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Below are Point and Counterpoint comments sent to the FTA regarding changes in New Start funding regulations.  GLAM's public comments are also included below.

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Mass DOT Public Comments on Advance Proposed Rulemaking - August 2, 2010

CATO Institute Public Comments on Advanced Notice of Rulemaking - July 15, 2010


FTA Docket Number: FTA-2010-0009

Federal Transit Administration's (FTA) New Starts and Small Starts Project


Carolyn Rosen



C/o 25 Bussell Road

Medford, Mass. 02155


U.S. Department of Transportation

1200 New Jersey Avenue, SE

Docket Operations, M-30

West Building Ground Floor

Room W12-140

Washington, D.C. 20590-0001

July 27, 2010

The public comments submitted herein on Docket number: FTA-2010-0009 arethe observations and input of the Green Line Advisory Group for Medford (GLAM). GLAM Is a grassroots community group representing the environmental justice and disability community, as well as, other abutters and concerned citizens of Medford, Massachusetts. Our mission is to educate the Medford public on the proposed Green Line Extension to Medford Hillside and to work to ensure that all community voices are heard in all its diversity.

Our public comments on proposed changes in New Starts and Small Starts are based upon our observations and experiences in the proposed Green Line Extension process.

Cost Effectiveness

Cost effectiveness methodology should include a debt service analysis of a Transit Authority's ability to take on additional debt service required by a match with FTA New Starts and Small Starts. For example, the Governor of Massachusetts commissioned an independent report on the financial status of the MBTA, who will be operating the expansion of the proposed Green Line here in Massachusetts. It is called the D'Alessandro Report. 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 you can see this report recommended slow down of expansion of the MBTA transit system until long term financial strategies could be put in place to reduce debt upon the agency and it could catch up with system maintenance back log, a public safety situation. Therefore, we recommend that the cost analysis of a project should include a more rounded view of an agency's financial condition. There should be a balance sheet review of an agency if you wish to call it that.

Reports such as the D'Alesandro report in Massachusetts should be required disclosure in any public transit submission for FTA funding and New Starts and Small Starts. Projects should not be looked at in isolation, but within the full financial health of an agency proposing the project. When an agency cannot support its current infrastructure, it can put stress on the system that in turn impacts ridership numbers. Poor customer service due to daily maintenance problems will negatively impact support for public transit.

Cost effectiveness should include implementation costs such as direct capital, annual operating, mitigation costs, maintenance costs and administrative costs. Each cost should have their individual line item so as to be separated out in a comparative cost benefit analysis based upon ridership. Cost effectiveness should include social welfare costs associated with each strategy. For example, what is the mitigation impact of each transit project from a job loss perspective, housing affordability, and displacement of populations such as small businesses, moderate to low income populations such as the environmental justice and disability populations.

Social welfare should include specific identification of job needs in the residential area in which a transit project will be entering. Labor reports will provide accurate information on job development needs so that development is based upon the population in resident now in all its diversity. A transit authority should not be allowed to state a project benefits the environmental justice and disability population with jobs and access without proven statistical reports. It should be able to demonstrate through statistics job development needs and demonstrate concretely how it will address these needs within the project.

A transit authority should be required to partner with the state's Dept. of Labor regarding analysis of increase job development. If jobs are identified as being lost to the public as a whole and to the environmental justice and disability population specifically, the transit authority and the state must demonstrate how and where those business will be relocated or jobs replaced before New Starts funding can be considered. Measuring job loss to a city's total population is not an efficient measurement of social impact to a community as a whole or to the environmental justice or disability population. These latter groups experience in both good and bad economic times higher unemployment than the rest of the population. A transit authority must determine how to relieve this undue environmental burden.

When a transit project crosses multiple cities, there should be a separate cost effectiveness analysis for each city regarding the project as pertains to ridership and other benefits. For example one city's ridership numbers should not be used to falsely increase or disguise the lack of ridership in another city. This level of cost detail would determine if taxpayer money were being used to the best cost benefit.

Baseline alternatives should still be used to determine cost benefit analysis. Otherwise the FTA is just basing its analysis on theoretical assumptions of those proposing projects.

Our environmental advisor. Dr. Mariene Warner, (1) points out to us in her review of Mass DOT studies on the proposed Green Line Extension, the use of numbers, lots of numbers by Mass DOT which 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. We agree that a cost benefit analysis should be able to articulate cleariy probable socio economic outcomes to the public and the FTA.

