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PUBLIC COMMENTS ARE DUE IN WRITING ON NOVEMBER 18, 2011 ON THE ENVIRONMENTAL ASSESSMENT (NEPA REVIEW).
 
COMMENTS SHOULD BE SENT TO KATHERINE FICTHER
MASS. DEPT. OF PUBLIC TRANSPORTATION
OFFICE OF TRANSPORTATION PLANNING
ROOM 4150
TEN PARK PLAZA
BOSTON, MASS. 02116
OR EMAIL AT

GLAM Public Comments on Station Design Principles - November 8, 2010

GLAM's public comments on SIP (page 36) - Sept. 2010

Additional GLAM public comments - Posted to the Medford Transcript - "There are still unanswered questions with Green Line" Wed Apr 22, 2009, 01:00 PM EDT

GLAM comments to Citizens Advisory Group (page 85) - August 2008

GLAM urges residents to attend Feb. 27th meeting - Medford Transcript - Feb. 19, 2008

See below the Mitigation Report submitted by GLAM to the Mass. Executive Office of Transportation and to the Medford Mass. City Council on Feb. 25, 2008

PUBLIC COMMENTS ON THE

 

GREEN LINE EXTENSION PROJECT

 

 

 

 

SUBMITTED BY

 

 

GREEN LINE ADVISORY GROUP FOR MEDFORD (GLAM)

Chairperson Carolyn Rosen

c/o 25 Bussell Road

Medford, Mass. 02155

 

 

SUBMITTED TO

 

The Honorable City Council of Medford

Transportation Subcommittee

Medford City Hall

85 George P. Hassett Drive

Medford, Mass. 02155

 

With copies to

 

Katherine Fichter and Stephen Woelfel

Executive Office of Transportation

Office of Transportation Planning

Room 4150

Ten Park Plaza

Boston, Mass. 02116

 

 

 

February 25, 2008

 

 

 

 

 

 

 

 

 

 

EXECUTIVE SUMMARY

 

 

The public comments submitted herein are the observations and input of Green Line Advisory Group for Medford (GLAM) committee members from their attendance at the civic engagement meetings held by the Executive Office of Transportation (EOT) and conducted by its engineering consultants, Vanasse Hangen Brustlin, and its communication consultants, Regina Villa Associates, since mid January. 

 

In this public comment report, we will speak to the lack of adequate outreach to the Medford community, particularly those abutters who will be directly impacted by this proposed transit project.  Based upon the first announcement of the January 23, 2008 meeting by EOT, GLAM members immediately took action together and individually in conveying our dismay directly to Regina Villa Associates and to EOT on the short timespan of public notices and inadequate outreach in our community.  There appeared to be, in our opinion, a seeming favoritism toward the Somerville advocacy community with their meetings placed later in the calendar.  

 

In speaking of the Somerville community, there appears to be a cultural war growing within the Green Line process.  Our members were surprised to find many Somerville and Arlington residents, including members of the Somerville Transportation Equity Partnership (STEP), a public transportation advocacy group, attend station workshop meetings regarding Medford station locations. In comparison, GLAM is neutral on its position of the proposed Green Line Extension.  GLAM does not attend Somerville workshop meetings on purpose since we are only trying to serve Medford.

 

Many of these Somerville residents and Somerville groups conducted lobbying efforts to sway Medford residents on station locations.  At one such “Medford” station workshop, one of our members even recognized a staff member of the Somerville Community Development Department in heated debate with Medford Hillside abutters regarding their concern of eminent domain and traffic issues in the three proposed station sites there.  In the last workshop meeting for the proposed Route 16 Somerville site, Arlington residents also attended to advocate for their ability to access the Green Line through Medford neighborhoods.  If EOT was trying to determine potential neighborhood impacts by learning those issues through Medford abutters and other Medford residents’ experiences, the question becomes how would a Somerville or Arlington resident know of such impacts.  And how did EOT distinguish the Somerville and Arlington resident comments from Medford resident comments unless they truly did not care? 

 

We found EOT’s station proposal workshops less than credible due to their avoidance of specific answers to questions asking for detail around station design, eminent domain, traffic and bridge replacement impact among other issues.  Instead of performing alternative analyses first to determine mitigation and impact issues on the community, studies that would have provided residents key information in making informed decisions, EOT instead chose to sell ideas of station locations leaving one to wonder if these meetings were nothing but to soft/hard sell station locations.  We, in GLAM, support meetings that gather information from the people who will be impacted. General information meetings should not be just to soft/hard sell station sitings to residents.

 

In the case of the Ball Square workshop, they proposed Harvard and Boston Avenue, an intersection with many, obvious mitigation issues.  When community outrage became obvious, EOT quickly backed down on this proposal.  Was this a political ploy on the part of EOT?  That is the question of GLAM members since much of the drawings presented on proposed station locations through the Medford corridor seemed to be drawn to favor the benefit of Somerville and Tufts University, along with transit advocates, while proposing threats to small business and residents homes for Medford.  Now we understand that this proposed station location maybe back on the table.  

