PUBLIC
COMMENTS ON THE
DRAFT
ENVIRONMENTAL IMPACT REVIEW
GREEN
LINE EXTENSION PROJECT
EEA
NUMBER #13886
SUBMITTED BY
Green Line
Advisory Group for Medford (GLAM)
c/o 25 Bussell Road
Medford, Mass.
02155
SUBMITTED TO
Secretary
Ian Bowles
Executive
Office of Energy and Environmental Affairs
MEPA Office,
Attn: Holly Johnson, MEPA Analyst
EEA Number
#13886
100
Cambridge Street
Suite 900
Boston, Mass.
02114
With copies
to:
Katherine Fichter
Executive
Office of Transportation
Office of
Transportation Planning
Room 4150
Ten Park Plaza
Boston, Mass.
02116
and
The Honorable
Mayor Michael McGlynn
And
The Medford City Council
85
George P. Hassett Drive
Medford, Mass.
02155
December 30, 2009
Overview:
The Green Line
Advisory Group for Medford, better known in the City of Medford
as GLAM, is a grassroots group consisting of members of the disability and environmental justice community along with abutters
and other concerned citizens whose mission is the education of the Medford
public about the proposed Green Line project. We are providing public comments
within the time frame allowed on the DEIR on the EEA # 13886 regarding the proposed Green Line Extension.
When speaking about
the proposed Green Line Extension, the Commonwealth of Massachusetts and the special interest advocacy groups need to get real.
The DEIR submitted by the Executive Office of Transportation (EOT- now known as MassDOT) to the Executive Office of
Energy and Environmental Affairs (EOEEA) from our perspective is riddled with abstract theory.
We will continue to call MassDOT EOT for the purpose of clarification as it was known during the process of this period.
The DEIR makes
ambiguous statements with vague conclusions versus presenting practical application on the reality of the true impacts of
this project that are both short term and far reaching. Some of these ambiguous
statements and conclusions often contradict themselves in other parts of the DEIR. While
stating they are looking at other maintenance sites, they recommend the Yard Eight location as their recommendation. While EOT states they don’t plan a 300 car parking garage at Route 16 MVP, they
encourage a garage at Route 16 MVP. The DEIR is like an open ended environmental
contract whereas citizens’ voices and concerns are not being heard.
The DEIR is a document
based more in political expediency and public relations hype by the EOT and special interest advocacy groups than based in
the stark realities of our times. As our environmental advisor, Dr. Marlene Warner, points out to us in her review of EOT’s past studies, the use of numbers, lots of numbers within EOT studies have a
“. . . striking absence of meaning, which is statistics applied to those numbers in a relevant way . . . “The
public should expect to see statistics that represent processed data with degrees of probable outcomes before planning or
speculating. The question, is this project the best the state can do for its
citizens? We think not, which is why we will be recommending that the state break
this project down into further phases with additional study needed.
This transit project’s
vision is limited in imagination with proposals, regulations and environmental standards that will likely be outdated by the
time this project is even ready for construction. On November 17, 2009 it was announced that President Barack Obama is pushing to impact federal safety controls
on state transit. (Metro Newspaper, “Will Obama set riders at ease?”) What does this mean to backlogged maintenance issues that the MBTA is currently experiencing?
As another example,
The Mount Sinai School of Medicine recently announced in its November 2009 newsletter Focus on Healthy
Aging in its News Briefs column:
“Carbon
monoxide in air pollution, even at levels well below national standards, is associated with an increased risk of emergency
hospitalizations for cardiovascular disease in older adults, according to a study published September 15 in Circulation .
. . Currently the EPA is evaluating the scientific evidence on the link between carbon monoxide and health to determine whether
the health-based standard should be modified.”
There is mounting
research evidence we can site concerning the negative impact of diesel particulates on health.
There have been numerous public comments requesting a health study to determine the impact of moving diesel commuter
trains closer to local residential homes. This is especially true when pinpointing
the impact on the disability and environmental justice populations living in the HUD elderly housing program known as Walkling Court in Medford. EOEEA will find no such
study in the DEIR. In fact, we have written responses from EOT playing the coy
game that they are only responsible for the proposed Green Line Extension, not the impact of the commuter rail. This is like a bank robber telling you they are only responsible for the intent of stealing money from
the bank while any collateral damage is not their responsibility. Let’
get real.
The proposed Green
Line extension project is not based in the financial realities of today. Day
after day we are confronted with news articles and reports concerning the MBTA’s high operating deficit, public safety
issues that put the public at risk due to deferred maintenance, compounded by mounting debt service. Despite these issues, EOT is recommending that the MBTA take on expansion of its operation and maintenance
by extending the proposed Green Line. This expansion does not fly in the
face of fundamental financial common sense.
In an August 16, 2009 editorial called “On the slow train to financial reality”
even the Boston Globe speaks to the need for restraint in expanding projects that further burden the MBTA under its current
weight of issues. The Globe rightfully asks the question about the proposed Green
Line, “. . . Are there cheaper ways to achieve the same transportation and environmental goals?” As we know, the Commonwealth is allowed under the federally approved State Implementation Plan to propose
substitutions that provide equal or better environmental benefits. In speaking
about the proposed Green Line Extension and financial realities, the Globe states in the same editorial “. . . that
project must be scrutinized more closely for affordability.” We believe
that the EOT should add within the DEIR an alternative choice that addresses a substitution for the proposed Green Line that
would address financial practicalities while achieving the same transportation and environmental goals.
In the same train
of thought, the November 2009 MBTA report commissioned by Governor Deval Patrick on a review of the MBTA’s conditions
recommends, “It makes little sense to continue expanding the system when the MBTA cannot maintain the existing one. Slow expansion until the safety and maintenance priorities can be addressed.”
As many citizens
recently have learned through unfortunate circumstances, you cannot continue to pile up debt or defer debt you cannot afford. At some point you have to pay the piper so to speak.
There are negative consequences to this lack of common sense or delusional approach by the state, especially when we
are putting the transit public in unsafe and at risk detriment. This public safety
issue is a concrete issue as many learned who rode the Red Line a few weeks ago.
In the Boston Globe
on Saturday, November
14, 2009, on page A6 in an article entitled “Obama
pushes domestic spending cuts” this article articulates the fact that the Obama administration is shifting gears to
address mounting debt by freezing or reducing domestic spending in the upcoming federal budget. This action is being taken in the face of mounting public anxiety over growing deficits that have become
both an economic and political liability.
Two days before
in the Boston Globe on the opinion page in the article, “Red ink is staining more than the MBTA,” a public policy
and advocacy firm points out that the Commonwealth of Massachusetts isn’t much better off than the MBTA when it comes
to incurring debt. This year taxpayers will be paying $1.8 billion in debt service
while needed social services and other public services endure the brunt of cuts. The
article points out the need for citizens to make the hard choices for what we want to pay.
Cut needed services or pay higher taxes?
EOT has decided
within the DEIR to impose that choice for Medford by recommending a phase II alternative that eliminates close to $300k
in assessed property tax value according to the assessor records of Medford
by taking down commercial property between North Street and Route
16 MVP. GLAM contests EOT’s figures in the DEIR that are based on estimates
as opposed to the actual numbers at the assessor’s office. This phase II adds $160 million in construction costs to this project and would
lose Medford revenue that we estimate is equivalent to 9-10 police, fire fighter or teachers jobs lost. How did EOT arrive at that decision for Medford? Why wasn’t the city of Medford involved in that decision?
What is their answer
to that tax loss? The hypothetical potential of urban development, assuming
that Medford the lowest density of the three cities wants to become a high-density
location. The oxymoron of the proposed Green Line extension, developing transit
to deal with high-density impacts while creating more high density impacts.
