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Testimony of Franklyn P. Salimbene, Chair, Arborway Committee, before the Massachusetts Department of Environmental Protection regarding EOTC's Petition for Substituting 310 CMR 7.36 (2)(d) Introduction Upon request made in October, 1997, by the Executive Office of Transportation and Construction (EOTC), an implementation extension was granted by DEP to December 31, 1998. On January 7, 1999, EOTC made the further request that DEP allow it to substitute Green Line Arborway Restoration with an articulated compressed natural gas bus service. EOTC has submitted to DEP the 1999 LS Transit Systems (LSTS) Arborway Report and other documents to support this request. A request to substitute a project must comply with 310 CMR 7.36 (4), in that EOTC "must demonstrate to the Department that a specific project listed in 310 CMR 7.36 is infeasible due to associated adverse engineering, environmental or economic impacts." The burden is on EOTC to prove that the "specific project listed" is infeasible on the basis of these criteria. It is the view of the Arborway Committee that EOTC in its January 1999 submittal to DEP has not demonstrated that the "specific project listed" is infeasible. The request should be denied. I. EOTC has not demonstrated that Green Line Arborway Restoration, the specific project listed in 310 CMR 7.36 (2)(d), is infeasible. Without a showing of infeasibility, DEP is bound by its own regulations to deny the petition for a substitute project. The specific project listed in 7.36 (2)(d) is "Green Line Arborway Restoration." The language of the regulation is clear and unambiguous. It requires "restoration." The accepted and indisputable meaning of "restoration" is the "return of something to a former condition" (Webster's Encyclopedic Unabridged Dictionary), to "bring back to original state" (The Concise Oxford Dictionary). As the specific project listed in 7.36 (2)(d), returning the Arborway Green Line to its "former condition" requires "bringing back" the essential components of Arborway Green Line service as it existed prior to its suspension in 1985. The essential components of any transit service include the type of transit vehicle used, the route that vehicle follows, and the frequency of the service provided. For instance, assume that the Red Line were suspended. What would constitute a restored Red Line? No one would agree that running a bus at 30-minute intervals only from Ashmont to Andrew Square, the Dorchester portion of the line, would constitute restored Red Line service. People would rightly expect that restoring the Red Line would require running rail vehicles from Ashmont and from Braintree all the way to Alewife according to the former service schedule. In the same way, a restored Arborway Green Line requires reference back to the type and level of service that existed prior to its suspension in 1985. That service was a light rail service from Arborway to Park Street at 6-minute peak headways. This is the "specific project listed" in 310 CMR 7.36 (2)(d). The language of the regulation is clear. "Restoration" can have only one meaning. Further, and most significantly, it is only the specific project listed that can be the basis upon which a determination of infeasiblity is to be made. "To replace a project EOTC must demonstrate to the Department that a specific project listed in 310 CMR 7.36 is infeasible…." [310 CMR 7.36 (4)] Thus, a request for a substitute project to replace the specific project listed must show the infeasibility of running light rail service from Arborway to Park Street at 6-minute peak headways. Also, it follows that any proposed substitute project must be measured against the performance of the specific project listed. To do otherwise would make the "specific project listed" irrelevant to the substitution process. Yet, this is exactly what EOTC attempts to do. A review of its submittal and the accompanying LSTS Report shows that the specific project listed is not used as the measure of the infeasibility of Green Line Arborway Restoration. Further, the specific project listed is not used as the standard against which the performance of the proposed substitute is measured. Instead, EOTC disregards the specific project listed in all of its analysis. First, EOTC misrepresents the specific project listed as light rail service from Arborway to Copley Square. As stated in the LSTS Report, "To facilitate comparison to today's services, as well as to a number of alternatives, the light rail service is defined as the Green Line between Arborway/Forest Hills and Copley" (p. 22). Such a route, however, cannot constitute "Green Line Arborway Restoration" because the historical route of the Arborway line was from Arborway to Park Street. "Until October, 1985, Arborway transit service was provided between Forest Hills and Park Street in Downtown Boston along the MBTA's 'E' line of the Green Line light rail system." (MBTA Arborway Transit Study, December 1987, p. 5, included as Appendix 1 of this testimony; see also the service schedule in Appendix 2) EOTC, however, disregards the historical route of Arborway service. Instead, it redefines the specific project listed as service from Arborway to Copley Square and then analyzes the alternatives on the basis of its own redefinition. By so redefining the "specific project listed," EOTC has effectively amended 310 CMR 7.36 (2)(d) to suit its purposes. Second, EOTC increases peak headways from the 6-minute service that existed in 1985 to 8-minutes. As LSTS notes, "Headways would range from eight minutes in the morning peak to ten minutes after 9:00 p.m." (LSTS, p. 22) Operating Arborway Green Line service at 8-minute headways, however, does not constitute a "restored" Green Line. The published service schedule for 1985, the last year during which the Arborway Green