The MBTA Rider Oversight Committee strongly commends the progress EOT is making with regard to many of the remaining six SIP transit commitments but is dismayed at the continued disarray in Massachusetts transit project planning, financing and implementation. This disarray is exemplified by yet another significant schedule slip, recently suggested by Governor Patrick and EOT, for the Green Line Extension which is the single remaining SIP transit commitment that contains most of the combined environmental benefits.
Three of the six transit commitments discussed in the EOT status report are well underway. The Greenbush commuter rail restoration is expected to open on-time by December 31, 2007, completing the new suburban transit service commitments that have been included as Transportation Control Measures within the SIP. The Blue Line platform lengthening and modernization is progressing, despite construction difficulties at State and delayed car availability, with six-car train-sets expected to be operating by the revised deadline of December 31, 2008. The Fairmount Line improvement project has been expanded in the proposed SIP, has seen construction completed on two stations in 2007, and has received a significant portion of its required funding from this year’s Emergency Needs Bond Bill.
The funding required to complete the remainder of the Fairmount Line improvement project must be in the next state transportation bond bill. It is also important that EOT and the MBTA continue to work closely with the host community to ensure good service to existing and proposed land uses, with special attention given to those riders whose quality of life may be highly dependent upon the ease of use and efficiency of these new services. In dense neighborhoods, urban design and convenient pedestrian connections to the surrounding community are critical. Finally, given the large amount of nitrogen oxide and particulate emissions from accelerating diesel trains as they leave closely spaced urban stations, managing pollution along the Fairmount Line should be among the MBTA’s highest environmental priorities.
Two of the remaining six transit commitments – provision of an additional 1,000 transit adjacent parking spaces and design/preliminary engineering of the Red Line / Blue Line Connector â involve neither complex construction nor large capital outlays and are expected to both be completed by their proposed SIP deadline of December 31, 2011. In accordance with prior SIP Transportation Control Measures, the MBTA and EOT have put in place many park and ride facilities. Their ability to provide the additional 1,000 spaces is not questioned. We hope these additional spaces will be provided in ways that are sensitive to local preferences and also work with transit-oriented development when the context is appropriate. The Red / Blue Connector work should anticipate and facilitate future rider increases from the Blue Line extension to Lynn.
The sixth and largest remaining proposed SIP transit commitment â the Green Line Extension to Somerville and Medford â is unfortunately not currently on track to be completed as proposed by December 31, 2014. This single project contains a majority of the environmental benefits to be derived from all of the remaining SIP transit commitments. The state’s failure to stay on schedule is especially disappointing for three reasons:
1. The state’s announced project delay precedes EPA’s approval of the 2014 deadline.
2. There is overwhelming local support and a large need for the Green Line Extension.
3. The project directly relates to pollution from both I93 and MBTA diesel commuter rail.
Through the Federal Transportation Conformity Regulations and State Implementation Plans, the US Clean Air Act as amended requires that states and Metropolitan Planning Organizations give priority to Transportation Control Measures, such as the SIP transit commitments, until those states are in attainment with National Ambient Air Quality Standards. Massachusetts is the largest state in the US whose full area has been in violation of federal ozone standards since implementation of the Clean Air Act of 1970.
Additionally, many of the Boston inner core communities, including Somerville, have been in maintenance status for federal carbon monoxide violations. Most troubling of all, EPA’s recent conservative review of the health effects of fine particulate matter suggests that reducing half of the Boston region’s fine particulate matter would save 600 lives per year. The most credible current aerosol science and health effects studies suggest that a large portion of all US environmental health damages stem from the close proximity of regional transportation facilities and dense residential populations burdened by fresh mobile emissions. The last five US OMB Reports to Congress on the Benefits and Costs of Federal Regulations state that over 85% of all potential net regulatory benefits (environmental and other) reside in prevention of premature cardiopulmonary mortality caused by exposure to fine particles, if combustion emissions can be reduced.