As the Globe opinion
columns above so aptly states and we quote, “Of course, hard choices run directly counter to the political process. Few leaders get elected by telling voters they can’t have what they want . .
. The result is a culture of immediate gratification – photo opportunities and ribbon cuttings, while debt piles up
and maintenance is deferred.”
We believe that
it is time that the State Representatives and State Senators, along with EOT officials who have pushed the Green Line project,
get out from under the above- mentioned political hackery trend and get real. Here
are facts they need to confront:
No money for this project for several years: More objective sources at the State House inform us that funding for the first phase of
this project will not be available until the year 2016 due to recession conditions.
Before we move to a new endeavor, we must address a plan for the financial and public safety issues at the MBTA. It is projected in the recent MBTA D’Alessandro report that by 2014 the MBTA
without additional sales tax revenue will be at a $1.19 billion cumulative deficit.
We must deal head on with this problem and make hard decisions before we set the proposed Green Line Extension in play. Otherwise we doom the MBTA to failure in being able to afford or maintain an expansion
project as currently proposed by the EOT.
Therefore there
is time to ensure that this project’s environmental and socioeconomic benefits are articulated in a more concrete fashion
that proves out hypotheticals now proposed and addresses residents’ and community concerns. Federal funding for the Route 16 MVP phase of this project may not occur until 2020, if at all, due to
scarcity of available funds. By that time, there may be other progressive techniques
available that would make this current plan moot.
This means the
state needs to bite the bullet and be honest with special interest groups, such as the Conservation Law Foundation (CLF),
that this project has to be scaled down and slowed down to allow the MBTA to address critical public safety issues. We all ready know of civil rights violations within seventeen years of this process where there has been
no participation by the disability or environmental justice community from Medford. This has been documented in a civil rights complaint/report to the FTA. We are all ready aware that the FTA and the federal environmental protection agency are studying particulates
to likely recommend a change to standards since there is a great deal of evidence regarding the negative health effects of
these particulates. (See mitigation comments for reference to these studies in this paper.)
And if the CLF refuses to listen, the state needs to take their case back into the courts based upon extraordinary
financial burden.
Immediate gratification without benefit of studies:
Activists practice doctrine that emphasizes direct action in support or in opposition to one side of a controversial issue. Activists do not always mirror the desire of the grassroots community. If their activism is not based in heuristic research or what also is known as political
ethnographic inquiry in understanding human conditions, they can create a polarization and anti-dialogical action within a
community as has been seen in the case of the proposed Green Line Extension process with groups such as STEP and MGNA.
As the progressive
educationalist, Paulo Freire, has stated in his book, “The Pedagogy of the Oppressed”, the one last fundamental
characteristic of anti-dialogical action is cultural invasion of a community. Activists,
not based in authentic diverse grassroots understanding, become cultural invaders who create divisive tactics and manipulation
for their own special interest and gratification. In this case pushing the theories
of material gain based in highest and best use, the promise of increased property values, and high density urban development
that can open communities to speculation and destabilization resulting in moving moderate to low income populations out. And because of their own special interest, advocates who use anti-dialogical action
most times do not represent the will of their community. Activist groups, not
based in the grassroots, often disrespect the potential of the community in which they invade and impose their own view upon
a community, inhibiting the ability to bring consensus on an issue within the community.
We believe this happened in the Green Line process in Medford. This cultural process is what educationalist Paulo Freire is articulating in his book.
We believe that
EOT and the State Representative who represents the district impacted by the Green Line in Medford allowed special interest
advocacy groups such as STEP and MGNA to have undue lobbying influence over the proposed Green Line process by the unlimited
access they were provided. This process was supported by the unusual tactic of
the CLF, a legal body that knew that the disability community was not being represented in this project. This tactic could be construed as doing an end run around the Americans for Disabilities Act and we believe
should be investigated as civil rights violations as we point out in our FTA case.
GLAM, a disability
and environmental justice group, came together because of these issues with the belief these special interest groups misrepresented
the diversity of our community. The EOT process has now put local neighborhoods
such as Brickbottom in Somerville and Medford businesses and residents
abutting this project in environmental harms way. This process became based in
advocacy groups’ own naiveté and elitist attitudes in understanding how citizens participation and the public choice
theory works versus the mechanism theory in building community consensus. Therefore
there became a collaborative process between the legislator and the special interest groups that drove the process to become
less transparent and less objective resulting in the individual citizen’s voice being shut out.
To show their arrogance
with only 10% of studies being done, the CLF came out in favor of the project going to Route 16 MVP. When these 10% of studies came out and the numbers of TAZs were not providing the ridership numbers to
justify this terminus, the CLF came out in support of unscientific literature that said 10,000 people would be riding at Route
16 MVP just because they lived within the surrounding area. Not only did EOT’s
modeling not bear this number out, but we brought studies forward from the CTPS that showed this theory was irresponsible
and ridiculous in comparison to practical application which through traffic studies showed commuters driving to their jobs
in the suburbs as opposed to downtown Boston.
When special interest
groups like MGNA started to present station designs without evidence of disability access and then promoted them with EOT,
we in GLAM felt this symbiotic relationship was going too far. In other
words none of the stations were designed in a fashion that allowed full accessibility or was the disability community allowed
to participate in those designs.
As Katherine Fichter,
planner for EOT, stated in a recent Tufts Daily newspaper article on the proposed Green Line, the cost of the Green Line expansion
increased because EOT was not fully complying with the ADA. GLAM had already brought these compliance issues out at an EOT public advisory meeting based upon information
we received from sources at the MBTA. Our source informed GLAM that EOT was trying
to cut the costs of this project by reducing ADA compliance since EOT had originally put forth bogus project cost numbers
in their EENF. EOT did not feel the public would accept the full cost of this
project. EOT denied our claim at the time.
But the proof is in the pudding.
The current design
for stations in the DEIR, which GLAM helped advocate for the disability community, shows how inept the special interest groups
were in their designs. But the station design process also proved a pattern of
excluding authentic citizen participation. This was the same pattern GLAM encountered
regarding shared community paths. We do appreciate that EOT actually has mentioned
in the DEIR the ADA enhancements to community paths that are required by the FTA in the design
process. These were the guidelines we provided to them at the Community Path
workshops. We do expect MassDOT (EOT) to continue on designing stations. But we must wonder if the disability and environmental justice community will be left
out of these designs as well, especially those who live in Medford. The DEIR process should recognize that a spokesperson for EOT stated in response to public comments on
the SIP annual report that the disability community would have to wait decades for their rights. And the disability community felt that was the attitude EOT had.
The DEIR process owes a responsibility to the disability community to ensure that the federal government is informed
if the disabled and environmental justice community rights are violated.
As pointed out
in the report called “Power and Interest Groups in City Politics”, a report written by Tufts researchers for the
Rappaport Institute for Greater Boston at Harvard University, the interests of the disability and environmental justice communities
remain seriously under represented when it comes to government and that special interest groups tend to represent the more
affluent and highly educated. Therefore, when EOT points out the negative impacts
to the environmental justice population in Union Square area or leaves
out mention of the mitigation impact to Walkling Court where the
elderly disability and environmental populations reside, GLAM knows that these populations were left out of the EOT process. This claim is based upon our own experiences and observations. Hence, GLAM has filed a civil rights report/complaint to the FTA regarding what we saw as civil rights
violations within the process.
Based upon the
undue influence of special interests, the State Representative for this district took an advocacy position to support the
proposed Green Line extension based upon theory without benefit of any studies. A
supposedly, highly educated person who could not wait for studies before taking an advocacy position that did not necessarily
represent the entire community. Therefore he now stands stark naked intellectually
before the Medford community having advocated a project that incorporates residential and commercial land taking, the code
name for eminent domain by the state, with the resulting impact of tax dollars projected to be lost to the city of Medford’s
tax base. And as we have recently seen in the Rivers Edge project, those
faced with land acquisition are often low-balled in the process and have to go to court to fight for the rightful value of
their property.
