The MBTA has filed a Notice of Project Change document for the new proposal for the portal location of the Silver Line, along Tremont Street between Charles Street South and Marginal Road. A hearing held by the MBTA Oct. 19, 2006, reviewed the project and registered public comment. Written comments may be filed with MEPA no later than October 30, 2006. For full information, call 617-222-6950 or go to: www.allaboutsilverline.com/environmentalreview.asp
Letter below was submitted by the Bay Village Neighborhood Association.
Bay Village Neighborhood Association, Inc.
October 23, 2006
Andrew D. Brennan
Director of Environmental Affairs
Massachusetts Bay Transportation Authority
10 Park Plaza, Room 6720
Boston, MA 02116
Sec. Robert Golledge
EOEA, Attn: MEPA Office
William Gage, EOEA No. 6826/11707
100 Cambridge Street, Suite 900
Boston MA 02114
We write to express the opposition of the Bay Village Neighborhood Association (BVNA) to the proposed Charles Street Modified Alignment for the Silver Line Phase III due to:
- the severe environmental impact it will have on the Bay Village neighborhood, and substantially increased risk of catastrophic environmental damage versus earlier proposed alignments;
- the lack of substantive analysis of alternative modes of transport--the single greatest determinant of environmental damage--in previous filings or in this Notice of Project Change;
- the violation of applicable Federal and State regulations requiring active and substantive public participation in determining all aspects of any proposed project;
- the lack of financial viability of the sponsoring agency, the Massachusetts Bay Transportation Authority, and its prima facie inability to fund implementation of environmental mitigation and remediation that will be required by this project;
- the MBTA’s incomplete, unsubstantiated and materially false calculations of projected ridership and usage;
- the extreme cost-ineffectiveness of this project. Even using the MBTA’s own figures, which unrealistically overstate the projected ridership and simultaneously understate the cost by some 100%, the cost per passenger-mile through the proposed portal described in this Notice of Project Change, for instance, is approximately 10x greater than that of the Central Artery Project.
This opposition to the alignment proposed in this Notice of Project Change does not supersede our previous opposition to ALL other alignments proposed for the Silver Line Phase III. While the BVNA is highly supportive of public transportation and believes that projects designed with the active involvement of citizens are essential, the mode of transport for the Silver Line (Bus Rapid Transit) was chosen without adequate regard to public process and is entirely inappropriate for a congested urban setting such as downtown Boston.
Further, we note our extreme disappointment that the handful of proponents that exist for this project have expressed no environmental concerns whatsoever in public hearings or written comments. Given the potential for grave environmental impacts, one can only conclude that such support is predicated on a superficial understanding of the project and potential alternatives and limited concern for the greater public good.
Lastly, we believe this project must also be assessed in light of the recent construction history of Boston, and not simply in isolation. The incremental effects of yet another massive, multi-year, billion dollar plus tunnel construction project through the central core of Boston are more severe than would otherwise be suggested by stand-alone analysis.
Bay Village Condition: Portal Siting Through The Entire length of Neighborhood
The history of landfill in Bay Village is extensively documented in books such as “Gaining Ground: A History of Landmaking in Boston,” by Nancy S. Seasholes.
Bay Village was one of the earliest landfill projects done in Boston, in the 1820s, and the original fill along this marshy edge of the high tide line of Back Bay was literally garbage and animal remains covered by sea mud. When Back Bay was filled in the 1860s, persistent flooding and sewage flow reversals became a serious problem in Bay Village. All the buildings on Jefferson, Melrose, Fayette and Church--streets immediately abutting the proposed portal site--were raised twelve feet, by hand, with fresh fill thrown underneath and with buildings then reset on their foundations. Since these houses had been built for laborers and craftsmen, the quality of construction was adequate but hardly robust. This trauma to the house foundations and the structural damage is evidenced by the near universality of houses with severely protruding main walls and “star braces” to keep main walls from buckling.
