Arborway Green Line Restoration
Documents

Testimony of Franklyn P. Salimbene, Esq., Chair, Arborway Committee before Executive Office of Environmental Affairs (EOEA) regarding Expanded Environmental Notification Form, Arborway Green Line Restoration Project

12 May 2003

TABLE OF CONTENTS

A. A single EIR
B. The Arborway regulation 310 CMR 7.36 (2)(d)
C. Arborway Rail Restoration Project Advisory Committee (ARRPAC)
D. Environmental Justice

A. Transportation improvements (EENF, pp. 1-2, 1-3)
B. Costs (EENF, pp. 1-3, 1-12, 1-13)
C. No additional alternatives analysis (EENF, pp. 2-1 to 2-4)
D. Air quality impacts (EENF, pp. 4-8, 4-9)
E. Simulation software packages and projections (EENF, p. 4-1)
F. Proposed mitigation measures (EENF, p. 5-2)
G. Additional comments: parking (EENF, p. 3-9) and cycling (EENF, p. 3-5)
H. Factual inaccuracies

• Mass. DEP Arborway Rail Restoration Feasibility Determination, 7 November 2001
• Arborway Rail Restoration Expanded Environmental Notification Form (EENF)
• Arborway Committee Testimony to Mass. DEP, 10 July 2001
• Arborway Alternatives Analysis report, MBTA/Systra, June 2001
• Massachusetts DEP Air Pollution Control Regs 310 CMR 7.36

INTRODUCTION

The Arborway Committee (AC) agreed with the order of the Department of Environmental Protection (DEP) dated November 7, 2001, to restore Arborway Green Line service. For reasons set out below, AC believes that the order made both good transportation and good environmental sense. Further, AC believes that restoring Green Line service to the entire Arborway Corridor is consistent with the Governor’s “smart growth” policies that put quality public transit where people live and provide the fastest service to their destination.

AC submits the following testimony regarding the Arborway project Expanded Environmental Notification Form (EENF). While agreeing and disagreeing in parts with the EENF, AC notes for the record that the EENF is at times both overly political and factually inaccurate.

Included in this AC testimony and incorporated by reference is a copy of AC’s July 10, 2001 testimony before DEP regarding the request by the Executive Office of Transportation and Construction to substitute the Arborway project. The 2001 testimony provides background to this testimony and is referenced throughout. The testimony along with appendices is found in the accompanying blue booklet. 

I. WHY THE DEP DECISION TO RESTORE ARBORWAY GREEN LINE SERVICE WAS RIGHT

In the late 1890s the City of Boston made a fundamental decision to remove transit vehicles from downtown roadways. The construction of the Tremont Street subway and its expansion to the Back Bay were key to providing a public transit system that neither added to downtown congestion nor suffered delays because of it. According to Vukan R. Vuchic, Professor of Transportation Engineering at the University of Pennsylvania, this decision “gave Boston a national reputation as a leading city in far-sighted transportation planning.” (Vuchic Arborway Testimony, p. 1, 2001)(A complete copy of Vuchic’s testimony can be found in the accompanying blue booklet at Appendix 8.)

Beginning in the 1950s, however, the MBTA and its predecessor, the Metropolitan Transit Authority, began the systematic dismantling of the very infrastructure that contributed to Boston’s national reputation. Streetcar lines that served city neighborhoods connecting them directly into the central subway were abandoned in favor of bus service. Where this substitute bus service did not go directly downtown, but dropped riders at subway stations that required a transfer to complete the journey, ridership suffered. The most prominent example is the Route 57 bus service from Brighton and Allston to Kenmore Square that replaced the Green Line’s A-Branch to Park Street. Where bus service did go directly downtown, as with the Route 43 bus service that replaced the Tremont Street Green Line, the bus service both added to downtown congestion and suffered delays because of it.

In 1985, continuing its systematic dismantling of transit infrastructure, the MBTA moved to convert the Arborway Green Line service to a bus service, the Route 39. Not only did the Route 39 bus service introduce into the Back Bay 800 daily bus trips, but it also required passengers to transfer into the subway in order to reach the final destination, Park Street.

In his testimony regarding the MBTA’s Arborway alternatives analysis, Vuchic noted that operating buses in the city center represents a major deterioration in transit service. (Vuchic, p. 2, 2001) The facts confirm his testimony. Ridership on the Route 39 has fallen from 28,000 in 1988 to 17,400 today. (MBTA Ridership and Service Statistics, pp. 2-10, 2-11, 1988; Arborway Alternatives Analysis , p. 9, 2001)

Vuchic also noted that conversion from rail to bus invariably results in a significant lowering of vehicle performance. (p. 2) Again, facts confirm his testimony. In August 1996, the MBTA issued a report on Route 39 bus operations that acknowledged the operational difficulties associated with running a bus in traffic for the full 10.3-mile route into and out of the Back Bay. The report stated that “customer complaints routinely show that schedule reliability is the primary concern of Route 39 passengers.” It went on: “This is reasonable since poor adherence to schedules contributes to uneven vehicle loading, bunching, delayed buses, and missed connections.” (Service Review: Route 39, pp. 2-3, 1996) Route 39 bus operations today are a confirmation of both the validity of Boston’s 1890 transit strategy of putting transit underground and the folly of the more recent MBTA policy of dismantling urban rail transit infrastructure that connects into the central subway system.