As businessman
David D’Alessandro wrote in the MBTA review, plans and theories by state government and legislators are often“.
. . well intentioned, but founded upon a combination of optimistic, unrealistic and untested assumptions.”
Hence we have a
pattern with the proposed Green Line project. Promoted by the same state legislator,
who listened to special interests that said there would be no land taking and who promoted station designs that did not meet
the Americans with Disabilities Act requirements. Even now claims of better
air quality are based in regional measurements while the DEIR admits on page 6-8 in the detail assessment of this project
that we could see localized decreases or increases in carbon monoxide and particulate matter in our area. Hence, the fallacy
of theory meets reality.
The DEIR is a contradiction
in terms and we would conclude it is like buying a pig in a poke. EOT leaves open doors for inference of further mitigation
issues upon the Medford community than currently articulated in the DEIR. Thus the DEIR should not become the final environmental report until these issues are further studied and
quantified.
The DEIR should
be turned down by MEPA until the FTA makes a decision on the alleged discrimination in the process or mediation takes place. If not, MEPA opens itself up to charges of discrimination on its own part by
knowing that a complaint is there and that is being judicated by the FTA and no decision has been reached by the FTA at this
writing.
The DEIR leaves
our small business community vulnerable with unrealistic statements made by state bureaucrats who do not know how business
runs. In fact, as one of our Executive Committee members pointed out, the
EOT appears to see “Medford as being the environmental toilet for Winchester, Arlington and Somerville.”
Therefore, we believe
this project requires further studies in specific areas before this project can be environmentally approved in a final FEIR. We believe for financial considerations this project should be broken down in to further
phases. Phase I should be the build to Lowell Street with the spur to Union Square. Phase II should include the maintenance facility center. Phase
III should be Lowell Street to Ball Square. In each of these phases the project should be analyzed and assessed for its actual impact upon parking,
land acquisition, and socioeconomic impact before the next phase begins. In essence,
theories need to be proved and we have the opportunity at this juncture to require a test of these hypothetical theories as
we see impact unfold.
Doing this project
in phases is not unusual and is similar to what occurred in the Orange Line build out process.
As people became accustomed to living with this project, it became more and more acceptable to extend deeper into neighborhoods. The reason we would recommend stopping at Ball Square, where intended in the original SIP plan, is a financial one.
We have read reports
by ReConnecting America, who documented for the city of Somerville the dramatic changing
socio-economic demographics of Porter and Davis Squares after initiating the operation of the Red Line. Their report documents that middle to low income people were pushed out of these areas. The phasing in of the Green Line project will educate us if successful housing strategies actually can
be implemented to prevent further displacement and pushing out of populations with this proposed expansion.
It should be assessed
if the environmental justice and disability community actually gain jobs from this transit project, not only in downtown Boston but also within the 128 belt. We cannot just claim in theory that a
project will provide jobs, we need to see concrete evidence in how it will create jobs.
It is a fact that the working disability community approaches over 20% in unemployment levels within its community. And there is no doubt for those who study this community that it is a community that
wants to work.
Yet EOT in its
opaque claim shows no tangible evidence by the Commonwealth of Massachusetts to assist this community in job seeking within this project’s intent. There is no
reference to labor research pertaining to this community to prove EOT’s claims that this project benefits both the environmental
justice and disability community in finding jobs. What type of jobs and where? Yet, the Dept. of Labor’s Office of Disability Employment Policy has issued
recent research reports in how to advance employment for people with disabilities. But
without groups like GLAM advancing these types of reports and advocating their use within project studies, they never see
the light of day.
As it has been
stated in the Rappaporte Institute’s report, the jobs are moving out to the suburbs while Boston is being dominated by university expansion. A CTPS traffic study on
the Alewife Brook Parkway correlates this information when it also determined the majority of traffic
to be moving to the suburbs as opposed to downtown Boston.
The Rapporte Institute’s
report has all ready stated that the jobs downtown will be for educationalist, which brings us to the point of Tufts University
and its tentacles within the community. Though Tufts has gotten a free hand to
develop in Somerville, it has had a great resistance in Medford. MGNA, a Tufts favored group, has stated many times publicly that bike paths and community
walk ways will benefit Tufts University students and is the way to go for station access.
For financial reasons we may want to agree with them and give them the ability to walk and take bicycles by stopping
at Ball Square, thereby, saving the Commonwealth millions of dollars of mitigation, particularly in rehabbing Tufts’
buildings. It is obvious Tufts own shuttle transportation costs will be reduced
when and if the proposed Green Line extends to Ball Square or College Avenue. We suggest that if Tufts wants the
proposed Green Line Extension built to College
Ave than the state should do as
Reno, Nevada did with their transit project and require those who benefit to contribute
a large donation to this project for financial reasons.
DEIR/Mitigation Review:
Our DEIR/mitigation
comments will focus on what we believe to be significant issues. This does not
mean that GLAM does not have other concerns with the DEIR report that should be addressed.
Land Taking in Medford
GLAM stated from
the beginning of the EOT process that our public position is that we are against any kind of land taking. We believe that property rights for both abutters and small businesses are paramount especially in an area
where affordable housing and jobs for working people are essential in sustaining socioeconomic diversity. Property rights should not outweigh property benefits.
In the current
DEIR, EOT has identified major and minor land taking in Medford and the loss of jobs
in Medford due to this land taking. With
unemployment in Massachusetts over 9%, EOT has cavalierly stated that the loss of jobs they estimate
in Medford is insignificant. Let’s
step out from under the public relations hype and step into reality. EOT states “. . . the jobs at stake represent at
most a minor economic impact.” With food pantries at capacity in Medford, foreclosures still occurring and unemployment in the country at a 26-year high and expected to climb, any job loss
is a significant loss and a significant socioeconomic impact to our community. We
are offended by the Commonwealth’s disconnect to the realities that their citizens face.
EOT makes conclusive,
undocumented statements that “Many of the jobs displaced would likely be relocated or replaced within the affected cities.” (Executive Summary, page ES-33) They
go on to state that there is an inherent economic advantage to having the Green Line close to Tufts University inferring that
Tufts University would hire these lost job positions. Is Tufts University who lost 25% of its endowment over the last year guaranteeing they are
picking up these lost jobs in Medford? If so, let’s get
that in writing. How does EOT come to the following conclusion? “Therefore, many of the jobs affected – particularly the office positions displaced in Medford – would not actually be eliminated but only relocated locally.”
There is no concrete evidence to this statement only assumption.
We actually contest
the estimated 224 job loss number listed for Medford and believe it to
be much higher than EOT is indicating. The Cummings Property representative at
the public hearing in March 2009 at the Brooks School in Medford mentioned at least
700 jobs in just the 200 Boston
Avenue building. This also does not take into account anticipation of impact on job loss due to traffic mitigation proposals
EOT has for the Medford Hillside businesses. They plan to eliminate parking spaces
by reducing current parking inventory and turning it into turning lanes at the intersection of Winthrop St. and Boston
Ave. This removal of parking spaces impacts businesses that depend not only upon walk in business but drive
up business. And who can anticipate the number of businesses that may go out
of business when construction of this project impacts customer’s ability to access local business? There has been no articulation of how EOT plans to address these economic issues in the construction
phase.
In fact, the proposed
land taking in Medford especially of the Elizabeth
Grady Building and the 200 Cummings Property building actually stymie economic development
in our community. Recently Mayor McGlynn negotiated the addition of an Italian
bioscience firm at the 200 Cummings property location. This firm is gearing up
to bring jobs and revenue to our community. Why would Medford want to jeopardize this expansion opportunity for speculative theories from EOT?