 

EOT often contradicted itself in various workshop meetings.  At the general informational meetings and in the first station workshop meeting concerning Ball Square, EOT and the engineering consultants mentioned that they wanted to minimize land taking and disruption to the community around concerns of traffic congestion.  Yet in the Route 16 Somerville station workshop that they held in South Medford they presented engineering drawings that illustrated definite land taking of a gas station and adjacent housing based upon a proposed parking garage that had not been noted before in presentations to the community concerning the Green Line extension.   It should be noted here that the proposed Route 16 Somerville site is beyond the State Implementation Plan (SIP).  Therefore this site has not yet been studied for its feasibility and environmental impacts.   Also, there was no mention of a possible small maintenance facility in the drawings nor were terminuses shown.  These two issues would impact the neighborhood greatly.

 

As noted above, many of the proposed station sites brought forth many obvious issues of concern that caused fear among abutters who live along the proposed corridor.  In Webster’s Dictionary, to mitigate means to “make less serious or severe.”   Therefore, GLAM believes it is paramount that mitigation be brought to bear now in studies regarding the Green Line Extension by the city of Medford to ensure our community is protected and that we are made aware in studies of impact to the community. 

 

As one Medford Green Line Neighborhood Alliance (MGNA) supporter stated to a GLAM member at the Hillside workshop, MGNA does not want mitigate for fear they will not get the Green Line. In EOT’s rush to meet legal mandates and to pacify those external and internal political forces that have only the intent of self-interest, we believe that our city officials need to speak up now to forge mitigation within studies for the protection of Medford residents.

 

Outreach and Public Participation

 

GLAM has been aware for quite some time that many Medford residents are still not aware of the proposed Green Line Extension project and both its positive and negative implications.  Much of this lack of information is due to the poor public notification and outreach done by EOT and its communication’s company on this significant project.   Many of the public meetings held on this project in the past were located in Somerville with little publicity in Medford.

 

This is the same communications company that did the original outreach to Medford in the first go round that was a dismal failure.  We are wondering if something is not awry here.  The public choice theory states that you should have all input, including abutters and their neighbors. 

 

Therefore, GLAM members reacted with great dismay at the short notice EOT provided the Medford community concerning the January 23, 2007 Project General Information meeting.  While Somerville received ample opportunity on upcoming meetings, Medford received less than a week’s public notice in its local newspapers, the Medford Transcript.  We called EOT and wrote public comments to them on our concern that EOT was again showing lack of good faith in educating the Medford public about the Green Line Extension project.  We requested in our comments and phone calls a second meeting in Medford to ensure that there was adequate time for the public to take notice of this project and to arrange their schedules accordingly to attend. 

 

Although we are pleased that at our urging EOT scheduled another Project General Informational meeting in Medford for February 27th at Century Bank, we have found EOT’s public outreach on its meetings, including station workshop meetings, very inadequate.   We have received numerous complaints from abutters that they received flyers at their house the day of a station workshop in their neighborhood.  Some received no flyers at all and only heard of meetings at the last minute through word of mouth from neighbors, friends and through GLAM’s information listing notices.

 

Although a Medford representative of the EOT Advisory committee advised them of these outreach problems, EOT instead bowed to Somerville’s way of doing things.  Then Somerville worked in the background to discredit this advisor, who has been fair and equal in the process.  What is the role of the Advisory Board if not to advise?   Still EOT depends mostly on computer email notices without taking into consideration that there are many people who chose not to or cannot afford Internet access.

 

Is the EOT advisory board only for Somerville, the dominant group?   Why is Somerville afraid of letting Medford have its own public meetings with the majority of Medford residents?  Somerville participants’ acrimonious style in meetings truly gives residents of Medford more of a reason not to go to meetings, thus discouraging public participation.

 

It is apparent from talking to staff at Regina Villa Associates that EOT has put little resources into public notices.  GLAM members suggested to EOT a couple of Advisory meetings back that they should specifically send letters through the mail abutters.  We have seen the City of Medford successfully use this particular method when addressing neighborhood issues within the city. Yet, EOT did not follow through with this recommendation to the best of our knowledge and feedback we have received through the community.

 

In addition, the most recent Transcript edition, there was no notification from EOT regarding the Feb. 27th meeting.  The Transcript is the most widely read paper in the community.  Whether you are a proponent, opponent or neutral on the subject, you should be made aware of public meetings as a citizen of Medford.  GLAM has instead put its own public letters in the paper encouraging all members of the community to attend these meetings.   We hope that we have had some effect in getting the public to these important informational meetings.

 

We recently suggested that EOT’s communication consultants investigate a reverse 911 type system that would allow them to leave phone messages for Medford residents regarding these meetings.  We have been told that EOT is investigating this suggestion, but we fear they have no real intent since notices for the upcoming February 27th meeting have seen even less public outreach.

 

In fact, one of our abutter members who is signed up on EOT’s website recently complained to Regina Villa Associates that EOT’s most recent email notice to her suggests that the meeting is only for those with interest in public transit.  She felt in this way that EOT was downplaying this meeting and indirectly discouraging abutters and other Medford residents whom will be impacted by this project.  

 

The station workshop meetings were disorganized and chaotic in regards to gaining feedback on survey drawings for station locations.  Only those who could push their way through were heard.  In this method, people with disabilities were left out of meeting participation, which was witnessed by a Medford community development staff member.  Residents often had to jostle to get a space at the tables to be heard, often competing with residents from Somerville and Arlington to get their comments heard.  Residents with disabilities could not hear in the rooms nor were they provided a separate table or designated space at the tables provided.  Public address systems are always bad.     

