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Green Line Advisory Group of Medford (GLAM)

State Environmental Response to Green Line Final Environmental Impact Report

Mission Statement
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The Secretary of Energy and Environmental Affairs, through the Commonwealth's MEPA process has released a record of decision on the FEIR submitted by the Mass DOT on the proposed Green Line extension. 

The project has been approved to move forward to preliminary design and engineering to College and Boston Avenue in Medford.


FEIR Certificate - Record of Decision - July 30, 2010

Final Environmental Impact Report and appendix

GLAM's Public Comments to the FEIR - July 19, 2010

Public Comments on the


Final Environmental Impact Review

Green Line Extension

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




The Honorable Mayor Michael McGlynn


The Medford City Council

85 George P. Hassett Drive

Medford, Mass. 02155




July 19, 2010



Public Involvement Plan Comments


Although we agree with Mass DOT’s Public Involvement plan as theorized in Section 6 of the FEIR, it is the equitable and practical application of the theory of which we are concerned.  On page 6-4 Mass DOT states:  “Topics raised and covered by the Design Working Group should be generally germane to the Green Line Extension Project as it has been defined and must not claim resources of the Project and the Design Working Group that could be better dedicated to pertinent and pressing issues;” The proposed Green Line Extension has been defined in the FEIR as College Avenue, Medford.  Yet, the project is still wide open to Phase II as Route 16 is still in play. 


We believe that this section of the Public Involvement Plan should be better defined as to what is germane to the proposed Green Line Extension.   For example, in the July 11, 2010 Boston Globe article, entitled “Long-awaited Green Line Extension to Somerville, Medford delayed” Secretary Mullan attributes the project’s delay to what could be considered the contentious behavior by the city of Somerville and its citizens around the maintenance facility site.  The new facility site location is now costing the project $50 million more in taxpayers’ dollars. [1]  Although we support Option L as a resolution for Somerville, much time and resources were diverted to this area that others might not find germane to the project since they also have pressing issues that have gone unanswered.   Germane can be a very subjective term based upon the state’s agenda.  Therefore, we recommend that a more objective term be defined.


In reviewing the Station Design Working Group membership assignments, Mass DOT is essentially stating that Medford is excluded from full participatory rights within a plan process that will affect our community’s quality of life.  Yet, our civil rights issues brought to the attention of the federal government are so far unresolved by the state. The state, though, is willing to pay an additional $50 million dollars more in costs for this project than address the Civil Rights and American with Disability Act (ADA) issues that have been brought to their attention.  The question is, are civil rights and ADA rights being overridden in Medford by Mass DOT for issues such as Brickbottom, where the majority of complainants are white.   We contend that ADA violations have continued to occur right up to the June 30, 2010 public meeting held by Mass DOT in Somerville. 


On page 6-7 of Public Involvement Plan under Stakeholders and Constituencies, Mass DOT states, “Through out the Project, Mass DOT has worked with and would continue to work with various local environmental justice community groups . . .”  The definition of environmental justice needs to be further defined in this document and expanded to include the disability community.  Although Mass DOT has made rhetorical reference to “continue to work with”, this participation needs further robust definition.  How does Mass DOT plan to work with the groups listed on pages 6-7 and 6-8?   How does the substance that comes from neighborhood groups get woven into the Station Design Working group  process? 


GLAM itself has been approached by the Metropolitan Area Planning Council (MAPC) concerning public involvement on this project.  But the topic was not about mitigation and construction issues within the defined project area.  David Moehler had previously stated to us in a letter.   Mass DOT’s resources would be focused upon.  The topic was on land use and station design for Route 16.   Although GLAM will certainly work with MAPC in regards to how the state can better perform outreach that allows all diverse voices to be heard, it does feel as if Mass DOT has created a dual public process that has marginalized community groups to the peripheral of Phase I.


An astute political analysis might determine this separate but equal process set up by Mass DOT is nothing more than a political ruse.  Delaying the project just far enough in advance so that Mass DOT can perform a slight of hand and put in a notice of project change to include the Route 16 station.  This analysis is based upon Ms. Fichter’s comments in a recent Somerville news article where she mentions this possibility and it is repeated as a theory on the Medford Green Line Neighborhood Alliance website.  Anyone with a contractual law background knows that Mass DOT can amend this project at any time, especially if you have a dual study process on going.