Cost benefit analysis should demonstrate that the community who currently lives in the vicinity will benefit from easy access to public transit and not be displaced by the project due to high end land use development strategies. Planning has a tendency to be based in middle class cultural biases and based in future populations. Therefore when dealing with environmental justice and disability populations or working class neighborhoods, it is important to ensure their involvement in public participation consideration.

The environmental justice and disability community voices are often left off citizen advisory participation and workshops. Their public transit and economic needs are left out due to professional planners, paid or volunteer, who have atendency to impose their preconceived middle class views on these cultural groups. Planning groups many times funded by federal agencies under technical service grants often subvert the local community's desires and wishes around public transit and land development. Throwing money at "front" groups to help transit agencies state to the FTA it has community support does not bring consensus to a community. Instead this type of process brings resentment of the government's top down planning process or as we call a paternalistic imposed view of how and where people should live.

We believe the FTA should measure the benefits of projects based upon current conditions, using the opening year of the project. For example, in the air quality study concerning the proposed Green Line Extension to Medford the analysts considered a 20-year forecast that is based upon the number of alternative energy cars on the road anticipated in 20 years. This assumption provides better air quality numbers than current conditions of the project with inclusion of the proposed new transit project. In the meantime as we understand it, the air quality for the project as it now stands would not be much improved based on current usage of older cars that people will hold to longer due to the

' Dr. Warner is a retired professor of Cell Biology and Ot)stetrics/ Gynecology and Interdisciplinary studies. Dr. Warner is a fomner Dean of Baylor College and also has taught at Union institute in Cindnnati. 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 sutxjivision. 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 trasis for cancer causation. She was the first woman to participate with NASA in putting a biological project in space.

economic downturn. We do not believe that theoretical assumptions based in a 20-year forecast viable because of too many variables. In the case of the Green Line Extension, by not doing the build alternative, you would still see similar regional air quality benefits over the years with just a gradual transfer to more cost effective alternative energy cars once the recession is over. The question becomes then why spend the money on the build alternative if the air quality will be similar on its own in a few years. Our assumption is just as good as the governmental assumption. The future is unpredictable. The forecast year should be the here and now. Look at the benefits now, not for a generation in the futurewho may want something different by that time.

Environmental Benefits

Environmental benefits should not be considered on a regional basis, but on a local area basis. In the case of the proposed Green Line Extension to Medford there is identified in the Draft Environmental Impact Report the issue of increased air pollution in some areas of the corridor. Of course, the transit authority has refused to identify where these areas are at this time. It is quite clear to many in the Medford community that they may be sacrificed with a large environmental undue burden to their community than in the public relations of a region. By working on local environmental benefits to assure that the project is a shared benefit is important. Otherwise the environmental issue is seen as nothing more than political rhetoric without real substance and defeats the purpose of environmental education.

Environmental benefit should include the whole environmental scope of a project, not just the transit project. For example we have a university that is noted in environmental climate reports as the top polluter in our city. It is a direct abutter to the transit project. Yet their smokestack has not been addressed in reducing greenhouse gas emissions in the area. These specific environmental issues should be included in the project's scope.

In the case of the proposed Green Line extension, the Mass DOT repeatedly tries to say that the moving of a diesel commuter train closer to abutters' homes is not within the scope of their project. Yet the commuter train is only being moved due to the impact of the proposed Green Line extension. There is a California EPA study that speaks to the negative health impacts of diesel particulate matter upon the public who resides near transit. This study speaks to premature death caused by diesel particulate regarding heart problems and respiratory illness. These negative environmental impacts particulariy affect the environmental justice community, the disability and elderly populations and young children. There also has been a New York study that points to the same issue. Therefore, we support the California EPA's call to separate out diesel particulate matter from regular air ambient quality studies and so does our air quality control expert. Dr. Mariene Warner. Diesel particulate matter can affect a population from 1-3 miles out.  Environmental health studies are important in any transit project and should be a required part of the New Starts criteria. Diesel particulate matter impacts should be separate from ambient particulate matter pollution as recommended by the California EPA Air Resource Board and supported by other environmental scientists. 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 on transit areas over time and separate for age and race. This is a basic and fundamental need that we believe should be required criteria in FTA funding of New Starts and Small Starts, environmental health studies.