Viewed in this context, therefore, the November 7, 2001 decision by DEP to restore Arborway rail service was a decision of historic proportions.

• First, it was a reaffirmation of Boston’s nationally recognized policy of the 1890s that removed public transit from the downtown traffic mix so that transit neither added to congestion nor suffered delays because of it.
• Second, it was a reversal of the MBTA’s 50-year policy of systematically dismantling rail infrastructure in heavily transit-dependent city neighborhoods and converting to bus service that significantly eroded transit reliability and air quality in the very locations where these factors mattered most.
• Third, it was a recognition that while Arborway Green Line service resumption created some challenges along portions of its route in Jamaica Plain, those challenges were in the long run far more manageable and less costly to remedy than the challenges associated with accommodating ever growing numbers of buses and bus routes in an increasingly more congested downtown traffic mix.
• Fourth, it was a pledge to increase public transit ridership and reduce toxic emissions by providing zero-emission Arborway Green Line service that is faster than bus to downtown Boston; creates direct connectivity to the Red, Blue, and Orange Lines; and provides significantly higher transit capacity along the heavily transit-dependent Arborway Corridor.

II. ARBORWAY EENF: Context

A. A single EIR

AC endorses the MBTA’s request to file a single EIR. The endorsement is based upon the long, public, comprehensive, and inclusive process relating to the Arborway transit project. Most significantly, the Arborway project has been the subject of three alternative analyses and three accompanying public processes. The 1987 Arborway Study was a 16-month process during which more than a dozen public meetings were held in the neighborhood. A public hearing on the study’s conclusions was held in January 1988. In 1999, a second alternatives analysis, The Arborway Study: Final Report was issued. This study and the proposed DEP ruling were the subject of two public hearings and lengthy public comment periods in March and May, 1999. From January 2000 to April 2001, a third alternatives analysis was undertaken, Arborway Alternatives Analysis: Final Report. During this 16-month period, approximately a dozen public meetings were held in the neighborhood. These meetings were ordered by DEP as a result of the 1999 public process in order to solicit the widest possible public input. They were well publicized, well attended, and well covered by the local press. The issuance of the report was followed by a public hearing in July 2001 and a lengthy public comment period.

In addition to these studies and hearings, additional public process occurred in relation to the following events. In 1986, an Arborway Green Line restoration referendum question appeared on the State ballot in Jamaica Plain. In 1989, a memorandum of understanding between the City of Boston and the MBTA to restore Green Line service was negotiated by the Jamaica Plain legislative delegation. In 1991, DEP conducted public hearings as part of the process that created 310 CMR 7.36 (2)(d) mandating the restoration of Arborway Green Line service. Also in 1991, the legislative delegation proposed and won inclusion of the Arborway project in the State transportation bond bill. From 1991 through 1996, the MBTA Arborway Advisory Committee conducted dozens of public meetings attended by representatives of residents, businesses, and the City of Boston to discuss implementation and operation of restored Arborway Green Line service. In 1995, the legislative delegation again proposed and won inclusion of the Arborway project in that year’s transportation bond bill. From 2002 through 2003, the MBTA has conducted more than a dozen meetings in the neighborhood as part of the Arborway Rail Restoration Project Advisory Committee (ARRPAC) process. Finally, in 1987, 1996, and 2001, the Jamaica Plain Neighborhood Council conducted public hearings preceding its voting to support the Arborway restoration project.

The EENF process is, therefore, only one step in the very long history of meetings, studies, and other initiatives relating to the Arborway Green Line restoration project. This long, public, comprehensive, and inclusive process regarding Arborway transit service warrants the submission of a single EIR.

B. The Arborway regulation 310 CMR 7.36 (2)(d)

Very much a part of this process has been DEP regulation 310 CMR 7.36 (2)(d) , which mandates Arborway Green Line restoration. This public transit regulation along with several others was promulgated in 1991. Together, these regulations were a counter-balance to what was rightly viewed at that time as a projected excessive expenditure by the State in favor of the private automobile represented by the Central Artery project.