The question becomes, is Mass DOT diverting funds from the defined project to once again increase costs to the project for Somerville’s benefit.  We can’t imagine that the city of Somerville has negotiated giving up $322k in annual property tax at Option L while not putting pressure on Mass DOT to recover these funds through land development at Route 16.  Thereby, Somerville, with its materialistic philosophy, is putting pressure on Medford’s elderly, environmental justice and disability community direct to the Route 16 area for Somerville’s benefit.   


In the recent Chronicle of Higher Education, dated July 16, 2010, essays were presented on the topic “Anger, How We Became the United States of Fury”, a multi viewed discussion on how our country has become one of rhetoric that threatens to swamp our politics due to the  “. . . schism of the role of government in American life.”   In the essay entitled “The Fairness Instinct” by David P. Barash, professor of psychology at the University of Washington, he points out that government policies that depart from perceived even handedness have a long history of rousing departures from citizen complacency and even from civility.  Paternalistic governmental dictates are often seen as unfair when the government does not consider the action of human freedom and rights in decision making nor in the role of history.  


In his book, “Best Laid Plans: How Government Planning Harms Your Quality of Life, Your Pocketbook, and Your Future”, economist Randal O’Toole points out planning’s failures in a challenging environment that stands between planning and success.  The planning task is often too big and multi layered amongst many planning groups at various governmental levels.  Government plans are often too complicated trying to accomplish too many goals with little transparency accept to special interest groups who lobby for their demands.   


Planning processes are often too slow to keep up with realities.  As Mr. O’Toole states, “Even if scientific planning were possible and the right people were doing it . . . politics inevitably distorts the results into something totally irrational.”  As he points out there is a disparity between how planners think people should live and how people really live.  The plan itself becomes a source of oppression instead of a way for people to improve their lives who all ready live there.  As sociologist Herbert J. Gans points out in the book “The Last Tenement: Confronting Community and Urban Renewal in Boston’s West End” he joined a sociological study on the West End before government’s forced relocation of the neighborhoods because he was concerned “. . . about the antagonism and middle class bias of city planning . . .” 


As is the case then and is mirrored now in the Green Line extension process, urban development is usually spurred by special interest groups who manipulate to get their way by selling to the public the rewards of economic growth while setting in motion the displacement of targeted groups who do not fit a middle class value system of hegemony. All the while influential business owners stand in line to get tax breaks for development, while the real estate industry buys up property in hopes of driving up the future price of housing and the Boston press is exploited in its partnership with the special interests to push the image of the need for change due to “blight.”  Blight, a subjective class term that has been used to insult Medford’s historical West Medford African American community by advocates of this project.   One can see the “stacked deck” process that was used in the West End urban renewal now being seen in the selling of the Green Line Extension project to the public. 


For example, on April 1, 2010 Mass DOT put out a press release that it was entering the Preliminary Engineering phase of the Green Line Extension project.  They created a GLX Design Working Group application to solicit residents’ help in pushing Mass DOT’s “selling” of this project to the public.  Mass DOT’s public preference criteria narrowed participation to those who lived within a mile of the catchments area, riders of public transit, and have an open mind with a strong interest in the Green Line Extension Project with preference with those experienced in the planning professions.  We contend that Mass DOT’s criteria was nothing more than code words to state it did not want anyone who might bring up criticism and skepticism concerning neighborhood impact in design plans.  And the code words are germane in Mass DOT’s effort to marginalize other important issues such as quality of life, which are germane.


In the Public Involvement Plan of the FEIR, section 6, it states that Mass DOT in the next phase of public involvement “. . . should build upon past experiences and gained knowledge to meet the goals we have now set out.”  We agree that public involvement is always a learning process if you have an open mind and are willing to learn from past experience.  Yet, we do not see a commitment to diversity within Mass DOT’s selection process.


In fact Mass DOT clearly states in the FEIR on page 6-4 the Design working group “. . . should be committed to and supportive of the planning process for the Green Line Extension project . . .” But who determines what is pertinent and pressing issues, the current community or Mass DOT?  In our opinion, Mass DOT continues its public policy of don’t ask, don’t tell and in turn appears to have set up a blue ribbon committee to rubber stamp its desires.    


