PUBLIC COMMENTS ON
FTA Docket Number: FTA-2010-0009
Federal Transit Administration's (FTA) New Starts and Small Starts Project
GREEN LINE ADVISORY GROUP FOR MEDFORD (GLAM)
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
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 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
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