 

Sound systems at the station workshop meetings have been poor.  Both the hearing impaired and non-hearing impaired have had difficulty hearing at these meetings.  This is based on complaints we heard at the meetings and complaints received at these workshops.  Meeting rooms have been inadequate in size.  As one GLAM member was told by a staff member at Regina Villa Associates, they did not expect much participation by the community.  Who were they expecting, public transit riders only?  Or just Somerville since they appear to have done their homework mostly in Somerville in earlier group meetings prior to the station workshop meetings? 

 

 

 


Cultural War

 

GLAM members are aware that MGNA and STEP have been working hand in hand as transit advocates to push the proposed Green Line extension to Route 16 Somerville and that they have a close relationship with EOT officials, often on a first name basis.  This knowledge is based on MGNA meetings that some of us have attended and based on publicly available STEP minutes over the last two years. 

 

But many Medford residents just learning about this project were surprised to find Somerville residents actively participating in the station workshop meetings that were particular to Medford.  In fact, one of our members recognized a staff member of the Somerville Community Development department debating Medford residents who were commenting on consequences they saw in the Hillside proposals.  There also was lobbying of Medford residents by Somerville’s representatives on the EOT Advisory Committee.

 

In one station workshop meeting concerning Route 16 Somerville, there even was Arlington residents in attendance pushing for the Green Line in Medford for access by Arlington. The presence of Arlington residents advocating for a Route 16 Somerville station, especially with the proposal of a parking facility before all meeting attendees without studies that was obviously going to cause land taking of businesses and adjacent housing, gave the impression that Arlington was pushing for park and ride.  Therefore, many Medford residents expressed to GLAM concern that their voices were being negated as they were being told by MGNA members and Somerville and Arlington residents that they must sacrifice their quality of life for the greater good of Somerville and Arlington.

 

The Route 16 workshop was probably the most acrimonious that we attended due to what we would categorize as a cultural war.  Many of the Medford abutters attending this workshop were moderate-income families who were fearful for their homes and property and other impacts of the project.  These moderate-income families included those with disabilities and long time elderly residents who were faced with hostile advocacy tactics by mainly young professionals.  These moderate-income families were also being pressured by outside advocates who seemed insensitive to the fact that EOT had just presented a proposal that represented land takings and displacement, even after being advised by Medford EOT Advisory member, City Councilor Fred Dello Russo, that this was a hot issue.  Both the Mayor of the city of Medford and City Councilors such as Bob Maiocco has stated that land taking is unacceptable.   

 

There is the cultural war of those who trust the government to do the right thing and want the Green Line at any cost to the community versus those who have experienced a less than honest process where station sites proposed on paper actually show up in other areas.   For example, although EOT documents state proposal of a station at Ball Square, they actually propose a station instead at the intersection of Harvard Street and Boston Avenue to prevent construction disruption of Broadway in Somerville.  They propose a station siting across from the Brooking Street to provide access to Tufts while impacting on abutters across the track.   EOT proposes a station at Route 16 with feasibility studies while also proposing a previously unannounced parking facility that obviously requires land taking of businesses and adjacent housing.  This is significant, obvious land taking that in prior workshops EOT consultant’s state they are trying to minimize regarding this public transit project. 

 

No where in the station drawings was there a depiction of the concept of a maintenance site, as referenced in the RFR.  Nor was there the concept of a terminus that would require vehicles to turn around.  The objection was made at the meetings that the drawings were not complete. 

 

It also was objected to that the pollution driven commuter rail was being placed next to the abutters’ homes from College Avenue to Route 16 Somerville where they would be exposed to denser diesel pollution.  EOT could not answer how they were going to minimize the pollution from the commuter and freight trains.  If they cannot find a way to minimize this pollution, then Medford will easily become environmentally overburdened.

 

EOT did not mention that under the New Starts program a maintenance center is required such as in the Haines Square area to provide a base for buses coming from surrounding cities and areas to park, thus creating more pollution.    

 

From an objective point of view, you can see Medford residents’ concerns since it appears that EOT and advocates are protecting large institutions such as Tufts University while working to provide Somerville greater benefit.  These types of issues should be part of the studies in order to provide information based upon facts upon which Medford residents can make decisions before anything is decided.  It is based upon this view that we provide in the next section of our comments the need to begin the study process with EOT so that Medford community is protected from special interests.   

 


Mitigation Issues to Include in Studies

 

Although advocates often use the phrase that Medford residents and abutters must sacrifice for the greater good, the greater good can represent three people or five hundred people.  The greater good is a utilitarian concept that is often subjective with varying degrees of success around social equity.  

 

Unlike Somerville, an urban city which appears to run under an anarchistic form of democracy where special interests are often the squeaky wheel that gets oiled, Medford residents seem to prefer a more representative form of democracy where they expect their elected officials to stay abreast of issues and to protect their broader interests.  GLAM has been pleased that Mayor McGlynn and some city councilors have come forward to publicly speak up for residents concerns and to mention some guiding parameters of support for this project during the last month.  We believe that based upon resident concerns that we are hearing that derive from the recent presentations by EOT that the City of Medford should begin its process of negotiating with the state to ensure that the greater good does not end up representing the few while the many end up with possible severe consequences. 