Line operated, indicates that peak service ran at headways of "7 minutes or less." (Appendix 2, service schedule) In an attempt to quantify the meaning of a "7 minutes or less" headway, the 1987 MBTA Arborway Transit Study (hereinafter 1987 Study) concluded that Arborway Green Line service operated "at 6-minute headways in peak periods." (Appendix 1, p. 5) The reason given by EOTC for its redefinition of the "specific project listed" is its desire "to maintain a valid comparison with the bus option." (LSTS, p. 22) Here again as already noted, however, EOTC cannot set up the bus alternative as the standard of measurement against which the specific project listed is judged. Rather, the regulation requires that the specific project listed be the standard of measurement against which the bus alternative is to be judged. While I will leave it to others to speculate as to EOTC's motives in attempting to redefine Green Line Arborway Restoration, the ultimate effect of its redefinition is a significant impact on ridership, costs, and ultimately environmental benefit to the detriment of the specific project listed. For instance, no one would dispute that a less frequent service loses riders. The LSTS Report admits as much, "More people would be expected to choose bus service…due to the bus service's shorter headways…." (LSTS, p. 27) So by increasing light rail headways to 8 minutes and measuring those against 4-minute bus headways, the impact on ridership is a foregone conclusion.
In the 1987 Study, EOTC actually did measure 4-minute bus headways against 6-minute headways for light rail with far different results from those shown in the LSTS Report. The 1987 Study found that light rail operating at 6-minute headways would carry 1,120 more daily riders than the bus operating at 4-minute headways. (Appendix 1, p. 41) This is a significant finding, yet EOTC's 1999 submittal ignores it. There is also a link between ridership and EOTC's attempt to redefine Green Line Arborway Restoration as having a Copley Square terminus instead of a Park Street terminus. In the 1987 Study it was noted that "streetcars provide a one-seat ride with no transfer required to downtown destinations served by the Green Line up to Park Street. A trip to these destinations via the Route 39 bus, on the other hand, requires a transfer from the bus to the Green Line at Copley Station. The time involved in making this transfer can be significant." (Appendix 1, p. 10) The effect of this transfer requirement and the resultant additional travel time acts as a deterrent to ridership. Thus, the 1987 Study concluded: "Only restoration of streetcar service to Arborway/Forest Hills…results in new transit ridership. All other alternatives would result in net decreases in transit ridership since all alternatives other than this alternative involve longer travel times and require additional transfers between bus and streetcar. As a result many of the former Arborway riders would be diverted to the Orange Line or to the automobile." (Appendix 1, p. 3) In preparing its submittal, EOTC knew that requiring a transfer from bus to subway to get to Park Street as a final destination would not compare favorably in terms of ridership against an Arborway Green Line service that required no transfer to get to Park Street. So it redefined the specific project listed as terminating at Copley Square and, in so doing, eliminated the need to account in its submittal for the adverse impact on ridership that would attach to its preferred bus alternative. What is the impact of the transfer requirement on the preferred alternative's ridership? EOTC does not answer this in its submittal. In addition to bloating the ridership statistics for EOTC's preferred bus alternative, changing the actual destination of Arborway service from Park Street to Copley Square has the effect of showing a lower operating cost for the preferred bus alternative in comparison to Green Line restoration. For instance, if the final destination of Arborway service is Park Street, and if the Arborway bus service only runs to Copley Square, then EOTC would have to calculate the added cost of moving Arborway bus passengers onward to Park Street, the route's final destination. That added cost would have to be attributed to the operation of EOTC's preferred bus alternative since the bus would not serve the entire route. What would that cost be? The LSTS Report states, "Approximately 21% of Route 39 customers transfer to rapid transit at Copley, where they represent approximately 25% of Copley boardings." (LSTS, p. 16) If, as EOTC estimates, current daily Route 39 ridership is 19,500, then 4,095 daily riders need to be transported from Copley to Park Street. What is EOTC's operating cost for moving 4,095 riders daily from Copley to a Park Street terminus? EOTC does not account for this in its submittal. The foregoing discussion confirms that EOTC has not met its burden of demonstrating the infeasibility of Green Line Arborway Restoration. There is no measurement of any of the proposed alternatives against Green Line service from Arborway to Park Street, the historical route of Arborway service. There is no measurement of any of the proposed alternatives against a 6-minute peak headway light rail service, the service that existed when the Arborway Green Line last operated. Simply put, EOTC provides no analysis of the specific project listed in 310 CMR 7.36 (2)(d). Not having analyzed the specific project listed and, therefore, not having demonstrated its infeasibility as required by 310 CMR 7.36 (4), EOTC's petition for a substitute proposal must be denied by DEP. If DEP were to allow the substitute proposal on the basis of this record, which does not show the infeasibility of the specific project listed in 310 CMR 7.36 (2)(d), it would be an act beyond the scope of DEP's regulatory authority.