In Hannah Arendt’s[2] book, The Promise of Politics, she speaks to Socrates unending questions of his community that were based in more compelling ethical ideals.  These “. . . unending questions disrupted and impeded . . .” Socrates community’s “. . . pursuit of wealth and influence and other material interests.”  Therefore Socrates took his own life because he asked such thought provoking questions.  Today, this method of questioning is called Socratic.  Mass DOT cannot stand up to the community who uses Socratic questioning.  We can only imagine what would happen if Mass DOT had to stand in front of people who understand Socratic questions such as professors, lawyers and those involved in civil rights laws to name a few.    


The progressive educator, John Dewey, in his book, Democracy and Education in the Chapter on Physical and Social Studies: Naturalism and Humanism, he too warns of allowing materialistic philosophy encroaching on the human spirit.   He states, “. . . it is even natural that the growth of scientific studies should be viewed in suspicion as marking a tendency of materialistic philosophy to encroach upon the domain of spirit.”  


We contend that the proposed Green Line Extension public involvement plan as proposed by Mass DOT is laudable in theory.  But the practical and non-socratic application of their process to focus only on design and provide scientific studies without concern to the humanistic impact to those who live here now is flawed. 


For example, Mass DOT through its Station Design Wok Group has actually encouraged special interest group pressure upon the community of Medford through its Community Corridor Planning Project (CCPP).  (Page 6-1)  This group is being sponsored by not for profits whose IRS mission appears to be within the confines of Somerville.  Yet they put forth station designs and land use development plans for Medford stations such as Ball Square, College Avenue and Route 16 without posting meetings to the general Medford public.  You are supposed to know who they are and where they are on the website.  This process is a Socratic question within itself of leaving out those citizens who are not online.  Is this legal?  Is it ethical and is this morally right?  That is a germane question to this project whether Mass DOT sees it as germane or not. 


One of these not for profits backing the CCPP group is called Groundworks Somerville Inc.  One of their founders listed on their Articles of Organization is Tufts University’s Community Relations Director, Barbara Rubel.  According to Groundworks website, it receives private funding from Tufts University and the EPA amongst other individual donors.  We believe Mass DOT should provide full disclosure to the Medford public on this less than arms length relationship with Tufts University.   By not doing so it appears that Groundworks is nothing more than a front for Tufts University and its self interest in the proposed Green Line Extension. 


The Station Design Working Group seems to be riddled with similar conflict of interest and undue influence on behalf of the City of Somerville and Tufts University.  For example, a city of Somerville official is a board member of Groundsworks whose term limit is not until 2011.  Two of the persons listed for Medford Ball Square representation do not appear to be Medford residents.  In fact one of the persons mentioned has worked for the City of Somerville as an intern developing a transportation and infrastructure report for the city’s first Master Plan.  This person has also worked as a Research Assistance for Tufts University.   Again, these relationships should be disclosed to the public since there does not appear to be arms length relationship with major political players in this project. 


GLAM has made a simple request of Mass DOT to provide full disclosure of the affirmative action breakdown of this Station Design Group and the ranking in criteria of how each member was selected based upon the criteria set by Mass DOT.  This is public information that should be readily available if indeed an objective, formal process was in place to meet the state’s overall goal of diversity in public participation.  Yet, Mass DOT could not respond to this simple request and has now turned it over to their legal department.  It appears the state can require its vendors to provide such public affirmative action information to them.  But they do not wish to provide it to the public themselves. 


We know even to most recent experience that disability access to public meetings has deteriorated.  Therefore, they no longer have to pay pretense to provide ADA accessibility or ensure authentic representation of the environmental justice community, inadequate as it has been over the last seven years.  In fact, Mass DOT no longer feels it has to record transcripts of verbal comments at public meetings because of the undue cost.  This means those with second language issues or the disability community members with communication disorders are left out of the process.   But Mass DOT will spend money on public relations magnets highlighting the proposed Green Line because they now think they have a process in place where they can control and dominate the public discourse. 


As we stated in our public meeting comments on June 30th, Mass DOT has set up a dual public process that we believe marginalizes the disability and environmental justice communities.  While Mass DOT claims it does not want the Station Design Work Group process to divert resources, it continues to divert resources and tax payers’ money to an area that is not designated under the FEIR.  We are speaking about Route 16, an unfunded project.