 

A plan to develop enforceable mitigation commitments to become permit conditions for the project, if and when it is permitted, has never been presented.  GLAM believes that it is important to include in the EOT’s studies mitigation issues up front and that the City of Medford should early on throw in everything including the kitchen sink to protect our citizenry so that the positive impact of public transit can eventually prevail.

 

Studies that include these mitigation issues should consider impacts to neighborhood quality, social interaction, safety and security, and social equity.   With due respect, GLAM offers the following study issues for consideration.  These study issues will include measures associated with the operation of light rail system and its long-term impacts. 

 

Maintenance site

 

First and foremost, we believe the City of Medford should seek in writing a commitment by EOT that they will not locate a maintenance site of any kind within the City of Medford or at Route 16 Somerville at the end of the Green Line.  The Request for Response, which is a contractual bid document released in March 30, 2007, for the Green Line Extension – Conceptual Engineering & Draft Environmental Impact Report, on page 15 of the work order, within Section 3.2.2 called Refine Northern Section (north of Harvard Street). Medford Hillside Alternative and within Section 3.2.3 called Refine Mystic Valley Parkway Alternatives states that the engineering consultants “At the end of the line, identify locations for storage and layover space for Green Line vehicles, a lobby building for MBTA personnel, and parking for supervisory and maintenance vehicles." (We have underlined the word maintenance for emphasis.)  This description as we know is similar to the facility in Haines Square. 

 

EOT in many meetings has tried to confuse the public between a light and heavy maintenance facility often disparaging the public comments around this work order statement.   Although after public outcry EOT has stated that this light maintenance facility is unlikely in Medford since Medford has offered no space at this time, we believe that the City of Medford should get this commitment in writing and have EOT also exclude such a facility at Route 16 Somerville.  Since the proposed Route 16 is in that portion of Somerville that you must get to through Medford, we believe that the City of Medford should get a commitment in writing that no such facility will be placed at Route 16 Somerville or thereabouts as well. 

 

Land Taking in Medford

 

GLAM has taken the public position 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 especially when it appears that many abutters who will be impacted appear to be moderate income and vulnerable populations. 

 

So far EOT has presented station proposals that would require encroachment upon small business in the Harvard Street and Boston Avenue area.  They also have proposed land taking at the corner of Route 16 and Boston Avenue, Somerville, where a gas station, the U-Haul building and adjacent housing are located.  EOT also has inferred that there will be areas of the Hillside and South Medford that will be tight areas along the corridor that may need real estate acquisition. 

 

The City of Medford should require that EOT immediately identify land taking and real estate acquisition needs so that informed decisions can be made around support for this project in the community.  To do otherwise is to put citizens and small business owners in constant fear of losing their homes or business and opens the city to land speculation and destabilization.

 

We recommend that the City of Medford require that EOT contact directly all property owners whose property would be directly affected to answer questions and provide additional information about this proposed project.  We suggest that the City of Medford’s community development department provide oversight of any EOT advisory meetings with abutters to ensure that proper notification occurs and that there is an honest presentation to abutters’ on their rights within this proposed project.

 

Many citizens also have recommended to GLAM that EOT and the City of Medford consider Tuft’s athletic field located just below the College Avenue bridge as a substitute for a Winthrop Street or Brookings Street station.  Many abutters believe that this will preserve the character of their neighborhoods while giving Tufts direct benefit of station access since they appear to be the primary beneficiary of the proposed Green Line extension in the eyes of the abutters.

 

 

Transit impact on abutters by moving commuter rail closer to homes

 

EOT has proposed 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.  EOT has not addressed this critical issue and its possible health affects on abutters such as respiratory illnesses.  The City of Medford should require a permanent solution to this problem before supporting this transit project, such as an electrified commuter rail.   

 

Ridership in Medford

 

Citizens in Medford have been told people in the neighborhood within walking distance of the stations would use the proposed Green Line Extension. Advocates have told residents that stations would not cause parking or traffic problems because local residents would be walking to the proposed Green Line. Supposedly there is to be no need for parking facilities, although EOT has proposed such a facility at Route 16 Somerville.  Many citizens are not convinced of these claims and remain skeptical of these points.

 

GLAM believes that the city of Medford should request that EOT conduct a survey of area Medford residents to determine potential ridership.  The survey should include how many times during the day, week, month or year a resident would use the proposed line.  The ridership survey also should separate out the Tufts College community from community residents within walking distance to see where greater benefit lies.  Such a ridership survey would also determine cost feasibility of the proposed project.     

 

Elimination of Freight Movement in Somerville and its indirect impact on Medford        

 

There possibly will be the elimination of freight rail in parts of Somerville.  As noted in the Metropolitan Planning Organization’s (MPO) planning document and in other research, the elimination of freight rail often has the impact of increased truck traffic in other areas.  Truckers often try to find diverse routes to avoid congested traffic areas.  Because Medford has many routes that essentially allow it to be used as a cross route city, EOT in its study needs to determine any impact on Medford of additional truck traffic if rail freight is eliminated in parts of Somerville.  EOT also needs to determine the additional cost to Massachusetts’s citizens if trucking becomes the prime delivery method for consumer goods since gas prices continue to go unchecked.

 

The city of Medford should be aware that analysis work behind the State Implementation Plan (SIP) used 1963 survey data for truck traffic information for their analysis using factoring methodology that is less than accurate in predicting the future since factoring is based upon assumptions and not current information.  The City of Medford should require a more updated truck traffic study for the Greater Boston area since much growth has occurred in the greater Boston area since the 1960s.