II. In addition to failing in its submittal to demonstrate the infeasibility of Green Line Arborway Restoration, EOTC's submittal also fails generally to provide DEP with the level of reliable information necessary upon which to make any decision other than denial of the petition. The following commentary will demonstrate the unreliability of the EOTC submittal from two perspectives. The first perspective relates to the context in which the LSTS Report was undertaken. The second relates to specific instances, beyond those already outlined above, in which the EOTC submittal provides inaccurate, misleading, incomplete, and even irrelevant information.
EOTC's decision to substitute Arborway Green Line service with compressed natural gas (CNG) buses was made long before the LSTS Report was undertaken. In October, 1997, then Secretary of EOTC Patrick Moynihan announced that Arborway service would be run with CNG buses, not light rail. (Appendix 3, Jamaica Plain Gazette, October 24, 1997) This CNG service announcement was made at the same time that EOTC was telling DEP something quite different in its request for an extension in the deadline for restoring Arborway Green Line service. (Appendix 4, EOTC letter, October 31, 1997) Viewed in this context, the goal of the LSTS Report becomes clear, i.e., prove that articulated compressed natural gas bus service is the preferred alternative to Green Line Arborway Restoration. Thus, the LSTS Report casts aside objectivity in an effort to support a predetermined outcome.
B. The LSTS Report is unreliable because it misrepresents the results of the full public process undertaken in the community following the suspension of Green Line service. The LSTS Report would lead one to believe that EOTC's decision to substitute a bus alternative for Arborway Green Line service was made as part of a public process. (LSTS, p. 6) This is untrue. LSTS references the Arborway Advisory Committee (AAC) and the 40 meetings held between the MBTA and AAC since 1986. The fact is, however, that these meetings and the public process relating to them resulted in a decision to restore Arborway Green Line service. In its submittal EOTC seeks to rewrite history in order to justify its preferred alternative. The public process began in 1986 with a non-binding referendum question on the November ballot asking Jamaica Plain voters whether they wanted restoration of Green Line service. By a two-thirds vote they said that they did. (Appendix 5, 1986 referendum results) Following this vote, numerous public meetings were held between 1986 and 1988 with EOTC's consultants on the Arborway project, Tippetts, Abbett, McCarthy, Stratton (TAMS). These meetings, often chaired by State Representative John McDonough, resulted in the 1987 Arborway Transit Study, which is referred to throughout this testimony. (Appendix 1) A full public hearing was held in January, 1988, at Jamaica Plain High School; the hearing recorded overwhelming support for Green Line restoration. (Appendix 6, Jamaica Plain Citizen, January 21, 1988) Subsequent to these events, the Jamaica Plain Massachusetts legislative delegation negotiated a "formal agreement" with the MBTA and the City of Boston to restore the Arborway Green Line. An MBTA press release of November 14, 1990, made the agreement public. (Appendix 7, press release) As part of the agreement, EOTC established the Arborway Advisory Committee as a community consultative body on Arborway Green Line restoration. In 1991, as part of the public process, DEP promulgated 310 CMR 7.36 (2)(d) mandating Green Line Arborway Restoration. Finally, in 1996, the Jamaica Plain Neighborhood Council reopened the restoration issue. It conducted a series of public meetings to gauge community sentiment. As a result of these meetings, the Neighborhood Council reaffirmed its support for Green Line Arborway Restoration by a vote of 13-1-1. (Jamaica Plain Gazette, November 1, 1996) Nevertheless, sometime during the period between 1993 and 1996, EOTC decided to discard its agreement to restore the Arborway Green Line and abandon the service. As a result, AAC meetings were suspended. In fact, between September 1994 and March 1999, AAC has met only once. That meeting, held in January, 1996, took place only because of repeated requests to EOTC by