- Bay Village has uniquely bad soil, groundwater, and building conditions even by Boston standards. The Charles Street Modified Alignment proposed in the Notice of Project Change actually increases the degree of intrusion into this fragile area by more than 100% versus earlier proposed alignments, and shows a reckless disregard for environmental issues by the sponsoring agency. Further, proponents of this project have suggested that this alignment was developed in order to address the environmental concerns of Bay Village residents; nothing could be further from the truth, and we reject this claim as an outright fraud.
We note that none of the unique groundwater, groundwater flow, and soil characteristics of this particular alignment are specifically addressed in any previous analyses or public filings. Detailed analysis and further public review once that analysis is completed is a prerequisite for building in such a highly sensitive location, should such construction even be allowed.
While MBTA filings consistently refer to construction along “solid land”, we note that this wording purposefully obscures the fact that this alignment traces the original boundary between the higher solid ground of Boston Neck and the poor quality landfill which constitutes the bulk of Bay Village geographically. While tunnels have historically been the cause of substantial groundwater depletion in Boston, this location is uniquely poor in also simultaneously interfering with any groundwater replenishment. Since this alignment simultaneously drains and blocks recharge of groundwater, it is virtually guaranteed to lead to catastrophic damage to Bay Village’s historic homes.
Groundwater, Construction & Operating Damage to Structures, Funding Mechanisms:
- The MBTA should be ordered to perform a detailed analysis of current groundwater levels at regular intervals along the proposed alignment for a distance of not less than 500 yards on either side. In such places where no pre-existing observation wells exist, the MBTA should be required to install and monitor such wells so that a map of groundwater levels are determined prior to construction.
- A detailed analysis and determination of soil composition along the proposed alignment for a distance of not less than 500 yards on either side should be performed.
- On the basis of item 2, vibration and soil displacement analysis of all construction and operating activities for a distance of not less than 500 yards on either side should be performed, as well as projected impact on each structure along the proposed alignment, including best and worst case analysis.
- On the basis of items 1 and 2, a detailed groundwater flow map and analysis (rate, amount) should be performed, so that impacts to the groundwater table can be identified prior to construction.
- On the basis of items 1, 2, 3, a detailed mitigation and active groundwater remediation systems should be specified for a distance of not less than 500 yards on either side of the proposed alignment prior to construction and incorporated as a condition of certification. Cost estimates of all mitigation and remediation should be incorporated in any future filings.
- While MEPA has previously ordered the MBTA to conduct
a survey of all structures for a distance of two city
blocks on either side of the proposed alignment, we note
that given Boston’s unique layout, two city blocks
is not a consistent or meaningful distance for analysis.
Further, we note that the manner of survey has not been
specified and is open to unacceptable latitude which
would perforce miss many areas of likely damage.
6.1. The MBTA should instructed to have substantive, on-site inspection performed by a certified engineer (not by remote supervision) of all structures within 500 yards of either side of the proposed alignment, including detailed structure-by-structure inventory of foundation condition, bearing wall condition, bearing wall bulge from true, susceptibility to incidental or catastrophic damage, and specific suggested mitigation or remediation.
6.1.1. Given the high likelihood of structural damage over an extended period of time and the MBTA’s history of denial of culpability even in the most obvious situations, criteria and mechanisms for determination of consequential damage to structures over a multi-decade term should be defined and pre-funded. These mechanisms should be in addition to judicial relief, not a substitute. - Given the likelihood of limited Federal funding in
the event of cost overruns, the age of cost estimates
leading to a high likelihood of cost overruns, the
MBTA’s substantially impaired financial condition,
ample evidence of inability to perform simple maintenance
tasks adequately on existing structures, and
unwillingness to take action despite clear evidence of
catastrophic groundwater damage caused by Orange Line
tunnels in the vicinity of Cazenove and St. Charles
Streets, the sponsoring agency should be required to
identify specific funding mechanisms which will ensure
that mitigation and remediation ordered by MEPA are
performed before, during and after project completion.