 

Traffic Congestion in South Medford and the Hillside to Route 16, Somerville

 

Although EOT is trying to sell the concept of kiss and ride drop off station locations, many in the community are skeptical of this proposal.  On the other hand many abutters on the Hillside and in South Medford do not want a parking facility in their neighborhood that will draw additional traffic congestion from surrounding areas.  It is important that the City of Medford realize that regarding future traffic congestion EOT can actually drop the responsibility for this condition back into the hands of the city’s by stating that these conditions are not attributable to the proposed Green Line Extension project. 

 

This would mean the city would have no recourse in obtaining EOT’s project funds for corrective action if future traffic congestion actually becomes the problem that abutters and other citizens believe it can cause.  The city needs to mitigate now for up to date studies on existing traffic and parking patterns before the proposed Green Line and then require studies on projected traffic and parking patterns if the Green Line extension is implemented.  In this way, the City of Medford can determine a threshold of attribute if EOT’s projections are wrong and go for recourse of EOT funding. 

 

We recommend then that the city and EOT must work together to determine appropriate traffic controls.  If any proposed station(s) is/are open, the city staff will then monitor all parking and traffic controls during the first five years after the system opens for operation.  If EOT’s implemented controls are found to be insufficient EOT will provide all funds for all corrective action as determined by the City of Medford.

 

Parking

 

      Hide-and-ride impacts may occur in station areas.  Many citizens report to us that they are all ready experiencing this type of parking issues in West Medford around the commuter rail and in the Wellington station area neighborhoods.  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.  Based upon surveys, we recommend that the City of Medford and EOT work with affected neighborhoods to identify and implement appropriate mitigation elements within studies prior to any proposed station openings. 

      Mitigation issues may 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.  For proposed locations where the mitigation is accepted and approved by the City staff and local community and neighborhood groups, EOT would provide funding for implementing appropriate parking controls, labor and all other related installation costs. 

      City staff should 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 fund any expansion of existing or newly created RPZs or other parking controls during the first five years following proposed station openings. 

 

 

Arterials and Local Streets Impact in Medford

 

Congestion – EOT has proposed several station locations at known congested intersections.  The city of Medford should require that EOT add to their cost analysis full costs to improve all intersections impacted based upon peak hour project trips.

 

Sidewalks – EOT should be required to provide ADA accessible sidewalks on proposed station property and immediately adjacent to proposed stations.  Proposed stations should include facilities for bicycle access, circulation and storage.  Proposed stations should provide for safe and effective pedestrian access that would include painted crosswalks and signals, appropriate street lighting, warning lights or signage. 

 

Local schools – There needs to be determination by EOT of traffic impacts on local schools in the proposed area. 

 

NonMotorized Access – The city of Medford should require that EOT include in its studies design features in proposed station locations to accommodate the increase in pedestrians.  Design improvements should include reduced speed limit signs for bicycles, distinctive paving or other improvements to enhance visibility and slow bicycle travel speeds to reduce the likelihood of bicycle/pedestrian collisions.     

 

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 a 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.  The State Shade Tree Law should be investigated as to its pertinence to this 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.  The City of Medford needs to require studies on this mitigation issue and should demand that EOT demonstrate 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, this retaining wall should enhance the character of what is all ready there, not replace it. 

 

Air Quality

 

As EOT has stated at its informational and station workshop meetings, this proposed transit project is about mitigating regional air quality.  The City of Medford should require that EOT provide a stand-alone study of Medford’s current air quality to demonstrate the need for this mitigation project.  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.  

 

Noise and Vibration

 

Noise: The city of Medford should require that EOT provide studies that demonstrate reasonable and feasible noise mitigation to reduce noise levels at properties identified with noise impacts attributed to the proposed Green Line Extension project.  Current noise thresholds should be identified to obtain a current baseline to compare to study projections with the proposed Green Line. 

 

In noise mitigation it is usual for transit agencies to recommend noise barriers along the corridor.  But as we have seen with residents who live along I-93 in Medford, noise barriers can be a long time in coming if not guaranteed at time of study.  The City of Medford should require the consideration of noise barriers in studies along the corridor as a reasonable and feasible form of noise mitigation.  But the City of Medford may also want to be creative and require that EOT pay for sound insulation of impacted structures along the corridor. 

 

The City of Medford should also require in cost analysis that EOT perform an annual noise analysis to ensure that noise levels throughout the neighborhoods and surrounding areas are below the FTA criteria.  The city should require that EOT perform these analyses on a regular basis.  Failure to do so would be subject to monetary penalties that would go to the city of Medford to institute recourse for residents and local businesses.  Other measures that the city should require is that EOT/MBTA perform ongoing maintenance for this proposed project and that EOT/MBTA demonstrate that they can provide adequate funding for this type of maintenance:

 

      Rail grinding and replacement – As rails wear, noise and vibration levels from light rail vehicles can increase.  By grinding down or replacing worn rail, noise and vibration levels can remain at projected levels.  Rail grinding and replacement should occur every three years.

      Wheel Truing and Replacement – Wheel truing is a method of grinding down flat spots (commonly called “wheel flats”) on the light rail vehicle’s wheels.  Flat spots occur primarily because of hard breaking.  When flat spots occur, they can cause increases in both the noise and vibration levels produced by the light rail vehicles.