The property tax
values listed on page 5-16 of the detail DEIR assessment also appear to be understated.
In visiting the Medford assessor’s office this summer, GLAM representatives found the 200 Boston Avenue building
to be actually worth $265,000 in property tax value and not the $122,000 that EOT is claiming based upon their estimates. This discrepancy makes EOT’s numbers very suspect for other properties listed
such as the Elizabeth Grady building.
We also believe
based upon the maps provided in the DEIR that not all land acquisition has been identified.
For example, the project juts into property at the Winthrop Street bridge
headed down the hill toward George
Street. Are we to assume they will not be some land acquisition at this bridge reconstruction area? Also, the 196 Boston Avenue property
is sited with land acquisition and is not mentioned on the list even though EOT maps show land acquisition graphs cutting
off portions of this property for the drop off area.
Piggot Road is targeted
with noise, vibration and land acquisition. The land acquisition grid actually
shows a house close to the track being severely impacted by land acquisition right up to its back door. EOT on the other hand expects us to believe that this is not an impact.
The quality of life for this particular residential street is so severely impacted that it makes living within this
street intolerable. As health professionals understand, destroying a neighborhood’s
culture, restricting its green and open space and abruptly invading its private space has resulting impacts to mental and
emotional health as Dr. Marlene Warner has pointed out to us a scientist.
We anticipate that
if this project goes to Route 16 that these residents will be targeted by speculators who will take advantage of the situation
and low-ball the real estate values. We believe this situation will also
occur for those homes that will be isolated by a Route 16 station as they will be surrounded by the MBTA and the constant
in and out of drop off, bus traffic and poor maintenance of surrounding MBTA property as seen in the maintenance today.
For these mitigation
reasons alone, GLAM cannot support this transit project beyond College and Boston Avenue. We in fact would encourage the city of Medford to deny all permitting beyond this area.
It is clear to
GLAM in reviewing this DEIR and in contacting abutters mentioned in land acquisition that they have not all been notified
by EOT of this project despite EOT’s contentions to the contrary.
Transit impact on abutters by moving commuter rail closer to homes
EOT has proposed
in the DEIR moving the commuter rail closer to abutters’ properties without mitigation of the diesel pollution that
currently exists. Abutters all ready experience environmental pollution from
diesel particles on their homes, cars and land. By moving the commuter rail closer
to their homes, this problem will only exasperate these environmental issues.
GLAM and abutters have called several times for a health study on the affect of diesel particulates on this area and
particularly in the area of the Walkling
Court elderly HUD housing program
where there is a vulnerable population of disability and environmental justice community.
We base our request
upon considerations that other environmentalist groups were projecting, in which later a California Environmental Protection
Air Resource Board study of December 2008 verified their findings. That environmental
study has found diesel particulate matter contributes to premature death, lung cancer and increased respiratory and cardiovascular
hospitalizations. The study results point out that those most vulnerable
are children whose lungs are still developing and the elderly who may have other serious health problems. We believe that the Walkling
Court housing program fits into
the latter population. These conclusions correlate with a recent study done in
New York City where similar health impacts were found upon those living near subway
stops, bus depots and areas of traffic congestion. We requested health studies
such as this prior to these findings and continue to request health studies to the date of this report with no studies being
done.
EOT has not met
our request to separate out diesel particulate matter impacts from ambient particulate matter pollution studies despite this
recommendation by the California EPA Air Resource Board and supported by other environmental scientists. Nor have they met our request for health studies upon the Route 16 MVP area. Our environmental advisor, Dr. Marlene Warner, states diesel exhaust does not equal auto exhaust. Diesel effects must be separated out in air quality studies. She also states it is essential to locate or create a cancer incidence and type survey for this particular
area of Medford both over time and separate for age and race. This is a basic and fundamental need. Though we provided Dr.
Warner’s comments to EOT, they did not comply with our request for these baseline air and health studies even after
they were made aware of the California study and the New York
subsequent study.
We believe these
health studies are warranted based upon a report entitled “Environmental Justice Inventory for Ten Communities in the
Greater Boston Area” researched and written by Tufts University’s Urban and Environmental Policy and Planning
Dept. This 2005 report was commissioned by MEPA itself. The City of Medford is specifically highlighted in this report in regards to chronic disease
indicators. Medford was noted to have
44 lung cancer deaths at an age-adjusted rate of 61.8, which was higher than the state age adjusted rate. As we noted above, lung cancer has been identified as an issue of exposure to diesel particulate matter. There were 201 cardiovascular disease deaths at an area age adjusted rate of 253.6,
slightly below the state age adjusted rate. These numbers need to be updated
to create a baseline health impact from this transit project.
We believe this
DEIR should not be approved until such health studies are first conducted.
Ridership in Medford
Most of the ridership
numbers in the DEIR are based on riders diverting from other forms of public transportation, in particular other light rail
systems. Based upon the financial issues the MBTA faces now and in the future,
these ridership numbers appear to be just rearranging the deck chairs on the Titanic.
The new ridership numbers appear weak. Yet, the DEIR does not address
a study of comparable cost/benefits if the state was to address more efficient, enhanced services on existing lines. The EOT is proposing to invest $1 billion dollars in this project while adding $21
million of annual operational costs to the MBTA, an agency all ready suffering from operating deficits and deferred maintenance
issues. If we, the taxpayers, were to invest in this project as EOT estimates,
which do not appear to include mitigation costs, we would think the public should deserve this cost benefit/analysis to say
we are putting tax dollars in the most beneficial way.
Special interests
groups told citizens in Medford that people in the neighborhood would walk to stations to use the proposed Green Line Extension
as opposed to drive. Advocates have told residents that stations would not cause
parking or traffic problems because local residents would be walking to the proposed Green Line. This is unrealistic. But in the DEIR we are told that
ridership will increase over the years due to high-density growth. Medford’s character is not one of high density as the DEIR points out and to force this change upon our community is
to create a quality of life issue.
Despite recommending
no parking garage at this time, EOT coyly leaves the door open to put a 300 car-parking garage at the Cummings Property site. As Mr. Woelfel was quoted as saying in a local access show out of Arlington over a year ago that he anticipated putting an “Alewife” type garage at Route 16. We believe that EOT actually intends to build this facility to divert traffic to our area from the Alewife
facility and are only waiting for the public’s eye to wane on this project in the future. After all, the DEIR is an open contract as it now exists.
With the amount
of property EOT plans to take at 200 Boston Avenue, we can only surmise that EOT will use this facility to put up this garage
and possibly put a car barn at this location for bus layovers. We based our statements
on EOT’s stated intent at a Winchester public meeting to bring buses from Winchester, Woburn, Burlington and Arlington to this drop off area to boost weak ridership numbers. Buses through
this area would have to go through the West Medford community, a historic African American community. We believe that either scenario would cause an undue environmental burden upon this environmental justice
community. As we have stated previously, we would be opposed to bringing this
project forward from College and Boston
Avenue based upon these quality
of life and mitigation issues.
Traffic Congestion in Medford
It is unclear in
the DEIR as to when EOT took its traffic measurements. If for example, EOT took
vehicle traffic counts at Winthrop
Street and Boston Ave or at Route 16/MVP in the late spring/ summer, than they have under estimated the impact of traffic
in the area. It is well known that when Tufts University reconvenes in the fall, traffic impact increases in these areas as students
arrive back in the area.
EOT’s mitigation
proposals around traffic control have impact to Medford parking inventory. They propose elimination of parking spaces at Route 16/MVP and at the intersection
of Winthrop Street and Boston Avenue, impacting upon the small businesses in that area that depend upon car traffic as well
as walk in business. These measures would have a negative impact upon revenue
generation for these businesses. EOT also proposed elimination of parking spaces
in Ball Square, which could impact upon the South Medford
area in terms of park and hide, an area all ready experiencing traffic and parking problems. There are no real concrete solution
to these problems from EOT other than it is the city’s problem. EOT
needs to come back with stated corrective action measures that articulate any further mitigation and who will be picking up
the cost.