We believe the public should be aware that GLAM believes the public process around land use and station design, especially within a dual process as proposed by Mass DOT, will become less and less transparent as this project moves on.  Especially now that Mass DOT believes it has lulled the general public into thinking this project will not happen due to lack of funding.  Mass DOT appears to be marginalizing community grassroots groups of diversity in the FEIR public plan without description of how they will continue to work with them and make this a meaningful process.  GLAM contends that Mass DOT will instead use not for profit groups to subvert the local decision making process. 


As described in a policy analysis called “Smart Growth at the Federal Trough,” this analysis describes how government agencies like Mass DOT and MPO’s provides government funds to not for profit organizations who are not diverse to unduly influence a process “. . . because locals cannot be trusted to determine there own fate. . .”  Case studies point to how local municipal governments are not only directly lobbied, but that a process is put in place to indirectly subvert local decision making of those municipal governments who may balk at the impact of projects such as the proposed Green Line extension. 


We believe this process is occurring now, especially when you see Somerville groups such as the not for profit mentioned who has put forth designs for College and Boston Avenue, Medford, that come right out of their donor, Tufts University’s Master Plan play book.  Or when we see these special interest groups putting undue pressure on Medford housing programs, such as Walkling Court,which has a large diversity, in the name of economic growth. 





College and Boston Avenue, Medford:


First and foremost, we would like the most egregious portion of this FEIR corrected.  In Section 4 of the FEIR called College Avenue Station, Mass DOT lists this station as being at the corner of College Avenue and Boston Avenue, Somerville.  Although we understand that Somerville has been the favored child within the process of this proposed project, we don’t believe it has been so favored that the state has annexed that portion of Medford and given it to Somerville.  Please correct this Freudian slip in the FEIR, a public record document.  The document should read College Avenue and Boston Avenue, Medford. 


Also, we are in agreement with Mr. Scott Peterson’s recent CTPS analysis of the definition of Medford Hillside and his use of TAZs as his breakdown.  CTPS interpretation, we believe, is the traditional definition as accepted by the general public of Medford.  We do not believe that the portion of Route 16 that is in Somerville can be justified as a part of Medford.  Hence, it is not the Medford Hillside.             



Page 1-1 of Introduction:


“Because Mass DOT is seeking funding through the FTA, the Project also requires review under the National Environmental Policy Act (NEPA).”  Our understanding is Mass DOT is preparing a separate Final EA once this FEIR is approved.   GLAM would like to put it on public record that we have formally asked Mass DOT planner, Ms. Katherine Fichter, to mail a hard copy of this Final EA report to GLAM as soon as it is complete. 


Page 1-3 of Introduction


Regarding Lechmere Station the FEIR states, “Explore ways to reduce the proposed parking program (in light of the station no longer functioning as a terminus).”  On page 5-3 of Lechmere Station section, Mass DOT is planning to reduce parking at the Lechmere area by 167 parking spaces. 


Since College Avenue will be the terminus in Medford, GLAM would like to see a parking study that determines the various arrival points from which cars are coming to Lechmere station now.  And how many would then be assumed to come to College Avenue instead if parking is reduced at Lechmere?  Without this study it will always open the door for a parking garage at Route 16.  Something no one is in favor since it will put a larger environmental burden on the environmental justice and disability community who live there. 


Page 1-4 of Introduction


As outlined in our comments on the DEIR, GLAM would like to see a Phasing in of the primary infrastructure improvements required by the project to address social responsibility impact concerning reconstruction of 11 bridges and their impact upon local traffic and neighborhoods.   Building a project such as the proposed Green Line Extension all at once within a short time span will be quite disruptive to neighborhoods.  We believe the FEIR should require more detail in the scheduling of the specifics of this project.   


As mentioned in the public announcement regarding delay of the proposed Green Line Extension to College Avenue, we are in support of alternative substitution to this project such as hybrid or retrofitted buses as proposed by Mass DOT.  We also would suggest that the commuter trains in this area be replaced with much more environmental friendly retrofitted engines to clean up the diesel pollution upon our abutting neighborhoods. 


GLAM has always been in favor of substitutions as documented in our public comments to the National EPA.  We believe approval of substitutions provides the Commonwealth of Massachusetts the flexibility of meeting environmental goals while addressing a dire economy.    



Page 1-5 of FEIR.  


We would like a study instituted during the proposed Green Line preliminary engineering design and construction period to investigate if the theoretical assumptions listed in both DEIR/FEIR such as 70 % percent of riders are projected to switch from using their automobiles to using transit.  This information should be verified before any proposed further expansion of the proposed Green Line in the far future. 