      Vehicle Maintenance – Performing scheduled and general maintenance on items such as air conditioning units, bearings, wheel skirts, and other mechanical units on the light rail vehicle will help maintain projected levels of noise and vibration. 

      Travel speeds and frequency of trips – Travel speeds and frequency of trips must be identified in studies. Travel speeds to reduce noise and vibration must be analyzed and implemented in any operational plan and drivers must be trained to reduce hard breaking.  Operated speeds must be the same as used in analysis plans or else noise and vibration will increase with additional speed.  Hard braking can cause wheel flats and may also damage track.  There must be recourse of the City of Medford around assessing penalties to the MBTA regarding negligence in maintenance based upon FTA criteria levels. 

 

We cannot stress more that vibration and ground-borne noise impacts must be analyzed early on and acceptable thresholds agreed upon before any plan can be agreed upon. 

 

Vibration: The city of Medford should require that EOT provide reasonable and feasible vibration mitigation to reduce vibration levels at properties identified with vibration impacts attributed to the proposed Green Line Extension project.  Current vibration thresholds should be identified to obtain a current baseline to compare to study projections with the proposed Green Line. 

 

      Reducing train speeds – Train vibration levels are generally reduced at lower train speeds and operating speeds must be lowered as reasonable to meet agreed upon vibration levels.  We suggest that there be a current study incorporated to determine current vibration levels and a survey of abutters who live near the track as to current vibration issues experienced with current housing and business structures.

      Train passby – How does EOT and the MBTA plan to control trains traveling in opposite directions and the increased vibration from a two to four train passbys?  Thresholds of vibration must be studied.

      Rail Straightness – In its studies EOT/MBTA must determine design of vertical undulation and vibration and identify and determine the effectiveness of this level.

 

We suggest the City of Medford require that the EOT/MBTA develop a vibration monitoring system with agreed upon thresholds of vibration based upon residential neighborhoods. The city should require that EOT perform these analyses on a regular basis if the proposed Green Line extension is implemented.  Failure to do so would subject EOT to monetary penalties that would go to the city of Medford to institute recourse for residents and local businesses.

 

Ecosytems (Wetland Impact):

 

It needs to be determined if there is any wetland area and wetland buffers within the areas proposed for the Green Line Extension.  We recommend that EOT work with the city of Medford and its Conservation Commission who has been identifying and protecting wetlands with the city of Medford. 

 

Water Resource Impact at the Mystic River:

 

Best management practices around water quality resources should be incorporated as required to meet applicable city, state and federal standards and requirements.   A study must be done to determined impact from a proposed Route 16, Somerville station.  The city of Medford will want to be assured that the Mystic River, which runs through Medford is not harmed from this proposed project and by possible ground water contamination from light rail trains and additional vehicle traffic.  

 

 

 

 

Geology and Soils as pertains to Medford:

 

Drainage and Stormwater Runoff: Through residents comments it has been identified that there are drainage and storm water runoff problems with the Hillside and in South Medford near the Harvard Street bridge. How does EOT plan to address and correct this issue with the proposed Green Line extension and at whose cost?   This problem needs to be addressed in studies and cost analysis.  

 

Soil testing: We also believe that there should be ground-testing studies performed of soil along the proposed corridor.  For example, creosote, a brownish oily liquid consisting chiefly of aromatic hydrocarbons obtained by distillation of coal tar, is usually used in the preservation of wood such as used for train tracks.  One would assume that this creosote has leaked into the soil over the years of maintenance of the commuter rail.  The city of Medford should have EOT identify through ground testing studies what soil contamination is present, at what levels and its impact in the air due to proposed construction to surrounding neighborhoods and residual long-term impact.  Other contaminates that should be identified is silica dust and pcbs. 

 

Hazardous Material Sites in Medford and at Route 16, Somerville

 

Although one would hope that EOT would try to avoid contaminated sites or portions of sites in identifying proposed routes to minimize encounters with hazardous materials, the city of Medford should require immediate identification of such sites within EOT’s plans in the city of Medford and at Route 16, Somerville.  Encountering hazardous material sites in constructing this proposed route could put neighborhood areas at risk of exposure, as well as, cause potential increase in cost to this project.  The city would want clean up efforts identified prior through studies to avoid potential long-term impacts.    

 

The city of Medford should be alert and protect any properties that may be left with residual contamination in excess of standard levels.  The project cost analysis should include dollars for residual contamination clean up of abutters properties.

 

Electromagnetic Fields due to light rail consumption:

 

Light rail, when electricity generated, uses electromagnetic fields.  The city of Medford should require that the EOT’s study identify if there will be any adverse impacts to human health due to electromagnetic fields. 

 

 

 

 

 

Public Service Safety and Security Plan:

 

The city of Medford 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.  Who will be responsible for emergencies and security issues?  Is the city expected to be the first responders?  Who will pick up this cost? This is a cost issues that needs to be identified within a cost analysis.

 

Utilities:

 

The city of Medford should require that EOT identify in its study the impact to current utility support and consumption not only along the corridor, but impacts to other parts of the city.  As we have experienced in areas such as Medford Square with black outs, there is a frail infrastructure concerning utilities in the city.  Therefore, the city of Medford needs to know who will be ultimately responsible for potential utility problems if this proposed project moves forward and the level of consumption demanded by light rail. 