Ironically, some opponents have come forward recently to lobby the State to abandon its regulatory commitment to the Arborway project because Green Line service, in their view, would have a negative impact on automobile access and parking along a short section of the Green Line route in Jamaica Plain. Putting aside the legal action that a reversal of the Arborway transit commitment would invite, the abandonment of any transit commitment so as to facilitate automobile access and parking would contradict the very purpose and nature of the transit regulation, which is to reduce reliance upon the private automobile. To take any action, therefore, that facilitates automobile access and parking at the expense of Green Line restoration in the Arborway Corridor simply invites more automobile traffic and the negative air quality impacts that the regulation is intended to remedy. It would stand the transit regulation on its head.

C. Arborway Rail Restoration Project Advisory Committee (ARRPAC)

None of this is to deny that restoration of Arborway Green Line service is without challenge. It is important to remember, however, that the entire Central Artery road-building project has been a challenge of monumental proportions. The challenge of restoring a two-mile streetcar line, which is a Central Artery commitment, pales in significance to the road project.

Nonetheless, to provide both a forum for raising issues and a mechanism for resolving them during the Arborway project, the MBTA has constituted the Arborway Rail Restoration Project Advisory Committee (ARRPAC). Chaired by William Lieberman, a nationally recognized expert in urban light rail design and operations, and Barbara Boylan, AIA, the project manager, ARRPAC is playing a positive role in the restoration process.

ARRPAC represents a wide range of interests. It represents Jamaica Plain businesses and residents. In fact, when formed, 25% of its membership was composed of Jamaica Plain business leaders. It also represents people who do not live in Jamaica Plain, but who live, work, and shop within the Arborway Corridor from downtown, the Back Bay, and the Fenway, to the Longwood Medical Area, Roxbury, and Mission Hill. In addition, it represents elected public officials and a number of City of Boston agencies.

Working from this representative base ARRPAC has been thoughtful and open in its deliberations. For instance, the first major issue discussed by ARRPAC related to transit stop locations for the restored Green Line service. (EENF, pp. 1-10 to 1-12) Several concerns were raised by business interests, many of whom feared that automobile parking would be lost in the Centre Street business district. To this end, ARRPAC agreed with the proposal of the Vice President of the Jamaica Plain Business and Professional Association (BAPA) that outbound stops be located at either end of the business district rather than in the middle. The objective was to smooth traffic flow within the business district and to create some new on-street parking where the current Burroughs Street bus stop would be discontinued.

Retaining the outbound stop at the southern end of the business district near Eliot Street as suggested by the BAPA Vice President posed a dilemma, however. While the owner of Little Peach at the corner of Eliot Street wanted the stop to remain directly in front of his shop, his neighbor, AAA Appliance, did not want the stop there. AAA claimed that the stop would interfere with appliance deliveries to his store. ARRPAC reviewed the situation and decided to retain the stop as located because AAA had ample room to take deliveries through a rear entrance. (Appendix 1 herein, photo) As a further example of ARRPAC’s thoughtfulness and inclusivity, agreement was reached that Green Line stops not be created directly opposite each other, but that stops be staggered along the route so as to provide ample room for emergency vehicle maneuverability. As ARRPAC works through these and similar issues, members know from prior history that Green Line service is compatible with retail activities and emergency access. ARRPAC has a good practical base from which to work.

ARRPAC is an important part of the restoration process. Not all issues raised can be resolved to everyone’s satisfaction. Doubtless, there will be other issues that will arise to demonstrate the point. Nevertheless, ARRPAC remains a positive, open, and representative mechanism for resolving differences of opinion.

D. Environmental Justice

One other important element that comprises the context of the Arborway EENF is Environmental Justice (EJ). Arborway restoration is an Environmental Justice project. Forty percent of Jamaica Plain residents are either Afro-American or Hispanic. (EENF, p. 3-28) In addition, 13.7% of residents within the study corridor are persons living in poverty. (EENF, p. 3-31) The MBTA also has reported that 20% of Route 39 riders have annual household incomes below $20,000, and 40% of riders do not own an automobile (Arborway Alternative Analysis, p. 9, 2001)

The replacement of a high pollution, internal combustion bus service with a zero-emission, electric transit line in a heavily transit-dependent, poor urban neighborhood is the hallmark of Environmental Justice. While not disregarding the overall regional air quality benefits that come from removing people generally from their automobiles and putting them on public transit, Professor Vuchic comments that “buses produce pollution not dispersed through the region, but directly in the streets. Their emissions are actually most intensive when they accelerate from stops, in areas of the greatest concentration of pedestrians.” (Vuchic, p. 3) In Jamaica Plain this is a critically important fact. The Boston Globe has reported that overall, Jamaica Plain has a higher level of reported asthma cases than the city-wide Boston average. Further, portions of Jamaica Plain have the highest levels of reported asthma in all of Massachusetts.