Page 1-5, Section 1.3


“Estimated travel time between College Ave and Lechmere Station for the proposed Green Line Medford Branch is 9.5 minutes.”  We believe that estimated travel time should be determined between College Avenue and Park Street instead.  Our members who take public transportation into Boston have seen disruption of the Green Line service every month at North Station.   Travel time has an impact on decisions in getting out of your car and taking public transportation.   Therefore, we would question this headway prediction.  The Green Line is known as the worst transit line amongst commuters.  Our membership observation in riding the Green Line recently this winter at peak hours was that it took 20 minutes to just go from Arlington Station to Lechmere Station for a Mass DOT public hearing in Cambridge.



Overall Disability Access Issues

1)    Stations design, page 1-5, Section 1.3.1 – We would want to see attendants at each station for assistance to the person with a disability.  Automated fare lines do not always work efficiently or properly.  We provided a survey to the MBTA a while back that detailed issues encountered by the disability community in participating in public transportation.  This survey was provided to then Secretary Cohen of the MBTA around the issue of security for people with disabilities both in and around the station area due to robberies and harassment of the disability community.  We also pointed out that those with intellectual challenges often have problems dealing with the Charlie Card and need help.  Therefore, we believe that an attendant is important at station areas. 


2)    Please note that Architects are not always necessarily versed in ADA standards based upon our experiences, such as the Gantcher Family Sports and Convocation Center incident at Tufts University where Medford citizens had to bring in MOD to demand corrections to a building designed as non handicap accessible.  Architects also only think of ADA as a physical barrier issue and not as a civil rights law.  Therefore we would like to see a Massachusetts Office of Disability (MOD) certified monitor included in the membership of the Station Design workshop who understand the participatory role of ADA. 


3)    We would also like to see a disability checklist developed and provided to disability groups regarding station design, much like the one that Portland, Oregon provides.  We can provide a copy of this list if you would to see an example.


4)    One of the biggest issues in disability access is inaccessible trains that do not meet the station platform and creates a boarding gap. 


5)    We would also like to see an educational, media campaign requiring courtesy to the disability and elderly community who chose to ride public transit.  Although Celtics player, Paul Pierce, promoted such MBTA publicity during the Celtics championship games, we believe this campaign needs to be on-going.     


6)    We still do not see appropriate, designated drop off areas for the disability community at stations such as College Avenue.  Para transit riders are the fastest growing transit rider population of MBTA according to reports we have read recently.  If we are to encourage their participation in further modes of public transportation, we need to make entrance and exit easily available.


We wonder if Mass DOT is not considering the disability germane since there appears to be no self identified environmental justice or disability representation on the Station Design Work Group.  We wonder what Socrates would think of such a non participatory set up.  Though there is a person with a disability on the Working Group, he does not represent the disability community of Medford.  He represents the dual interest of the MBTA as their representative.  This dual interest in participation is not what Socrates was speaking to.  In the style of Socratic questioning, would this MBTA representative through the design process push for New Freedom Initiative funding that encourages going beyond the ADA with further accessibility enhancements?  Yet, in his dual interest role, he may not be strong enough to make this case for the disability community.  And this may be germane to the proposed Green Line extension process.      


Small Business community


We still do not see a clear articulation in how Mass DOT plans to deal with the small business community in Medford from Ball Square up to Winthrop Street.  Many of GLAM’s business community members complain of not being notified of proposed Green Line action concerning their property and of finding Mass DOT personnel disingenuous when approached with questions by the business community.  Many of the business community in this Medford area did not know until the DEIR was released that there property was on the land acquisition list.  Many of these family owned businesses provide blue collar jobs to our community.  Because Mass DOT’s failed in being forthright and upfront to this community, they are now seen in a suspicious light.  This is true especially when Mass DOT uses groups such as the CCP to act as if the neighborhood is a blank canvas regarding their land development desire.  This behavior does not play well to an audience who has spent their lives building up their business with their own future plans.  This is a social impact that Mass DOT can never put a price upon.  Materialistic philosophy played out in middle class planning bias versus the human spirit. 


There is not a representative from the Medford small business community on the Station Design Working Group located near the station. Therefore, we recommend that the small business community of Medford should be represented.   