 

EOT in its proposed design studies should coordinate with utility service providers in identifying impact to utilities during light rail operation throughout the city.  Potential service disruptions should be identified as well as the use of electrical resources that have the potential to impact the whole city. 

 

The report should describe how:

 

      EOT will coordinate the proposed light rail design with local utility providers including relocation of manholes and other access points for ongoing utility maintenance once light rail is in operation.

      EOT will design the system to control stray current to levels where significant damage to metallic utility infrastructure does not occur.  How will EOT replace particularly susceptible metallic utility infrastructure with nonmetallic materials?

      EOT will design the proposed system to reduce the impacts of soil settlement on underground utilities and special infrastructure concerns such as lead joint pipes.  The City of Medford also needs to know who will be responsible for appropriate measures to protect the existing utilities from damage due to settlement or other light rail related construction impacts. 

      EOT needs to identify all substations required and their locations.  Our understanding is that these substations may be located further into neighborhood areas. 

 

 

 

 

Historic and Archaeological Resources:

 

Our understanding from those who have been involved in historical meetings within the city, the proposed stations EOT has proposed north of College Avenue may be in conflict with a recent historical designation of the Middlesex Canal landmark.   This point should be investigated because there may be some adverse impacts to this historical designation.

 

Walking Court Housing:

 

There is concern within the community that EOT has proposed a station at Route 16, Somerville that may have adverse impacts on the Medford public housing known as Walking Court.  This housing contains frail elders and people with disabilities.  The city of Medford should request a study that includes identifying potential impact to this environmental justice population. 

 

Impact issues that GLAM can easily identify from proposed architectural drawings presented at station workshop meetings:

 

      Noise and vibration impacts both in operation and construction of this potential project

      The potential of increased hide and ride parking in this area

      Disturbances by Pedestrians using the Walking Court site to cut through to station locations

 

Terminus:

 

EOT at its station workshops failed to identify terminus impacts on the community at the end of the proposed Green Line Extension although they have stated they are thinking of cross track potential.  As we have researched, a cross over track uses a “frog” (a rail crossing structure) to allow the train to either crossover to another track or continue moving on the same track.  A gap is provided on top of the frog so that vehicle wheels can pass regardless of which track is in use.  Our understanding is that with typical frogs, impact vibration is generated when the wheels pass over the gap.  In a moveable frog, the gap is eliminated and one end of the frog moves in the direction of the train travel, thereby, reducing the vibration associated with the wheel impact.  The city of Medford needs to be sure these types of designs are included in any design study plans by EOT to minimize potential impacts. 

 

If EOT/MBTA chooses instead to plan for a traditional terminus, the city of Medford certainly needs to understand the full impact of this design in any study as it has the potential for more land taking, noise and vibration impacts in the community. 

 

 

Bridge Replacement:

 

The city of Medford should require that in studies EOT early on identify proposed bridge replacements and bridge construction requirements.  Bridge replacements have enormous impact on the city and immediate impacts on abutters and small businesses in the area.  Traffic congestion during bridge replacement can impact areas far outside of the immediate construction area, especially if there is construction on several bridges at one time in the area. 

 

Bus Routes in Medford:

 

The city of Medford should require that studies identify any disruption in bus service and planned changes in bus service routes based on alternative analysis. 

 

Although advocates often use poor bus service as their reason for supporting the proposed Green Line Extension, we actually have had abutters/riders approach GLAM that they prefer their efficient bus service along this route to the Green Line.  Some abutter/riders have commented that the Green Line would actually increase their commuter time due to its well-known poor service and that it provides a less direct route to their destinations. 

 

We believe that study should be done on destination points of bus ridership to ensure that we are not actually impacting on the use of public transportation and forcing current bus riders to be forced to use their vehicles.

 

Disability Access:

 

Disability Access to public transportation is an important issue for GLAM as an organization since we have many of the Medford disability community in our membership.  Currently there are still Green Line stops that are not disability accessible such as Symphony Hall and Boylston Station.   Although there is a MBTA lawsuit settlement with the disability community to make stations accessible, we have found that the MBTA may have a choice of which old stations they will reconstruct for disability access.

 

The Americans with Disabilities Act (ADA) must be adhered to in all phases of this proposed Green Line project and the MBTA must adhere in providing equal access to people with disabilities.  That EOT plans to spend billions of dollars on this proposed project while people with disabilities still cannot access all stations on the Green Line is a tragic human rights violation. 

 

The city of Medford under its Human Rights Commission should require that all stations on the Green Line should be accessible before any ground breaking on a proposed Green Line extension project.  Are citizens expected to board a Green Line train in Medford only to find themselves in Boston with no accessibility?  This is a civil rights violation of enormous consequences. 

The city of Medford should require that EOT and the MBTA demonstrate in their cost analysis how and when they will accomplish the accessibility of all stations on the Green Line.  If the MBTA has decided to only remodel certain old stations for accessibility purposes, then the city of Medford should demand to know what dedicated accessibility services they will provide for people of disabilities at inaccessible sites.

 

Needless to say, any potential new stations must be accessible.  To not do so opens the MBTA and EOT up to potential legal lawsuits. 

