's work since its inception, and the ABN has previously commented on RTP drafts. We submit the following comments on the 2001 Plan Update in relation to the EJ Committee's role.
Recommended Plan Projects
The Draft RTP Recommended Plan omits the Light Rail Service on Washington Street. Contrary to the Draft's dismissive characterization of this service as something that "has been requested by several groups from the Roxbury district of Boston," replacement of the Orange Line with service of equal quality has been an MBTA commitment of over 15 years' standing, and was reqired as well as a Central Artery commitment. It was strongly recommended -- in fact, requested -- by the MPO's EJ Committee. Yet, it was not adopted by the MPO, citing Federal, City of Boston and MBTA pressure to use "bus rapid transit." There is no need for an "illustrative project" and further analysis for this project; it has been a commitment for over a decade. This MPO decision is an unacceptable slight of the needs of the largest transit-dependent community in the city and region, and continues our transportation agencies' long-standing racially discriminatory transit strategies.
The Draft explains this decision by saying: "Rapid Transit (BRT) systems have the potential to carry passengers as quickly and efficiently as light rail vehicles at lower cost." This may be true; however, the Silver Line will not be a BRT, by Federal definitions; it will be a bus, traveling in mixed traffic, into the most congested core area of the city. It will not provide service different from that of the current bus, and will fail to provide what the community needs most: connection into the rapid transit network.
The argument that the BRT provides service as quick and efficient as light rail at lower cost is also inaccurate, when calculated on a life-cycle basis. Further, the $165 million budgeted for the LRV is a mere 4.5% of the non-Artery $3.7 billion capital budget (and an infinitesimal fraction of the full with-Artery highway budget of the state). Moreover, as the Draft states, the MPO is (correctly) reconsidering the usefulness of some included projects, in particular the Red-Blue Connector, the deletion of which alone would save $220 million, much more than the cost of the Washington Street LRV; inexplicably, the Draft RTP speaks of reallocating this money to parking expansion for commuter lines, "frequency improvements" (frequency of what service is not specified) and more buses for the Urban Ring -- none projects of EJ benefit. The MPO has egregiously failed to meet an essential goal of its EJ mandate in excluding from the Plan this long promised project, which has been a high priority for the EJ Committee and indeed the EJ community as a whole for many years.
The Recommended Plan includes Phase 3 (or B) of the Silver Line, a tunnel through Chinatown to connect the Washington Street Silver Line route with the Piers Transitway at South Station. The usefulness of this very expensive tunnel, the problems with the bus conversion of the existing tunnel segment from Chinatown to Boylston Station, and the technological issues of vehicle compatibility for the whole route, have been questioned by the EJ Committee and the Boston Transportation Department, and alternatives .have been suggested that are less expensive (see BTD Access Boston report and information provided by Bob Terrell, Washington Street Corridor Coalition). The solution in the Plan involves hundreds of millions of dollars, and the MPO has not looked seriously at the alternatives.
The Recommended Plan omits the purchase of clean buses, another improvement that is very important to the transit-dependent EJ communities, which suffer extraordinary respiratory disease rates. The Red-Blue Connection could pay for both the Washington Street LRV and these buses; clearly the financial constraint is not the reason for these omissions. The MPO has not explained their reasoning convincingly.
The Draft RTP implies that the majority -- 3 out of 5 -- EJ committee "recommendations" were followed. However, the Arborway Restoration had already been included earlier as a mandated commitment, with or without the EJ Committee's intervention. And the improvement of service on the Fairmount Line is a very vague prospect; at recent public meetings held by the MBTA, no clear program of improvements was promised or even outlined. The community had expected a meeting on the "Indigo Line," which would provide service by the Fairmount Line comparable to the other MBTA rapid transit lines; this level of service was not even under consideration by the MBTA, and no indication of better frequency, extended hours, station safety, access and signage, or even consistent stops (as opposed to current "flag stops") was given. Therefore, it is not clear what the $29 million budgeted would cover, despite the description in the Draft RTP. In sum, the members of the EJ committee seem to have wasted a substantial amount of time, only, it seems, to have legitimized pre-conceived outcomes.
Two of the projects the MPO did include which are designated by the Draft RTP as beneficial to the EJ communities are actually highway projects (Route 126/135 grade separation, Mahoney Circle in Revere) that will benefit drivers using congested highway interchanges. It is disingenuous and cynical to pretend that we must help automobile through-traffic move faster through poor neighborhoods to save the residents from the pollution of idling cars stuck in traffic jams; this is an issue the EJ committee discussed. It is well known that alleviating congestion by improving roadway capacity (rather than reducing car use) is akin to treating obesity by loosening one's belt; facilitating driving only leads to more driving. These items are not only not beneficial for the poor communities that are being used as traffic corridors; they reflect short-sighted and environmentally harmful planning for the whole transportation system.