Such mechanisms should include, but not be limited to:
7.1. Potential escrow provisions for monies to be segregated for such environmental work prior to construction;
7.2. Analysis of all outstanding indebtedness, including bond and other financing instrument covenants, which might impair or impede the MBTA’s ability to effect capital expenditures required for environmental work;
7.3. Analysis of existing legal or financial obligations between the Commonwealth and the MBTA which might impair or impede the MBTA’s ability to effect capital expenditures required for environmental work, as well as dependency on future legislative actions which might effect the MBTA’s ability to meet its obligations under MEPA requirements. -
Construction & Operating Impacts to Pedestrian, Vehicle Traffic Flows, Air Quality:
- We note that the Commonwealth and the MBTA have
previously affirmed a commitment to reducing the use of
diesel buses due to serious health concerns regarding
diesel particulate emissions;
8.1. We ask that the sponsoring agency be ordered to use either all electric or dual mode buses utilizing Compressed Natural Gas (CNG).
8.2. We ask that should such order not be made, the MBTA be required to file a separate notice of project change regarding its intent to use diesel buses on this project. - Detailed analysis of tunnel excavation and
construction methodology, including:
9.1. timeline showing street closures, roadway changes, and all traffic impacts during construction and operation; noise impact; and associated air quality impacts from construction and operation related roadway obstructions;
9.2. air quality assessments should be modeled at peak times, should be adjusted for anticipated vehicle use growth over the next twenty years, and should be modeled for weather conditions extremes (heat, humidity);
9.2.1. Study area should extend along Herald and Arlington Street from the intersection with Albany Street to the intersection with Beacon Street. Lane reversals and closures on a major north-south artery in central Boston will have severe traffic repercussions, which will extend well past the immediate project area;
9.2.2. Study area should extend along Tremont Street and Charles Street South from Berkeley Street to the intersection of Boylston Street. This passes across an area of major traffic congestion which will be substantially worsened by construction, permanent lane reversals and lane closures;
9.2.3. Study area should extend along Stuart and Kneeland Streets from Dartmouth Street to the intersection of Tremont Street. This heavily over-trafficked roadway serves as a principal exit from the Massachusetts Turnpike for the Back Bay and the Theater District, as well as a principal route for access to the Southeast Expressway and westbound access to the Massachusetts Turnpike. Construction and operating obstructions on major cross streets and intersections along this route will severely impact traffic flows;
9.2.4. Study area should extend along Boylston Street and Essex Street from Berkeley Street to the intersection with Atlantic Avenue due to severe traffic impacts along this route from open cut construction activities over a multi-year period;
9.2.5. Such studies should evaluate impacts on young children due to the proximity of the proposed portal to two public schools;
9.3. Relevant epidemiological records should be utilized in evaluating prevalence of pre-existing air quality induced medical conditions which will be worsened by construction and operation of this project;
9.4. All such studies should evaluate environmental racial justice of construction and operation of this project due to its siting through areas of minority and economically challenged households; - We note that several hundred buses per day will be
switching from electric to diesel operation at the mouth
of the proposed portal for this alignment near the
intersection of Charles Street South and Jefferson.
10.1. Air pollution impacts in the immediate surrounding residential areas, including Bay Village and Mass Pike Towers, with particular attention to diesel particulate emissions generated at engine startup and during idling in cold weather;
10.2. Such studies should evaluate impacts on young children due to the proximity of the proposed portal to two public schools;
10.3. Such studies should evaluate prevailing wind conditions and seasonal weather patterns;
10.4. Noise impacts of engine startup and idling in the immediate surrounding residential areas, including Bay Village and Mass Pike Towers, as well as immediately abutting public schools; - Pedestrian impacts should be identified for both
construction and operation phases.
11.1. The proposed portal and contra-flow lanes will effectively “wall off” several hundred residents of residents of Mass Pike Towers on all sides and will serve as a barrier for southerly and easterly pedestrian traffic from and to Bay Village.