 

GLAM has researched transit facility design ADA checklists that are too numerous to mention in this report.  But we will be watching closely the design of any potential new stations to ensure that ADA accessibility is incorporated to its fullest magnitude to accommodate the disability community of Medford.  We anticipate that the city of Medford will do so as well. 

 

Tunneling and Other Alternative Provisos:

 

Requiring EOT to study other alternatives such as tunneling may eliminate some mitigation issues, such as land taking, noise and air pollution.  Tunneling has occurred in other transit projects in the Commonwealth to avoid lengthy mitigation remedies.  We suggest that the city of Medford ask for such an Alternative Study since tunneling seems to have support within the community.   Since the proposed Green Line extension project is about mitigating air quality from impacts of the Big Dig, residents need to be assured that the best environmental alternatives are being studied. 

 

GLAM also has put forth an alternative study to EOT to ensure that the best environmental benefits are being realized. 

  

MBTA Assessment fees and other costs:

 

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 the neighborhoods so that deep bonds of commitment to the community can be developed through family and social organizational ties.  We believe the city should be cautious concerning the proposed Green Line Extension project and Smart Growth. 

 

Many advocates and new residents have spoken of their desire for Medford to have destination points like Davis Square, Somerville.  Others have publicly spoken of the economic boom they saw in Davis Square and Porter Square while living in those areas. It makes one wonder why these folks are not still living in those areas.     

 

The answer may lie in a recent University of New Hampshire study concerning income inequality in the New England area.  The Cities of Somerville and Boston are prominent in this study as two top cities of income inequality, essentially pushing out their middle class due to the lack of affordable housing and high cost of living. 

 

So the question becomes, who benefited from the economic development in the surrounding areas, development as supported by Green Line advocates?  While universities like Harvard University dominate cities like Cambridge and take over cities like Allston/Brighton and Tufts University dominates the Somerville landscape, cities in the Boston area have become an area of “boutique” cities with “boutique” economic sectors that offers economic opportunities for far too little of the general working population.  

 

As part of GLAM’s principles and objectives, we believe the city of Medford should challenge conventional wisdom around the economic theory called university expansionism.    As we have stated before in this report, 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.  As witnessed at a station workshop on the proposed Lowell Street and Harvard Street stations, one Somerville resident spoke of his knowledge that his neighbors, abutters to this project, were selling their homes for fear of the impact of the proposed Green Line extension project.   There have been news articles on real estate speculation in Somerville particularly around the Max Pax site as developers push a high-density project on residential neighborhoods of long time moderate-income residents. 

 

Historical Sociological Study on Demographic Changes: To understand the true socioeconomic impact of projects such as the Green Line extension, we believe that you must go back and study history to understand how we have come to this place of economic inequality in Massachusetts.  Therefore, we believe that there should be a sociological study based in historical demographics on areas such as Davis Square and Porter Square, Somerville to determine and document the impact on the Somerville community of the Red Line.  This study would analyze the socioeconomic impact on populations that were present before development of the Red Line and then the socioeconomic populations that developed after the Red Line based on the social policies implemented in economic development that were tied to that public transit project.  And is it really as good a benefit or is the New Hampshire study more accurate in its assessment?  We believe that such a study would benefit the city of Medford in determining whether its wants such a proposed transit project in our city as we learn from the mistakes of Somerville.

 

 

 

 

 

 


Conclusion:

 

In conclusion, we believe that it is the best interest of the city of Medford to now take a prominent role in pushing for studies on the Green Line Extension extension before a decision is made about this proposed transit oriented project without Medford input. To do otherwise, we believe will allow EOT to permit Somerville and Arlington to dominate the destiny of our city without benefit of public choice.

 

Some people feel this proposed project is a done deal.  This project is only in the study stages.  The economy of the Commonwealth does not merit a proposed Green Line Extension project that will only benefit the University of New Hampshire study conclusions.  There must be more merit to this project that benefits all peoples than a certain group of people in Somerville. 

 

That is why GLAM is requesting scientific studies that take into account all socioeconomic implications of the cities.  We believe if cities like Waltham, Stoneham and Woburn recognize the financial burden we are putting on them regarding this proposed project, either by bonding or assessment fees, this project will be easily nullified by those more interested in the tax rate issue.

 

As we stated earlier in this report, Medford citizens expect their city officials to represent their best interest.  Best interest can only be determined by scientific studies that are performed with accurate modeling using current data.  Best interest is requiring that EOT study all alternatives to determine that the eventual proposed routes provide the most environment benefit to our area.  That is why GLAM has proposed an alternative study to EOT as well to ensure that Medford is not being asked to take on other cities environmental burden without opportunity of equal environmental benefit.

 

In many comments we have received from the public and GLAM has discussed at its organizational meetings, one question arises.  With the multi million-dollar deficit of the MBTA and the billion-dollar deficit of the Commonwealth, is it financially viable to do this project?  Floating bonds to finance this project only causes more debt service and corresponding interest payments for the Commonwealth?  What impact would this project have on local aid if tax revenues have to be diverted to cover debt service?  What of other priorities such as infrastructure issues such as roads, highways and bridges? 

 

GLAM and many Medford residents have found that by asking critical questions like these about this project, you expose yourself to personal attacks and character assassination by the transit advocacy community who would move this project forward without benefit of mitigation and studies.   We hope that like GLAM, the city of Medford will stand tall to ensure true independent, scientific studies are performed so that informed decisions can be made and consensus eventually reached within the community.