members of the AAC to convene a meeting. (Appendix 8, letter, December 2, 1995) Further, the January 1996 meeting was limited by the MBTA to addressing the issue of poor transit service along Huntington Avenue and on the Route 39 Arborway to Copley bus. MBTA officials refused requests to discuss the matter of Arborway restoration or any alternatives at that meeting. (Appendix 9, January 1996 meeting agenda) Thus, with the exception of one public meeting in 1996, every one of the other 39 meetings referred to by LSTS took place between 1986 and 1994 either as part of the original Arborway Transit Study or under the "formal agreement" to restore Arborway Green Line service. This is the public process to which the LSTS Report refers. And this public process resolved the issue of Arborway service in favor of Green Line restoration. The public process did NOT support EOTC's proposed alternative.
C. The proposed bus alternative does NOT increase current Arborway ridership, which the LSTS Report misrepresents as 19,500. Current ridership is 17,405. Despite numerous paragraph headings in the LSTS Report linking the bus alternative to increased public transit ridership, there will be no increase in ridership under the proposed substitute. EOTC admits that current ridership levels will be maintained under the bus alternative. "The CTPS model predicts 19,500 Arborway study corridor trips…an increase of 2,500 trips over the base case (maintaining current ridership levels)." (LSTS, p. 27) While admitting that there will be no increase in transit ridership along the Arborway corridor resulting from the implementation of the bus alternative, EOTC misrepresents current Arborway ridership as being 19,500. This ridership figure is contradicted not only by the ridership history of the Route 39 bus, but also by the latest available figures from the Central Transportation Planning Staff (CTPS). In a fax to the Arborway Committee dated January 11, 1999, CTPS provided the latest ridership figures for Route 39. These were compiled in the fall of 1997 and apparently issued in May, 1998. They show daily Route 39 ridership to be 17,405. (Appendix 10) This figure is consistent with previous ridership statistics issued by CTPS, eg., ridership in 1993 was 17,167 (Appendix 11); in 1995 it was 16,192. (Appendix 9, p. 6) It is true that in February 1996, a ridership count was undertaken that showed 19,420 daily riders, but that appears to be a weather-related aberration since the winter of 1995-1996 was the only winter in history when the snowfall in Boston exceeded 100". The logical conclusion to be drawn from the factual record is that the bus alternative will maintain the current level of Arborway ridership. The current level of ridership is 17,405. Since the LSTS ridership statistic of 19,500 is contradicted by the weight of historical evidence and by the most recent available figures, it is not reliable. Ridership is 17,405. Further, on the basis of EOTC's submittal, it seems likely that the preferred alternative will actually lose ridership rather than maintain it. In its consideration of the "build alternatives," the LSTS Report speculates on the relationship between the number of transit stops along the route and the level of ridership. It concludes that "ridership would be expected to fall with significant reductions in the number of bus stops." (LSTS, p. 24, footnote 5) The report notes that light rail would make 17 less stops than the bus alternative with a resulting lower ridership for light rail. What I find remarkable about this analysis is the fact that the report also projects that the proposed bus alternative would make 17 fewer stops than the current bus service, yet EOTC projects no resultant ridership loss for the bus. If EOTC's submittal is correct in maintaining that "ridership would be expected to fall" because of a reduction in the number of stops, and if the proposed bus alternative would make 17 fewer stops than the current bus service, then implementation of the proposed bus alternative should result in reducing ridership below the current level of 17,405. Yet, EOTC maintains throughout the report that implementation of the preferred bus alternative would maintain the current level of ridership. In view of EOTC's own analysis, this is not believable.