11.2. Particular emphasis should be placed on impact to children attempting to attend both nearby schools abutting the proposed portal; -
Lack of Substantive Public Participation; Absence of Meaningful Alternatives Analysis:
- The MBTA has not had public hearings regarding the
mode of transport selected for this project. Mode of
transport is the single greatest determinant of long term
environmental impact.
12.1. The MBTA should be ordered to perform all analyses requested in sections 1 through 8.3.3 for the following alternatives:
12.1.1. A no-build alternative, which continues to utilize city streets. We note, as we have noted before, that the proposed transit time savings projected by this tunnel and portal are substantially less than would be provided by routine traffic enforcement on the current Silver Line route as is currently required, but not provided, by the MBTA.
12.1.1.1. The MBTA has advanced this project with the proposition that a one-seat ride” from Dudley Square to Logan Airport is desired by its ridership. We are aware of no such ridership community despite repeated investigation, and note that any project which lacks ridership or logic to its endpoints perforce maximizes environmental damage;
12.1.2. A no portal alternative. We note that the current portal and tunnel configuration enforces a hypocritical transportation apartheid, where minority transit ridership is routed through a portal not needed for their transportation needs in order to economically justify a tunnel deigned for the Seaport district users. Analysis on the substantially reduced theoretical ridership under this scenario is reflective of reality and must be studied;
12.1.3. A light rail alternative, evaluating and comparing such an alternative to the project as outlined in the Notice of Project Change. In addition, the following comparison should be performed for this alternative and compared with the project as described in the Notice of Project Change;
12.1.3.1. Maximum carrying capacity;
12.1.3.2. Tunnel cost, taking account of the substantially smaller tunnel and less stringent turning radius required for rail;
12.1.3.3. Ability to reuse existing rail tunnels. The MBTA has previously affirmed that such tunnels are unusable, without specifying reasons. Common sense dictates that tunnel rehabilitation, no matter how extensive, would be substantially cheaper than de novo construction and would have de minimis environmental impact. - Ridership Analysis
13.1. We note the existence of confusing or contradictory claims and absurd growth rates for projected ridership attributable to this project and note that such analyses is central to determination of environmental benefits and costs.
13.1.1. We request that the MBTA be ordered to provide fuller explanation of all underlying data, assumptions and calculations for ridership and that such analysis be compared with other relevant data (e.g., census projections, government or independent economic analyses).
13.1.1.1. This ridership analysis should be compared with recent ridership trends across the MBTA system;
13.1.1.2. This ridership data should be compared explicitly with growth projected for each MBTA line;
13.1.1.3. The number of buses required to be in simultaneous operation to meet projected ridership and comparisons with the aboveground routes, portal, and tunnel capacities. A cursory analysis suggests that such projected ridership will require buses at 60 second intervals along the entire route, a physical impossibility.
13.1.2. Further, we request that all such ridership estimates explicitly model expected effects of construction and operating budget impacts on likely system-wide fare increases, as well as the consequential impact of fare increases on ridership estimates for the Silver Line and the entire MBTA system. Systemic declines in usage would outweigh any purported benefits attributable to one project, and so such analysis is a prerequisite for understanding overall environmental impacts.
For over three decades, the Bay Village Neighborhood Association has worked to preserve and enhance the residential quality of life in and around the Bay Village neighborhood of Boston. The Association has approximately 250 current dues-paying members, who represent a majority of the households in Bay Village.
We appreciate the opportunity to comment on this Notice of Project Change and would be pleased to meet with EOEA officials to clarify any points of concern expressed above.
Sincerely,
Mark Slater
Cc: Governor M. Romney
Lt. Governor K. Healy
Secretary J. Cogliano
Secretary S. Pritchard
Speaker of the House S. DiMasi
Senate President R. Travaglini
Representative M. Walz
Senator D. Wilkerson
Mr. A. Michlewitz
Mayor T. Menino
Councilor J. Kelly
Councilor M. Flaherty
Councilor F. Arroyo
Director V. Gupta
Mr. D. Patrick