The current Massachusetts SIP requires completion of the Green Line Extension by December 31, 2011. Because neither the pending Boston MPO Transportation Improvement Program nor the State TIP give priority to timely funding and completion of the project by 2011, they do not comply with the Transportation Conformity Regulations. The current SIP, however, does not include the Union Square spur which is an additional benefit to Somerville residents in the revised SIP. The proposed Massachusetts SIP transit commitment revisions contain a delayed Green Line Extension deadline of December 31, 2014. Unfortunately, Massachusetts has proposed further delay in the Green Line Extension, with tentatively suggested completion in 2016, even before EPA has finished processing the 2014 deadline request.
The reason given for this troubling additional schedule slip is that it is smarter to use as much Federal funding as possible for large transit projects than to rely entirely on state funding, as previously planned. However, there is no assurance of succeeding in attracting New Starts funding for the Green Line Extension and success would likely result in far less chance of using New Starts funding for other, potentially larger, urban transit projects in the Boston core. Since Massachusetts EOT and the MBTA have long understood the project delays that may be associated with applications for Federal New Starts program funding, they have also known that such applications would require an earlier start on meeting project deadlines.
The residents, businesses and political leaders of Somerville overwhelmingly support the Green Line Extension as proposed in the revised SIP with a 2014 deadline. Many in Medford hold the same position despite some concerns there with project terminus and execution. Pro-Green Line supporters have made up more than 75% of all participants and commenters in the last federal certification review of the Boston MPO and in the state’s 2004 and 2005 SIP transit commitments review. A majority of the Traffic Analysis Zones (land areas defined by the MPO staff) in Somerville and Medford meet environmental justice criteria, including over two thirds of the TAZes in Somerville. Somerville has been the densest community in Massachusetts for over a century, has the highest ratio of multi-family to single family properties, has the second highest density of immigrants (after Chelsea), and has 5,000 people per square mile who live in households without access to a car (Massachusetts Municipal Spreadsheets and US Census 2000). These citizens deserve clean convenient transit sooner rather than later. Besides benefits to local residents, the Green Line Extension and an Orange Line T-stop at Assembly Square (a much smaller project for which funding is available) could support between 15 and 25 million square feet of university related office and research space in eastern Somerville alone. That transit-oriented commercial space, in turn, could directly support 50,000 to 80,000 new jobs for the region, not counting support services.
Finally, the public health damages accrued to the citizens of Somerville and Medford have been large. Interstate 93 passes through both communities and all of the northern MBTA diesel commuter rails pass through Somerville, which ironically hosts the Boston Engine Terminal even though no commuter rails stop in the city to pick up or let off passengers. Due to interstate and regional arterial highways which pass through, Somerville is the only municipality in Massachusetts which hosts over 200,000 vehicle miles traveled per day per square mile (Boston MPO TAZ level data, Travel Demand Model for 2000). And no other Massachusetts community comes close to hosting 15,000 diesel rail trips per square mile per year (MBTA commuter rail schedules, land area from Municipal Spreadsheets).
Somerville residents smoke less than Massachusetts’ state average (Cambridge Health Alliance 2002 report). Yet from 1989 through 2003 Somerville suffered 292 excess lung cancer and heart attack deaths – using actual mortality counts, comparing Somerville and Massachusetts age-adjusted mortality rates (Massachusetts Department of Public Health, MassCHIP database version 3.00 revision 3.19 accessed by Wig Zamore on August 31, 2007 using International Classification of Diseases 9 and 10). Over the same 15 year period, Medford had 156 excess lung cancer and heart attack mortalities.
The MBTA Rider Oversight Committee urges EOT and DEP to re-double their efforts to bring all the SIP transit commitments to full fruition as soon as possible, and to deliver a fully functional Green Line Extension to the communities of Somerville and Medford by December 31, 2014.
Sincerely,
Eric Bourassa & Vicki Haddix
Co-Chairs
MBTA Rider Oversight Committee