D. Green Line Arborway Restoration would result in a significant fare reduction yet there is no analysis in the LSTS Report on the resultant impact on Green Line ridership. There is a significant amount of data on the beneficial impact on transit ridership that results from a fare reduction. Because of Green Line fare policy, all outbound surface trips are free. This policy was in existence in 1985 when the Arborway Green Line last operated, and it continues on the Green Line today. Green Line fare policy means, therefore, that Arborway Restoration would result in a 30% fare reduction for all surface riders in the Arborway corridor. For instance, an Arborway Green Line rider who wanted to get from Forest Hills to the Longwood medical area and back, or who wanted to get from South Huntington Avenue to the Jamaica Plain business district and back would pay a total roundtrip fare of $.85. The current roundtrip bus fare, which would be maintained under the proposed bus alternative, is $1.20. The LSTS Report provides no information on the impact of such a significant fare reduction on light rail ridership in comparison to bus ridership. In addition, implementation of Green Line fare policy would also result in faster on-street service. For instance, the current bus service and the proposed bus alternative require the collection of an outbound fare. Passengers must queue and enter the front door of the bus to pay. This adds to the bus's travel time. With the free outbound service that the Green Line would provide, however, passengers would enter the car from all doors without pausing to pay a fare. This would result in less time spent at stops and faster service. The link between faster service and increased ridership was highlighted in a 1988 City of Boston study of Green Line Arborway service. The study indicated that a cut in "travel time by about five minutes in each direction [could] increase ridership by as much as 4,000." (Appendix 12, Parking Management Program, executive summary) What would be the travel time-savings for Arborway riders resulting from the Green Line fare policy and what would be the impact on light rail ridership in comparison to bus ridership? The LSTS Report is silent on this matter.
E. In its submittal EOTC significantly overestimates the cost of Green Line Arborway Restoration. In any discussion about costs, it must be admitted that rail service is always more costly to construct and maintain than bus service. It would certainly be cheaper for EOTC to provide a bus service for the 5000 daily South Shore riders who commute to Boston on the Old Colony commuter rail than it has been to build and operate the Old Colony Line. It also would be cheaper for EOTC to bus the entire Green Line than it is to buy light rail vehicles, and build and maintain the current light rail system. No one would contest this. And yet, if EOTC were to make all service decisions on the basis of cost, EOTC would abandon all rail service in favor of bus service because bus service is always cheaper to build and maintain. In its submittal EOTC attempts to draw DEP into this discussion about the cost benefits of bus service over rail service in order to demonstrate that Green Line Arborway Restoration is economically infeasible. Such a discussion is quite irrelevant, however. I would argue that the better measure of the economic feasibility of Green Line Arborway Restoration is a comparison between it and other Green Line services. What is the cost of Arborway Line operation and maintenance in comparison to the Beacon Street Line or the Commonwealth Avenue Line? LSTS does not provide this information. Further, what is the relationship between operating costs and farebox recovery for each of the Green Line branches in comparison to the Arborway Line? LSTS does not provide this information either. Such information is available, however. In fact, in a comparison of Green Line (excluding Riverside) operating costs and farebox recovery for 1985 provided by the MBTA Advisory Board, the Arborway Green Line had the second highest rate of farebox recovery of all Green Line branches and a lower operating cost than the Cleveland Circle Line. (Appendix 13, Advisory Board comparison) Such comparisons contribute to the conclusion that Arborway Green Line Restoration is not economically infeasible. However, even if one were to accept EOTC's misguided approach of comparing the cost of the bus alternative to the cost of light rail as a valid means of measuring economic infeasibility, one might still conclude that Green Line restoration is not economically infeasible. In fact, had EOTC provided a more candid account of costs, it would show that light rail compares much more favorably to the preferred bus alternative than the LSTS Report admits.