It appears that
if EOT’s inferred traffic mitigation measures do not work EOT can actually drop the responsibility for this condition
back into the hands of the cities by stating that these conditions are not attributable to the proposed Green Line Extension
project. For example, EOT is proposing a turning lane on the bridge at
College and Boston Avenue as a mitigation measure. Yet
we can envision drivers using this lane to drop off riders to the MBTA station instead of the designated drop off area. We can also envision these drivers impeding traffic as they try to use this lane to
head down College Ave toward Somerville or down Boston Avenue toward Ball Square as opposed to turning toward Route 16/MVP.
As Mayor McGlynn
stated in the city’s public comments to the EENF released in 2006 he states his concerns for the unique challenges this
intersection creates that are exacerbated by the College Avenue bridge
feeding into this intersection. As he notes this intersection has a high traffic
count, irregular turning movements with a significant number of university students walking through this campus area. We do not believe that EOT has addressed in their mitigation the Mayor’s assessment
of this intersection as a dangerous area. This issue needs to be addressed.
To understand traffic
mitigation, one must understand human behavior. We believe the measure that EOT
has proposed for this bridge will only enhance the danger of this intersection and its impact upon public safety. In fact, we cannot envision how people with disabilities would be able to navigate this hectic situation
as they try to access elevator and escalator entrances on the opposite side of the drop off area.
Based upon EOT’s
mitigation proposal cities would have no recourse in obtaining EOT’s project funds for corrective action if future traffic
congestion actually is not solved by EOT’s measures. We recommend then
that EOT work to determine within the DEIR appropriate traffic controls. It is
not apparent that they have done so prior to this DEIR report. We propose that
it should be required in the DEIR that all parking and traffic controls be monitored during the first five years after the
system opens for operation. If EOT’s implemented controls are found to
be insufficient EOT will be required to provide all funds for all corrective action as determined as needed by the cities
impacted by this project.
As Wendell Cox,
a Senior Fellow at the Texas Public Policy Foundation, writes in his article, “The Illusion of Transit Choice”
found in the Quarterly Journal of Public Policy in Texas, rail does not reduce
traffic congestion. He points out traffic congestion is getting worse everywhere
– in urban areas with new rail systems, and in areas without them. In looking
at transit choices as alternatives that bring drivers out of their cars, one must consider whether these choices are auto
competitive. As he states, the minimum requirement for auto competitiveness is
transit service that is fast or nearly as fast, from origin to destination, as the automobile.
This means taking public transfers into consideration as well when speaking of origin to destination. Although the proposed Green Line may get you to Boston,
what is the time to destination when taking into consideration transfers to other lines to get to your final destination? And since the trend in the country has been decades of suburbanization, hence there
has been significant growth of jobs out in the suburban areas. As has been
already been proven and pointed out in our comments, cars are going to jobs in the suburbs.
Therefore the flexibility the car brings to convenience of reaching a job in the suburbs versus a fixed rail system
that limits destination to downtown does not point to the conclusion that there will be reduction of traffic congestion to
the Medford area.
Recently Parade
Magazine highlighted a poll in its Oct. 18, 2009 issue that asked the question,
Should America cut funding for roads in favor of public transit? The results
showed the following, 51% of the public said no. Their reason was the following,
“Mass transit doesn’t go to enough locations on a frequent enough schedule to make it worthwhile. Driving is a better alternative.” This poll correlates
with Mr. Cox’s study conclusion that for transit to have any hope of attracting people out of cars, it must be available
in a form that is auto competitive. Although EOT has shown the proposed Green
Line’s extension’s competitiveness with current bus service, it has not shown it to be auto competitiveness. Therefore its conclusions that traffic congestion will be reduced are again theory
without practical application based upon other transit studies on traffic congestion.
This issue raises the question as to whether the proposed Green Line Extension is going in the areas of best benefit.
Parking
ü Hide-and-ride impacts may occur in station areas. To identify appropriate
parking controls, EOT should be required to conduct on-street parking inventory surveys now around each proposed station area
up to one year prior to the possibility of station openings to document existing on-street parking supply within a half mile
radius of the proposed station areas. We believe they have not identified this
inventory within the DEIR. Based upon surveys, we recommend that EOT work with
affected neighborhoods to identify and implement appropriate mitigation elements within studies prior to any proposed station
openings.
ü Mitigation issues should include time-limit signs, parking meters where
appropriate, passenger drop-off/pick up zones, truck and load/unload zones, and residential parking zones (RPZs) within a
half a mile radius of each station. We do not see proposed mitigation within
the DEIR that expands beyond the immediate station areas. EOT should be required to provide funding for implementing appropriate
parking controls, labor and all other related installation costs for these mitigation issues and we believe the cities should
insist that these measures extend to within a half-mile radius.
ü EOT staff should be required to monitor all parking controls during the
first five years after the system opens and determines if RPZs boundaries or other parking controls are insufficient. EOT should be required to fund any expansion of existing or newly created RPZs or
other parking controls during the first five years following any proposed station openings.
Visual Resources and Aesthetics
The Hillside area has many trees, vegetation and animal and bird habitats along the commuter rail.
This woodland habitat is an appealing, valuable environmental, and neighborhood characteristic for those abutters who
live along that area. This woodland barrier also acts as a natural sound and
diesel particle emission barrier for the commuter rail and traffic and buses on Boston Avenue. It also acts as a light barrier for the railroad and Boston Avenue and provides shade in the summer. We believe
the State Shade Tree Law should be investigated as to its pertinence to this area and should be an included requirement within
the DEIR. We have not seen such consideration of this law within the DEIR. In fact we are greatly concerned and opposed to the number of trees that EOT has proposed
to cut down such as oak and maples.
Many of our membership
who lives near the commuter rail have had negative experience with the MBTA and its vegetation replacement program. Once the MBTA puts in place its replacement vegetation program it rarely revisits the program to measure
it success or to maintain the area.
We are aware that
many abutters in that area are concerned with the destruction of this area by EOT’s proposal to move the commuter rail
closer to their homes, the construction to accommodate the proposed Green Line tracks and the impact on the wildlife in that
area. EOT within the DEIR seems to treat this concern with little veracity. MEPA should require further studies on this mitigation issue and should demand that
EOT come back with a further demonstration of how they will protect this woodland area without removing trees and vegetation
and disturbing animal and bird habitats.
The proposal of
any retaining walls by EOT in their studies that does not disturb the woodland area should incorporate aesthetic retaining
wall design measures, such as steps, patterning, texture, and vegetative planting that blends into the scale and character
of the neighborhood all paid for by EOT funds. In other words, any retaining
wall should enhance the character of what is all ready there, not replace it.
Air Quality
EOT has all ready
admitted in the DEIR on page 6-8 of the detail assessment that this project would cause some localized decreases or increases
in carbon monoxide and particulate matter. These areas have not been pinpointed
within the DEIR and MEPA should require that this information be held transparent to the communities involved and that mitigation
measures be identified.
MEPA should require
that EOT provide a stand-alone study of Medford’s current air quality especially in light of the health study we
are demanding for our community. EOT needs to guarantee that Medford’s air quality
is not going to be negatively impacted by additional traffic congestion and or the movement of commuter rail tracks closer
to abutters’ homes. We, as citizens, need to be guaranteed through scientific
studies that our air quality is not being negatively impacted by additional traffic congestion as we have seen in the Wellington Circle area with the TOD development there.
