Dear Secretary Grabauskas and Commissioner Golledge,
The actress Mae West used to say âan ounce of performance is worth pounds of promises,â and those words could not be truer as I write today to comment on the Commonwealth’s reconsideration of the transit commitment to extend the Green Line from Lechmere to the Medford Hills.
In 1990, the Commonwealth made a simple, straightforward promise to its residents and taxpayers for better transportation services and cleaner air in neighborhoods long underserved. More than a decade has passed since the Executive Office of Transportation (EOT) first agreed to fulfill a host of transit commitments as required by the state’s non-attainment under the federal Clean Air Act and to mitigate for the inconvenience and cost of the Central Artery/Tunnel Project.
The question before you today is: will the state’s transportation agencies abandon the most promising of those transit commitments — the Green Line extension from Lechmere through the densely populated communities of Cambridge, Somerville and Medford? An ounce performance is all the people who were promised the Green Line extension are asking for.
The Green Line extension through Somerville will bring relief to commuters and residents in one of the densest urban regions of Massachusetts. It will undoubtedly generate millions of dollars in economic development to low-income and minority communities. And it will provide a solution to clogged and dirty air. According to the 1990 State Implementation Plan, substitute projects for the commitments âmust provide great improvement in air quality in the area where the required project was to have implemented.â There is simply no other transit project that will deliver the air quality benefits the Green Line extension will deliver to the hard hit communities along I-93.
But the commitments are not just a promise about clean air; they are a legal obligation upheld by state and federal law. The legal precedent for the transit commitments agreed to in 310 CMR 7.36 has been upheld by over 10 years of litigation and confirmed by the 2000 Administrative Consent Order entered into by the Executive Office of Transportation and Department of Environmental Protection.
The Commonwealth’s reconsideration process for Green Line extension is inherently illegitimate and legally unfounded because:
- The project is a longstanding legal commitment: As mentioned previously, the commitments are a longstanding legal commitment and to back out now with NO serious effort to honor them is outrageous. The first stage of the Green Line extension planning began just this summer and, to date, no additional planning resources have been allocated by either EOT or the MBTA. The mandate is clear: the Green Line extension commitment must be completed by 2011.
- It’s also about better transportation options: The commitments were promised as part of an overhaul of the state’s urban transportation services to traditionally underserved communities, in exchange for the cost, pollution and traffic of the Big Dig. That means any reconsideration must include quality of service, permanency, and equity of service for the affected communities.
- EOT’s air quality analysis fundamentally flawed: Both Secretary Fred Salvucci and the Conservation Law Foundation agree that EOT’s air quality analysis is fundamentally flawed because it fails to account for long-term improvements to air quality that will result from transit-oriented development. The Green Line extension means fewer cars on the streets and a net benefit for the densest community in Massachusetts long underserved by transportation services.
Additionally, you must not overlook the enormous smart growth and economic development impact the Green Line extension will have on the communities the rail line will travel through. The project will undoubtedly result in significant economic development opportunities along the path of the train as it travels through the dense, environmental justice neighborhoods of Cambridge, Somerville and Medford. It will be an excellent opportunity for the Office of Commonwealth Development to put into practice its previously stated commitment to transit oriented development.
Finally, for the following reasons I am extremely concerned that the draft policy will fail to meet the standard for an open and honest public process:
- The reconsideration plan includes no public meetings scheduled in any of the affected communities. At the very least, the plan should explicitly stipulate at least one meeting in each community that will be served by the transit commitments.
- The plan includes only one hearing per stage of the process and no explicit agreement to rotate hearing locations to ensure everyone who would like to testify may do so.
- The process for submitting testimony includes no electronic method of receiving testimony. In the electronic age of computers and internet, it is essential that an email address be provided for the public to submit comment.
- The first public meeting was held in the middle of the day when many people are at work and unable to attend. Additional meetings should be scheduled in the evening when the majority of residents can attend.
It is up to the Governor and EOT to fulfill the legal commitment to complete all of the Central Artery/Tunnel and clean air mitigation legal commitments. Failing to complete the Green Line extension commitment could lead to expensive legal challenges and possible loss of federal transportation dollars. It is time that the state’s transportation agencies begin to fulfill their promise to the people of Cambridge, Somerville, and Medford by completing the Green Line extension. I am
Sincerely yours,
Jarrett T. Barrios