With the delivery of 100 new low-floor LRVs in 1999, EOTC has a combined Green Line fleet that exceeds 220 vehicles. Current peak MBTA Green Line service requires only 142 LRVs or 71 two-car trains. (Appendix 14, Rollsign, p. 7) Assuming that one car of each train must be low-floor to comply with the Americans with Disabilities Act (ADA), EOTC will require only 71 of the new 100 low-floor LRVs and 71 of the older 120 standard LRVs to run all current peak Green Line service. This leaves a significant fleet of spare light rail vehicles. This spare fleet is more than adequate to cover the peak requirements of a restored Arborway Green Line. Yet, EOTC estimates that an additional ten light rail vehicles at a total cost of $26.4 million must be purchased in order to restore the service. This is incorrect on two scores. First, a review of the 1987 Study shows that operating the Arborway Line at 6-minute headways would require 18 LRVs, or nine two-car trains. (Appendix 1, p. 47) Thus, if one were to add Arborway service to the total Green Line peak requirements, then nine additional new low-floor and nine additional older standard LRVs would be required. This would bring the total number of LRVs needed to operate the Green Line with a restored Arborway service to 80 low-floor and 80 standard cars. This still leaves a spare fleet of adequate size to allow for operating peak service while removing vehicles from service for maintenance and repair. Clearly, EOTC's claim that additional cars must be purchased for Arborway service is incorrect. Secondly, however, even if one concedes the need to purchase new low-floor vehicles, the correct number to be purchased would be nine, not ten. The cost of nine new low-floor LRVs is $23.76 million, not $26.4.
As the photograph in Appendix 15 shows, however, the conditions along that portion of South Huntington Avenue where light rail service is currently operating are virtually the same as the conditions on that portion of South Huntington Avenue where service is not operating. The roadway in the vicinity of the track shows significant deterioration. This current condition certainly questions the validity of EOTC's claim that the condition of the road is a good indicator of the condition of the railbed. Again, EOTC has not made its case. One would rightly characterize the replacement of rail between Heath Street and the Arborway as being a questionable expenditure. Yet, if track replacement is required, the cost of rebuilding and maintaining the Arborway rail infrastructure should be measured against the cost of maintaining the rail infrastructure of the other Green Line branches, as already noted.
F. In its submittal EOTC significantly underestimates the cost of the bus alternative.
The import of FTA's useful life standard for Arborway service is that in order to operate 25 years of Arborway service using buses, EOTC will have to make 2.08 purchases of buses for every one purchase of LRVs. This type of analysis is not unknown to EOTC as it was incorporated into the 1987 Study's assessment of vehicle costs for Arborway service. (Appendix 1, p. 30) Thus, a fair comparison of vehicle purchase costs for Arborway service over a 25-year period would show that the preferred bus alternative would cost approximately $30.67 million ($600,000 x 24 x 2.08 + an inflation factor of 5% on the second purchase) compared to only $23.76 million ($2.64 million x 9 x 1) for light rail vehicles. The LSTS Report fails to account for this added bus expenditure.
As currently designed, the Arborway bus facility contemplates housing a fleet of approximately 160 buses, 54 of which will be CNG powered. The facility will include a specially designed CNG storage and fueling station, specially designed CNG bus repair bays, and space for storage of CNG vehicles. Since one-third of the buses to be stored at the facility will be CNG-powered, then one-third of the cost of construction of the facility should be attributed to that component. As proposed, only two bus routes will share in the use of the CNG facility-- Arborway and Washington Street. Estimating the ultimate total cost of the facility to be between $30 million and $50 million, the CNG component will likely cost between $10 million and $17 million, or one-third. Of that amount, the cost attributable to EOTC's CNG bus alternative for Arborway service would be between $5 million and $8.5 million, or one-half. This cost must be assessed as part of the capital cost of EOTC's preferred bus alternative for Arborway service because without this facility, there can be no CNG service Yet, no where does EOTC account for this cost. In the alternative, however, if the cost of a fueling, storage, and maintenance facility, which has not yet been built, is not to be included as a component of the capital cost of EOTC's preferred alternative for Arborway service, it is quite impossible to justify assessing the cost of light rail vehicles, which have already been purchased, against Green Line Arborway Restoration. EOTC cannot have it both ways.
G. A fair comparison of the costs of Green Line Arborway Restoration and EOTC's preferred bus alternative differs greatly from that projected in the LSTS Report (p. A-1). On the basis of the foregoing commentary, two cost scenarios are possible. The first, shown in Table 1 below, would exclude the cost of the construction of the CNG facility at the Arborway Yard and the cost of purchasing light rail vehicles for Green Line restoration. The second, shown in Table 2, would include both costs. Neither case would support a finding of economic infeasibility for Green Line Arborway Restoration.
Table 1
Table 2
*Because the need to replace track is questionable as discussed in section E above, LRV infrastructure costs might be significantly lower than this estimate.
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