As we understand
it from EOT advisory committee meetings, the DEIR air quality projections are founded in part on projections of high rates
of alternative fuel/electric car ownership over time as non residents increase their use of the proposed area. As Dr. Warner advised GLAM, it makes more sense in these economic times to project the numbers for 15-20
year old high polluting cars and trucks that private, business, taxi and city users will be desperately sustaining during
these economic times and into any recovery. Therefore, we believe that air quality
studies should be done based upon current car and truck air quality usage.
Noise and Vibration
In regards to EOT’s
claims regarding mitigation for noise and vibration, we can only refer to the recent article in the Boston Globe, dated November 1, 2009, titled “Too Close for Comfort.” This article articulates that many of the proposals in the current DEIR, such as insulating windows, do
not address noise and vibration in the long term. Too much of the mitigation
proposed by EOT regarding noise and vibration depend upon the ability of the MBTA to maintain tracks and keeping tracks lubricated
over the years.
Based upon the
current maintenance conditions at the MBTA, it is self evident that this simple plan does not work. And anyone who has ever ridden the Green Line knows that is one of the most troubled of transit lines within
the system. We cannot think about what a project reveals when first brand new;
we must anticipate the issues of 10-20 years down the road when maintenance schedules break down. In the October 20, 2009 MetroBoston newspaper,
there is an article entitled “Outrage outpaces problems for now”. This
article mentions the issue transit riders have concerning the $2.7 billion maintenance backlog on the Green line. During the period of September 1 – October 9, 2009 the MBTA reported Green Line service failures
due to the following causes, 36% was caused by brake issues, 15% by door problems, 15% due to propulsion problems and 15%
due to electrical issues with 19% of problems accounted for other problems not specifically identified.
Much of noise and
vibration depend upon driver operation and good maintenance. There are no proposals
within the DEIR to slow down transit traffic and no evidence that noise levels were tested with consideration of both the
commuter rail and transit trains running at the same time. We caution MEPA and
abutters that mitigation as proposed by EOT is dependent upon MBTA maintenance. This
proposal is unrealistic and can negatively impact upon the quality of life. This
is evident whether it is issues pointed out on the Green Line or in the above-mentioned article we have found on abutters
fighting the MBTA on the Orange Line mitigation issues that have grown over the years.
It has also been
identified in the Consumers Reports on Health publication that noise pollution is correlated to high blood pressure problems,
especially in populations under 60. Therefore full mitigation in this area is
important to the quality of life for our residents.
The EOT/MBTA should
be required to develop a vibration and noise-monitoring system with agreed upon thresholds of vibration based upon residential
neighborhoods. The EOT should be required to perform these analyses on a regular basis if the proposed Green Line extension
is implemented. Failure to do so should subject EOT to monetary penalties that
would go to the cities impacted to institute future mitigation fund recourse for residents and local businesses. As we read in the above-mentioned Globe article on mitigation, the MBTA and state are rarely willing to
correct problems that arise over the years from poor maintenance on transit systems.
Water Resource Impact at the Mystic River:
We are greatly
concerned that the DEIR has identified wastewater discharge from Ball Square up into the Mystic River from this project. We would be seriously opposed to this environmental impact on the Mystic River. Best management practices
around water quality resources should be incorporated in the DEIR as required to meet applicable city, state and federal standards
and requirements.
Electromagnetic Fields due to light rail consumption:
Light rail, when
electricity generated, uses electromagnetic fields. In fact, the MBTA is the
greatest consumer of electricity usage in the state according to records we have read.
In fact, there is no comparative study to determine if the energy usage of expanding this system actually negates any
energy benefit identified. EOT has actually given short shrift to the impact
of substations and electromagnetic fields in the expansion of the proposed Green Line. The MEPA should require that the EOT’s
DEIR identify if there will be any adverse impacts to human health due to electromagnetic fields.
Recently the city
of Medford experienced electrical supply problems in South Medford
over a two-day period where residents were left without light and heat. How does
this additional demand on electrical systems affect an all ready over burdened problem?
This question has not been identified or addressed in the DEIR.
In fact, we have
researched that DC rectifiers primarily power light rail systems. If left uncontrolled,
stray currents originating from light rails and substations can cause corrosion of buried structures and piping. Light rails systems in close proximity to many underground utilities such as water, gas or sewer pipelines
may be affected by stray current corrosion. Repair of these kinds of problems
can be difficult because light rail systems have to be shut down prior to excavation.
EOT has not demonstrated in the DEIR what steps they propose to take to ensure that stray current has been addressed
in its plans and construction.
Also, the DEIR
appears to only mention a substation in Somerville. We cannot believe that
the electricity demand of this project would not require other substations in other areas.
Substations need to be clearly identified.
Public Service Safety and Security Plan:
The MEPA should
require that EOT in its studies determine a safety and security maintenance plan for policing of stations and neighborhoods. This plan would include developing procedures throughout proposed project design,
construction and operation. Although EOT identifies that the MBTA will be responsible
for emergencies and security issues, it is unrealistic to think that the city’s first responders will not be first on
the scene to protect citizens. Who will pick up this cost? This is a cost issues
that needs to be identified within a cost analysis.
Walking Court Housing:
We cannot express
more than we have all ready our concern on the environmental impact on this elderly disabled and environmental justice population
who live at Walkling Court.
EOT has claimed
there would be no impact on this housing program and also claimed that this housing was not in an environmental impact area. Yet we find this housing program under the noise mitigation map but not mentioned
specifically in the DEIR. We oppose any extension beyond College Ave and Boston
Ave due to these numerous mitigation
issues that have not been addressed specifically regarding this home to elders.
¨ Noise and vibration impacts both in operation and construction of this
potential project must meet HUD thresholds. EOT has not documented this project’s
impact or that it meets the HUD vibration or noise thresholds.
¨ What is the potential of increased hide and ride parking in this area? This has not been addressed in the DEIR.
¨ Disturbances by Pedestrians using the Walking Court site to cut through to station locations will be a problem that has not been addressed
in this DEIR.
Bus Routes in Medford:
It is unreasonable
to believe from a financial perspective that EOT would continue to run a bus route that mirrors the route of the proposed
Green Line Extension. We would like to see an alternative that demonstrates air
quality benefit if hybrid buses are used on this route instead of extending the proposed Green Line extension.
EOT states light
rail to be faster in accessing Lechmere station. But citizens who currently ride
the bus to Lechmere tell us that when you take into consideration the ability to transfer to get to areas such as Longwood
Medical area, the bus actually takes less time because it provides more flexibility in transfer connections than transferring
downtown at Park Street on the Green Line.
Also, EOT has stated
at its November 2009 hearing in Somerville that they will be reassessing the use of these bus routes as implementation
of the proposed Green Line plays out over the next few years. We believe the
discontinuance of any bus routes currently in Medford will cause increased
traffic congestion as people resort to driving to work or resort to kiss and ride drop off.
The reduction of any bus routes actually diminishes transit and choice of transit for those who reside in West Medford. The discontinuance of these bus routes we believe will have impact
on the planned development of Medford Square since the 326 Haymarket express, the 94 bus to Davis Square and 95 bus to Sullivan
Square stop in Medford Square for pick up of passengers.
MBTA Assessment fees and other costs:
The DEIR does not
address cost in any fashion that specifically shows a cost breakdown for this project.
We recommend that any cost analysis of this project must identify potential increased MBTA assessment fees to the city
of Medford, identify any electrical cost increases to its citizens and any additional
public service fees upon the city of Medford.
Smart Growth versus Fair and Sustainable Growth:
As GLAM has stated
in prior public comments, we support community development projects only when they instill the stability, affordability and
quality of life of neighborhoods so that deep bonds of commitment to the community can be developed through family and social
organizational ties. We believe the public should be cautious concerning the
proposed Green Line Extension project and EOT’s encouragement for Smart Growth.