The Recommended Plan includes only Phase 1 of the Urban Ring; the ABN has commented previously on the need to proceed immediately to Phase 3, the rail Ring; Phases 1 and 2 are simply roadway projects classified as transit because of the buses involved. The scant environmental benefits of Phases 1 and 2 do not justify the vast financial expenditure. We also commented that even the rail Ring proposal must be significantly modified to provide routes that not only travel through EJ communities, but also serve the EJ communities along the route.
EJ transit performance measures
The four measures listed were considered by the EJ Committee as preliminary indicators of equity in transit; however, as the results were reviewed by the MPO's EJ committee, problems were seen in interpreting these performance measures as the critical indicators. The committee asked that additional data be collected, data requiring new surveys, for a more comprehensive measurement of the overall serviceability of the transit system for people's transportation needs in daily life. EJ communities do not use transit the way suburban residents do, for commuting to jobs or occasional trips into the city for entertainment or shopping; they need transit that will support all their mobility needs -- children's activities, education access, health care access, recreation, civic activities, family activities, child care, etc. For this pattern of use, carefully distributed routes, headway frequency, and absolute dependability of service on all days and at extended hours, is essential. The RTP should include, as the committee discussed, an intention of using the UPWP to fund special studies of people, rather than of vehicles, toward this kind of service evaluation.
The committee also asked, as the Draft RTP states, for comparison of EJ-benefit and other projects. Such an analysis is not included in the Draft. Not all transit projects are EJ-oriented; commuter rail is not, nor is the Russia Wharf Ferry Terminal. Further, commuter parking is not beneficial to EJ communities. Indeed, as we have argued at meetings, the proliferation of commuter parking lots, promoted as a transit-supporting expenditure, is extremely harmful in the long run; these parking centers enable ever more distant suburban sprawl, and are destructive to the fabric of towns (many of them historic) along the lines, towns which are fast being overwhelmed by parking.
In addition to a comparison of relative costs, the MPO should compare capacity increases for EJ and other communities. Dollar amounts vary based on technology and other artifacts, and may not reflect the actual amount of service capacity being added for populations served. Putting money into stations, for example, does not add capacity although it may enhance serviceability of transit.
RTP Policies
Policy 7, which refers to EJ policy, needs some explanation in the way it is used to evaluate proposed projects; the impact of most projects marked as positive or neutral is not clear on EJ is questionable. Most notably, as currently proposed, the Urban Ring would not adequately serve EJ neighborhood populations. EJ representatives have for years attended meetings protesting the routing of the Ring as excluding their communities. The "+" rating for the Urban Ring has not been earned by the planning to date. As it stands, the Ring is primarily designed to relieve radial rapid-transit traffic in the inner core by intercepting commuters along the institutional crescent and connecting them with either buses or parking garages along the Ring.
Policy 2 includes an implementation item calling for public-private partnerships to fund transit. This is a strategy that the EJ Committee specifically rejected, for reasons explained in detail in the October 31, 2001 memorandum from Anne McGahan and David Mohler to the Sub-Signatory Committee. Private funding will inevitably lead to corporately driven decision-making, which will disadvantage EJ communities. Yet again, the Draft RTP ignores the EJ Committee's work, promoting privatization without even attempting to add safe-guards to protect against the consequences feared by the EJ committee members.
Modeling of Alternative Build Outcomes
The Appendix D summary of modeling results using alternative project sets says that differences across alternatives are minor (which is likelier to indicate that the alternatives chosen may not be allowing for testing of sufficiently different planning strategies, rather than that overall system outcomes are not sensitive to planning changes, as implied in the text). However, as written earlier in the Draft, differences are more important in individual areas than in the over-all system; these differences can be extremely important, especially in EJ communities. Two interrelated conclusions in Appendix D are especially troubling:
- Little shift from cars to transit is expected,
regardless of project planning, in what is called
Boston's "mature transit system with established rider
markets"; aspirations seem limited to shifting existing
transit riders to new services, primarily to relieve
over-capacity congestion on core radial lines.
- Automobile volume-to-capacity ratios (congestion) are decreased, in all the build options, by adding expanded roadway capacity, and "these results are expected." This is the wrong way to remedy congestion; the right way is to decrease car use -- by shifting more drivers to transit. Capacity increases are a sure generator of more congestion and more capacity need, in a continuing spiral of increased car use.
We hope to see a final RTP that is more responsible in serving the EJ communities of the region. As it stands, the current Draft renders the MPO's EJ effort largely irrelevant.
We also urge the MPO to adopt more enlightened goals toward controlling car use and measuring congestion relief. The current attitude as expressed in this Draft will not lead to better transportation planning, nor to better land use policies among the region's communities.
Sincerely,
Shirley Kressel
Vice President
Alliance of Boston Neighborhoods