On page 2-9 under real estate impacts, the FEIR claims that M.S. Walker Wholesale Distribution provides jobs for 74 people.  The owner, who appeared at the public meeting on June 30th, pointed out the falsity of this assumption because he employs over 300 people.  Instead of Mass DOT personnel lurking in parking lots counting parking spaces to determine employment numbers, they may have done their credibility better by asking the owner the number of employees he employs or instead review Commerce department reports filed by business to provide accurate employment data.  This is the second time that Mass DOT has provided erroneous employment information that the business owner has countered as false at public meetings. It is ironic that Mass DOT would not consider in calculating employment number people who may carpool, who take the Ride (a disability transit program) and those who may walk or bus to work from Sullivan Square. 


We suggest that state’s labor department should be involved in the proposed Green Line study where more accurate employment information can be provided to determine true socio economic impact and needs in the surrounding community.   Walker Wholesale is a union shop as the owner reported.  At the recent Democratic Convention in Worcester, we heard Speaker of the House, Robert DeLeo, call the current state of financial affairs in the Commonwealth a Blue Collar Depression.  Therefore, we would have to wonder why the Commonwealth of Massachusetts would chose to eliminate 300 blue and white collar jobs from the market place.   There seems to be a pattern building here concerning economic impacts eliminating blue and white collar jobs in traditional blue collar businesses.  But this is not germane to Mass DOT’s project.   



Page 2-35, Section 2.5.6 Title VI and Environmental Justice – Executive Order 12898 Federal Actions to address Environmental Justice in Minority Populations and Low-Income Populations- disproportionately high and adverse effects on minority and low income populations that affect human health or the environment so as to identify and avoid.


Under the Transportation Reform bill passed recently by the legislature there is outlined the need for health studies regarding projects within 500 feet of transportation projects.  We are once again requesting that an environmental health study be done on diesel particulate impact in the Medford community, similar to the California EPA study and subsequent New York study that found similar health issues.  This has been pointed out to Mass DOT on several occasions.  We are formally requesting that MEPA require this baseline study on diesel particulate pollution in Medford in which the California EPA has determine it as a cause of premature death and increase in respiratory illness and lung cancer.  They have recommended that diesel particulate impact be separated out into a separate study from general ambient air quality status.  In our reading of the legislation, there is a partnership required with the Dept. of Public Health in conducting these studies.  


We also are concerned at the environmental justice and disability impact we see at site locations such as the VNA in Somerville, the elderly housing at Pearl Street and Medford Street area in Somerville, as well as, the Walnut Street area that houses disability service program.



On page 4-9 of the FEIR regarding the College Avenue Station Mass DOT has stated that the FTA requires that severe impacts should be mitigated if at all feasible.  Moderate impact, according to Mass DOT allows more discretion.  We interpret these phrases as legal language loop holes that leaves Medford abutters open to Mass DOT’s interpretation of if at all feasible.  We believe that Medford abutters deserve the same consideration as Somerville residents at Brickbottom.  Medford abutters should receive the fullest mitigation that money can buy.  If the Mass DOT can add $50 million to the costs of this project for the City of Somerville, we request the same amount or more in Medford mitigation for our homeowner and business community impacted by this project since they will bear the undue environmental burden according to the legal settlement on stopping at College and Boston Avenue, Medford.  If Mass DOT goes beyond that defined area and legal settlement, they are opening the door for more mitigation equal to or worse than stopping at the defined legal settlement area.  This expansion would open the door for people with respiratory illness to bring litigation against the state since according to the California Study diesel particulates can travel from one to three miles in impact.    


Mass DOT also states in the FEIR that vibration mitigation remedies generally perform better for light rail as opposed to hard rail.  (see page 4-11)  We wonder why Mass DOT has not considered moving the Green Line to the opposite side of the tracks than proposed so as to better mitigate for residents.


We also suggest that consideration should be given to move the College Avenue station south of the College Avenue Bridge and thereby also moving the Ball Square station to the other side of the Broadway Bridge.  By keeping the Green Line to the opposite side of the tracks than proposed, a Green Line station could be developed at the Athletic field through land acquisition with its natural parking facilities.  This affect could also lessen the impact of creating a full 1000 foot long 6 ft tall noise barriers along the abutting line.  No one wants to have their back yard effect destroyed by a six foot noise barrier that appears as if you are walking into a prison exercise yard.          