We make these comments upon the findings of the Reconnecting America report, which focused on the changes in Porter
and Davis Square that ended up excluding middle to low income populations.
As part of GLAM’s
principles and objectives, we challenge EOT’s conventional wisdom around the economic theories that EOT is promoting
called university expansionism. As we have stated before in comments, many
abutters to this project are moderate income residents who fear of being displaced or priced out of their neighborhood as
advocates push the concept of higher property values with the proposed Green Line. Affordable
housing is not just a city issue; it is a state issue especially when the state is promoting forced changes in the DEIR upon
a community as opposed to natural change.
As pointed out
through Census Bureau 2000-2008 estimates of population, North Reading and Middleton’s population
has seen fast growth increases while Somerville’s population was down 2.5% during this same time period. Even when looking at the 2007-2008 time period, Medford
and Somerville both only had slight increases in population. These figures are collaborated by the weekly real estate transaction reports where Somerville has seen decreased sales in condominiums and single family home sales. These population trends show folks moving to suburbs such as North Reading
and Middleton for better quality of life and education issues as well as lower property taxes.
Therefore that is also why we feel riderships numbers should be reviewed within the contexts of loss population trends.
Americans with Disabilities Act
Although EOT has
spoken of stations being in compliance with the ADA, we do not see enough
specifics mentioned in the DEIR to ensure this compliance has been fully accounted within the DEIR. Therefore, we are providing some questions/comments regarding ADA
that we do not see addressed in the DEIR. These questions/comments are not meant
to be construed as fully addressing all ADA concerns. It is not the
job of GLAM to develop an accessibility design review checklist for EOT. But
we do believe that there should be an extensive accessibility design review provided within the DEIR to ensure compliance
for the disability and elderly community.
(a) Are curb ramps provided at all sidewalk and drop off areas? And are all disability access modes near the main circulation
route?
(b) Are all accessible gates and turnstiles located in an accessible path?
(c) Are all walkway surfaces paved, uniformed and surfaces slip-resistant?
(d) Are all sites graded to direct flow of water away from walkways?
(e) What is the measure of slopes and are they in compliance with ADA
access board architectural standards?
(f) Do all detectable warning surfaces have raised, truncated areas and in color designation?
(g) Are handrails and guard rails included at proper height?
(h) Within parking and drop off areas, have the required number of accessible parking spaces been designated or considered
in the design of drop off areas? Are the accessible parking spaces located on
the shortest possible accessible route of travel from adjacent parking to the accessible station building entrance? Have these issues been considered when looking at drop off areas such as College Avenue?
(i) Will there be posted warning signs with the international symbol of accessibility at each accessible
drop off area with penalties mentioned for violators?
(j) Does each passenger-loading zone have an access aisle at least 60 inches wide and extend the full
length of the vehicle pull-up space they serve? For example, is there room for The Ride to drop off people with disabilities? And have these plans been incorporated in station designs at areas such as College
Avenue when considering reconstruction of this bridge area?
(k) Wherever practical do exterior ramps or waiting areas have roofs or protective coverage for people with disabilities?
(l) Do all elevator cars have slip resistant surfaces? Do
elevators have handrails at appropriate height and control panel buttons within appropriate height? Do all elevators have a self-leveling device to bring the car to floor landing?
(m)Are all elevator car alarm and emergency
stop buttons and emergency communication grouped at the bottom of the control panel, with their centerlines no lower than
35 inches above the car floor? Will control panels have accompanying Braille
designation?
(n) Will all Green Line cars have similar floor leveling capability to bring a wheel chair on board? Will there be attendants at each station for passengers with disability access needs?
(o) Will the proposed Green Line station have audible signals to announce
cars arriving and departing? Will these audible signals as well be in elevators? Will there be visual signs for those who are hearing impaired for the same designations?
(p) Is weather protection planned for the outside elevator entrances?
(q) How will the disability community access trains inbound and outbound?
These items listed
are not to be considered inclusive of our ADA concerns. We suggest that EOT access
the Puget Sound Transportation Accessibility checklist. This checklist is extremely
comprehensive regarding ADA requirements in all aspects of providing public transportation.
In a letter provided
many months ago to a past EOT Secretary, we had surveyed a disability program to find their concerns about public transit
regarding the disability community they served. Two major concerns arose. The first is the fact that the Charlie card system was often difficult in access for
those with physical disabilities. For those with developmental disabilities,
literacy can be an issue when using the Charlie Card. Both these populations
suggested that there should be an MBTA customer service staff available to assist with these issues. The second concern was those with disabilities are often preyed upon by other riding populations. For example, there were those in the survey who had been robbed on light rail and
when riding a bus. Others experience verbal and physical abuse and harassment
at MBTA stations. Their recommendation was that there should be more security
available and more trained MBTA staff available at station sites.
Unlike EOT, we
believe that the MBTA settlement with the disability community does require that there be manned stations to address these
types of issues.
We also have raised
the question with FTA in our report/complaint as to whether the state can expend billions of dollars on a new project without first bringing
all, older stations into ADA compliance, such as Boylston Street station and Symphony Hall station as examples. This question should be answered before there is approval of the proposed Green Line project.
Environmental Justice and the Disability Community
GLAM’s purpose
is to give authentic voice to those segments of the population who are being excluded from the EOT process. GLAM’s credibility in the community of Medford is unique in that it is neither an advocacy nor an
opponent group. GLAM is an educational group that has tried to force transparency
in this project, posed the hard questions to EOT for those citizens who have felt disenfranchised by the EOT process. We have submitted public comments throughout the process, pointed out the need for
additional environmental study considerations and provided research on the disability community to EOT to enhance their knowledge
of the American with Disabilities Act (ADA) and its long reaching impact in this project.
It is well known that consideration of the disability community is often omitted from many governmental studies such
as found in the DEIR preparation work. In fact, the Dept. of Labor has just begun this year to track unemployment statistics
of the disability community.
We believe EOT
and special interest advocacy groups have demonstrated legal and cultural incompetence when dealing with the disability community and its civil rights laws. Therefore,
we cannot believe that they have the best interest of these populations within the project.
This cultural incompetence has lead GLAM to support a civil rights report/complaint to the Federal Transportation Administration
submitted by its individual members. This report/complaint is now under review
by the FTA with an assigned case number.
The federal EPA
recognized GLAM in 2008 as a public transit group based upon an alternative proposal we submitted to both EOT and the federal
EPA regarding the proposed Green Line extension. The federal EPA termed this
alternative proposal an enhancement worthy of discussion at the state level. This
alternative enhancement was posed to the EOT in anticipation of the mitigation issues we foresaw at the proposed Route 16/MVP
site. Our alternative enhancement can be found on EOT’s current document
site from October 2007.
We had proposed
that EOT do an alternative analysis study on taking the proposed Green Line from Ball Square, Somerville by tunnel to Route
16 Clarendon Hill Somerville where it could then connect to the Alewife Red Line station to meet the Urban Ring concept. We proposed that a maintenance facility could be constructed at Route 2 behind
Alewife to meet EOT’s needs. We provided EOT evidence developed by
the city of Somerville that shows there is more ridership at Route 16 Somerville than at Route 16 MVP.
EOT turned down
this alternative enhancement and has denied us public access to their quantitative and qualitative data that arrived at this
decision. For example, EOT claimed our enhancement did not meet the environmental
justice criteria for a transit project area even though the information provided to HUD by the city of Somerville demonstrates
a large environmental justice population at Route 16 Somerville than at Route 16 MVP.
Although we were told by EOT after several months of asking for this material, that the qualitative and quantitative
data would be provided in the DEIR. No such information has been provided and
we are asking that this information be put in the DEIR.