We also believe that a transit authority should complete more than 10% of environmental studies before any project is submitted to FTA New Starts or Small Starts for funding. Such a small percentage of studies completed do not give a clear environmental picture of a project.

As stated above concerning health studies, we believe that the FTA should take into consideration both the human and natural environment. This keeps the proposed project consistent with National EPA standards.

We adamantly oppose a transit project being evaluated and rated on how well it maximizes the land use efficiencies created through locating the project in areas that facilitate sustainable development. Although we believe fully in sustainable job development, we believe that adding this criteria to the FTA funding of New Starts and Small Starts sets a negative dynamic in place on the state and local level. This criteria puts real estate speculation into play and allows the transit agency to play off this pressure by undermining the local community planning process. We are seeing this process being used in the proposed Green Line Extension at this time. This speculation causes destabitization of neighborhoods as people move out in fear of mitigation impacts to their property. This is true especially when the transit authority is allowed to present only 10% of studies and isolates mitigation specifically to influential business and universities while leaving out dialogue with local residents and small business who have similar environmental impact.

We also believe that the word "blighted" should be defined in land use development so that it is not exploited. HUD defines blighted as a dilapidatedproperty that is a public safety issue. But blighted is often used by planners to eliminate modest housing of working class neighborhoods or those of the environmental justice and disability community. This is an important issue to address.

We have found that adding land efficiency criteria allows the transit authorities to divert public relations focus to station designs and land use, favoring transit advocates, while marginalizing impacts to the environmental justice and disabilitypopulation. These communities than become under threat of gentrification, as demonstrated in other historical projects such as the Red Line to Davis Square in the late 1980's and the ensuing gentrification in the 1990's. Reconnecting America documented this historical socio economic change to a neighborhood in a report. These are historical information that the FTA should take into consideration.

Sustainable development has become in the case of the proposed Green Line Extension a regional issue where someone's home or business is open to threat of eminent domain/land acquisition as citizen planners present land use design plans without input from the majority of the local community's citizens. This is especially true when taking into consideration of the environmental justice or disability community. The transit authority than manipulates this situation for their own agenda in obtaining FTA funding under New Starts and Small Starts.

Environmental justice becomes an abused term as developers and planners justify their actions as supposedly helping these populations while actually displacing these populations. Then there are promises of land value increases to real estate speculators. The environmental justice and disability owners then lose equity In existing housing under the concept of "blight." A materialistic philosophy as opposed to a humanistic one. By controlling this speculative scenario, the environmental justice and disability owners can keep their homes and grow equity through natural change and not lose it through forced,manipulative change upon a community.

Smart Growth has become a euphemism for high-end luxury development. We believe that transit development that crosses city lines should be address with each city individually. In the case of a city such as Medford Massachusetts, it is a lower density city that is mixture of professional and working class with a historical African American community that is one of the oldest in the country. It is a livable, walkable community and the majority of homes are owned by its residents. This is unlike the characteristics of the other two cities involved in the proposed Green Line Extension project.

Sustainable development must provide diverse jobs and opportunities. It cannot be focused on one industry. It must provide shared opportunities. The FTA should not be in the business of economic development. It should be in the business of providing easy and affordable access to public transit.

We believe that civil rights issues are paramount in consideration of providing funding under FTA New Starts and Small Start. That is why we believe that the FTA New Starts and Small Starts criteria should require evidence of diverse citizen participation. FTA should require to see a public involvement plan that shows evidence of this diversity. This evidence should include equal representation on transit citizens advisory groups of the authentic voice of the environmental justice and disability community. The Americans with Disabilities Act should be another human condition whereas this community is represented in authentic voice and not by surrogates that the transit authority appoints.

In regards to any application for FTA New Starts and Small Starts funding, the FTA should inquire of its civil rights division as to complaints filed concerning the project and a review of the track record of the Transit authority's ability in providing consistent equal access to public transit. The ability to provide equal access should be addressed before any funding application Is awarded.

We submit these comments respectively to the FTA from a grassroots citizen's point of view. We believe that any transit project only improves when there is skepticism and constructive criticism of processes that due not provide a more democratic process that encourages the use of public transit.

Sincerely yours,

Carolyn Rosen


Green Line Advisory Committee for Medford.