We do not believe that the city of Medford’s questions have been answered through this FEIR.  In fact, it raises more questions concerning hidden costs of this project upon municipalities. 


On page 8.3.4 it states “New and expanded stormwater management systems would be required to collect the runoff from these areas.  These systems would discharge into the existing municipal stormwater drainage systems.”  These areas are defined as new impervious surfaces, including station roofs, walkways, platform and other pavement for new stations.  Who is picking up the stormwater runoff cost that the MWRA will charge to the city of Medford? 


Also this FEIR does not address this runoff impact on the Mystic River?  Why not?


While the FEIR pays attention to building station designs in accordance with the history of Somerville, it mentions nothing of the same accommodation for Medford. (see page 8-17)






As we stated in our Public Involvement Plan comments earlier in this report, the process of the proposed Green Line Extension seems to be a stacked deck that ignores Medford’s need for clarity in concrete content of impact upon its community.  Errors in geography aside, other than public access to transportation that we all ready have in our community we see no socio economic benefit articulated at this time for Medford.  We support the city of Medford’s request for more concrete engineering information on the defined plan area and construction impact.    


Therefore, having reviewed the FEIR we have found nothing new from Mass DOT regarding improvements in the Medford proposal.  Knowing that the city of Medford must provide permits for station and bridge construction, we advise the city of Medford to reframe from providing their permission until we see a much more robust socio economic plan.  Instead of advocates encouraging our city to  tear down elderly housing such as Walkling Court and replace it with Station Landing type smart growth development or forcing out legitimate small business in favor of what Herbert Gans refers to as a middle class bias planning process, we should be demanding better mitigation for our diverse community.     


These comments were written by Carolyn Rosen, B.A, MBA, M.T.S. and William Wood, B.A., M.Ed., Ph.D. and respectfully submitted and approved by the Executive Committee of The Green Line Advisory Group for Medford and other concerned citizens.



Sincerely yours,



Carolyn Rosen, B.A., MBA, M.T.S


Green Line Advisory Group for Medford (GLAM)


[1] See Maintenance Facility Alternative Analysis table 2-51.

[2] Hannah Arendt (October 14, 1906 – December 4, 1975) was an influential German, Jewish political theorist whose book The Promise of Politics was post humously published in 2005 by Schocken Books, New York.  Arendt demonstrates how our habitual view of politics as an instrument in the service of private liberty, material gain, and social prosperity actually increases the danger of these goals.

GLAM's Comments on the DEIR - Dec. 30, 2009












Green Line Advisory Group for Medford (GLAM)

  c/o 25 Bussell Road

Medford, Mass. 02155





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




The Honorable Mayor Michael McGlynn


The Medford City Council

85 George P. Hassett Drive

Medford, Mass. 02155



December 30, 2009





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,[1] 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. 2  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 naivet 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.





     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. 

     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. 

     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 [2] 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 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. 


     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.


     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.


     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. 


     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. 


     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.


     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


Green Line Advisory Group for Medford (GLAM)

















[1] Dr. Warner is a retired professor of Cell Biology and Obstetrics/ Gynecology and Interdisciplinary studies.  Dr. Warner is a former Dean of Baylor College and also has taught at Union Institute in Cincinnati.  She has served on the Houston Galveston Area Council, a 17-member county planning commission for over ten years.  In particular she serves on the Environmental Health committee and its Air Quality subdivision.  Her background and interest is in health as a faculty member of both the Cell Biology and Obstetrics/Gynecology Departments and in research in the Realties of Cancer in Minority Communities, and chemical and environmental basis for cancer causation.  She was the first woman to participate with NASA in putting a biological project in space.

2 In our research at the Medford Assessor’s office, it was found that the 200 Boston Avenue property was assessed at $13,016,400.  At a commercial tax rate of $20.36 per thousand, the property tax on this commercial building alone represents $265,000.  This figure does not include the Elizabeth Grady building proposed to be taken as listed in the DEIR. 

2 Cultural incompetence is the lack of awareness about cultural difference and this lack of knowledge can result in an inability to step out of one’s position to recognize the difference.  Despite a community population’s similarities, fundamental differences among people arise from nationality, ethnicity and culture as well as from family background and individual experiences.    We define these differences to include race, ethnicity, disability, class, religion, gender, sexual orientation and educational position.