As you can see
with the maintenance facility issue, when Somerville asks for mitigation consideration, they are provided options that EOT
states will cost the state millions of additional dollars. But when GLAM at the
beginning of the EOT Advisory process, asked that studies (not the project) be completed on our alternative enhancement to
determine its feasibility, EOT gave us little attention and failed to bring our alternative enhancement forward in a transparent
fashion. We have found the EOT process discriminatory when considerations were
brought forward by the disability and environmental justice populations.
Tunnel
Alignment Analysis
During the EOT Advisory committee meeting process,
GLAM asked that a tunnel be considered between College Avenue and Route 16 MVP. A tunnel was proposed to alleviate
what we saw as severe mitigation issues coming forward if EOT proposed going above ground to this area.
Although EOT prepared a tunnel alignment analysis,
they turned down a tunnel as too costly based on numbers they proposed in their tunnel alignment analysis. But this cost analysis did not include the savings to be achieved in mitigation costs if EOT was to do
a tunnel in this area. Therefore, the possible savings of not having to replace
bridges or not having to do some or all mitigation to surrounding buildings was not addressed. We believe that the cost analysis prepared by EOT was not complete without addressing these mitigation
cost savings. We believe that had EOT truly explored this tunnel alignment that
they might have achieved consensus in the city of Medford on the Route 16 area as the idea took a positive hold among many residents.
This summer members of GLAM explored a capped,
depressed tunnel that was created in Reno, Nevada that took Amtrak passenger and freight trains below the city’s surface.
This train system addressed the pollution problem and inconvenience of a train that passed through the middle of the
city, causing both diesel pollution from the trains passing through and the idling of trucks, buses and cars as they often
waited for long freight trains to complete their trip and business through the city.
This city was much improved by a depressed tunnel that was then capped to provide a community shared path with proper
landscaping, ADA accessibility and Western artistry on display throughout the shared path.
The shared community path was used as an asset to expand community events near the Truckee River, which flows next to the train tracks.
Portions of this tunnel were hand dug to preserve
historic artifacts and buildings and had to accommodate a water way as mentioned above.
Therefore, you would think that the cost of the Re-Trac project as is it is best known would be very costly. But we found through discussions with Reno municipal staff involved in the capital project that this 2
½ mile structure actually cost much less than what EOT was proposing for a similar stretch of tunnel we had requested they
explore from College Avenue to Route 16.
Therefore, you must imagine GLAM’s surprise
when the tunnel idea was turned down by EOT due to cost, while the options proposed on the maintenance facility center for
Somerville adds millions of dollars. It seems that Somerville was provided all consideration
while GLAM was considered a second class citizen. We believe that MEPA should
require that EOT explore the tunnel option with a full cost analysis that includes mitigation savings, presented to the public
in a transparent fashion.
Verbal Comments
GLAM is protesting the fact that the Executive Office of Energy and Environmental Affairs (EOEEA) is not
accepting verbal comments for public record on the Draft Environmental Impact Review (herein called the DEIR report), EEA
number 13886. In attending the public hearing on November 18, 2009 in Somerville
on the DEIR, where EOEEA did not appear to be in official attendance, it was not clear that EOT would be transcribing the
verbal comments made at those meetings to EOEEA for their review process. Our
understanding is that the Federal Transit Administration (FTA) is asking for transcripts of these verbal public comments. We believe that verbal and written comments should be included in all Commonwealth
public reporting for the purpose of a diverse inclusive process that includes comments from all, not just those skilled in
written communication.
We have made our
complaint known to Mr. Donald Gomes, affirmative action officer for the Mass environmental agency in November as we believe
EOEEA’s process in excluding verbal comments violates the Americans for Disabilities Act (ADA). Mr. Gomes as of this
date has failed to respond to our letter of complaint. This protest letter was
copied to the Federal Transit Administration for inclusion in our civil rights report/complaint filed with the FTA regarding
what we believe to be public processes used by the EOT that have excluded citizen participation by the disability community
and environmental justice populations within this project.
As an organization
with representation of the environmental justice and disability communities, we believe that this process is becoming an elitist
one as opposed to a process of plurality, especially when you consider that EOEEA will be making a decision within seven days
after the January 8, 2009 extended deadline. Denial of putting transcripts of verbal comments in public record for review
solidifies this elitist process. The Commonwealth imposes cultural incompetence
upon its citizens by denying those with second language issues and those whose culture may be more comfortable in verbal communication
the right to have their comments put in public record. The federal government
on the other hand demonstrates its progressive stance by asking for the transcript of those verbal public comments. GLAM has notified both the Commonwealth and the FTA that we consider the policies of EOEEA to be discriminatory
to various cultures, including the disability community and environmental justice communities. This EOEEA process should be
nullified until proper public participation processes are put in place to allow meaningful scrutiny.
Conclusion and Recommendations
If one wants to
believe that theoretically the state and its forces have correctly analyzed and standardized what is going to happen in this
project, then one needs to review the financial conditions of the state. They
will recognize there is limited amount of money for cities and towns and that President Obama has announced he will be decreasing
domestic spending to bring debt under control. Based upon the financial picture,
we believe it brings the opportunity to require that more concrete studies come forward with conclusive evidence.
This theoretically,
abstract DEIR report bases everything on standards that have not been proven accurate.
We, as responsible citizens need to see reports with more empirical data.
We do not feel that empirical data is in the current DEIR.
Therefore we recommend
the following.
ü That the DEIR be forced back for further study to address omissions and
errors in the current report that weakens the credibility of this proposed project. For
example, there is no presentation of College
Avenue as a terminus for Phase
I of the proposed Green Line. Therefore, mitigation impacts are not articulated.
ü We believe that Route 16 should be eliminated from the current DEIR due
to the severe mitigation it proposes to the city of Medford as currently proposed.
ü This project should be broken down into additional phases that allow the
public to see at each phase the actual impact of this project upon communities. This
process would allow further studies to determine better mitigation measures and gives cities like Medford the ability to absorb
current economic development plans with affordable housing strategies.
ü Although GLAM is not unsupportive of the effort to build to College Ave
and Boston Ave, we just do not believe that the theoretical evidence proves the need there since the stations are so close
to each other. Using MGNA and STEP’s own statements that people will only
want to walk or bike to a station, why not walk to or bike to Ball Square in an effort to save money for the Commonwealth? This is of course assumes
that Tufts does not wish to contribute to this project, taking a financial burden off the state.
ü Due to severe mitigation and financial impacts upon Medford, we cannot
support the proposed Green Line beyond College Ave. In fact, we question the
financial viability in doing this project at all, but do realize that transportation is the future growth of our communities. But we want to grow with a population that includes the Disability and Environmental
Justice populations who are currently a part of our community unlike Davis Square and Porter Square where these populations were partly eradicated from this area.
ü If the state ever gets the money for this project, we would suggest EOT
instead revisit GLAM’s alternative/enhancement to Route 16/West Somerville where the largest population in that part of the city is where the disability and environmental justice populations
live. But we are willing to recognize that the financial constraint of the state
hampers this progress at this time. Or so we thought until EOT was willing to
ante up additional millions of dollars for the Option L maintenance facility site as proposed at their December 2009 public
hearing in Cambridge. Although we support Brickbottom in its compromise with
the state to meet mitigation issues, we also are concerned that this compromise was won at the expense of the disability and
environmental justice communities.
Unfortunately if
the state takes this financial burden on at this time as it is proposed, we will probably find ourselves in another Big Dig
capital project with very little reality coming out of promises made and a great deal of debt burdening the next two generations.
These comments
are respectfully submitted by Executive Committee of The Green Line Advisory Group for Medford
and other concerned citizens.
Sincerely yours,
Carolyn Rosen
Chairperson
Green Line Advisory
Group for Medford (GLAM)