Coupled with the Governor’s recent apparent decision to reallocate transit dollars from commuter rail projects to rail projects within the urban core, DEP’s November 2001 order to restore Arborway Green Line service clearly promotes the Environmental Justice agenda. Arborway Green Line restoration will reduce high concentrations of toxic emissions in the very places where people of color and poverty live.

Before moving from this topic, the Arborway Committee (AC) notes that the EENF, while concluding that “the Jamaica Plain area meets the criteria of an EJ population” with more than 40% Afro-American and Hispanic residents, surprisingly concludes that only 4.4% of the population within the Arborway EENF study area is Afro-American or Hispanic. (EENF, p. 3-30) This seeming discrepancy between the overall Jamaica Plain minority population and the minority population within the EENF study area may result from the methodology used in reaching the conclusion or from seeming statistical omissions.

• First, the study area used for the EENF does not correlate with the 2001 study area used by the MBTA for calculating Arborway ridership. To calculate the minority population in the study area the EENF used U.S. census blocks while to calculate ridership the MBTA used straight lines running parallel along both sides of the Green Line alignment at three-quarters of a mile distance. This is known as the ridership “catchment” area. Measuring the population characteristics within the catchment area may be a more reliable measure of the ethnic characteristics within the Arborway Corridor.
• Second, Table 3.6-2 (EENF, p. 3-30) omits from the list of census blocks several blocks within sight of the Green Line alignment that have heavy concentrations of minority residents. For example, Census Tract 812 Block Group 2, Census Tract 1206 Block Group 1, and Census Tract 1206 Block Group 2 as found in Figure 3.6-1B (in the map appendix to the EENF) are all excluded from the Table and the calculation.
• Third, the methodology used to demonstrate the ethnic characteristics of the study area takes no account of actual ridership characteristics. Even a casual observer of Route 39 ridership would note that during certain periods of the day, a majority of passengers are members of racial and lingual minorities. These, however, are not incorporated into the ethnic calculation.

Utilizing these alternative measures would likely result in an assessment of ethnic characteristics of the population to be served by the Arborway Green Line that more closely comports to the overall ethnic composition of the Jamaica Plain neighborhood.

III. ARBORWAY EENF: Comments

A. Transportation improvements (EENF, pp. 1-2, 1-3)

AC concurs that the EENF captures the importance of Arborway Green Line restoration as a project that both improves transportation services and distributes these improved services more equitably within the urban core.

To wit, Arborway restoration will:

1. promote “an economically strong urban core that is not dependent upon automobile access;”
2. “comply with state air quality strategy plans;”
3. promote an “equitable distribution of transportation services across the metropolitan area;” and
4. “support regional mobility and environmental goals through cost-effective transportation measures.” (EENF, pp. 1-2, 1-3)

AC would add that the Arborway project will promote an economically strong urban core that is not only not dependent upon automobile access, but also not dependent upon bus access. As Vuchic has stated, buses are “a major contributor to street traffic congestion.” (Vuchic, p. 2, 2001) In the context of current Route 39 bus service, the congestion impacts are magnified. Route 39 operates 401 inbound and 401 outbound trips in the Back Bay every weekday. Removal of these buses from the urban core will play a significant role in decreasing Back Bay congestion. In 2001, in seeming agreement with Vuchic, the Boston Transportation Department (BTD) responded to the MBTA’s proposal to extend Route 39 service to Park Street as follows: “The City cannot determine if this transportation link is effective unless further detailed analysis is undertaken.” BTD Commissioner d’Amato went on to call into question the capacity of Tremont Street to accommodate additional 60’ articulated buses as well the overall impact of the extended service on the streets leading to and rounding Boston Common. (AC Testimony, Appendix 14, 2001, in the accompanying blue booklet) 

B. Costs (EENF, pp. 1-3, 1-12, 1-13)

AC concurs that the Arborway project as “a cost-effective transportation measure.” (EENF, p. 1-3) AC has continually maintained that the costs of Arborway Green Line restoration as presented by the MBTA in the past were overly inflated and that the costs of the alternative CNG bus proposal were significantly underestimated. (AC Testimony, pp. 5-8, 2001, in the accompanying blue booklet) In its 1999 and 2001 submissions to DEP, for example, the MBTA was adamant that restoring Green Line service would require the purchase of additional Green Line cars at a cost of $45.9 million. Contesting this point, AC’s 2001 testimony demonstrated the adequacy of the current fleet to accommodate restored Arborway service. (AC Testimony, pp. 5, 7, and Appendix 4, in the accompanying blue booklet) It is refreshing to see, therefore, that the MBTA now admits to the possibility that new Green Line cars might not be necessary after all. (EENF, p. 1-13). This is indeed progress.

None of this should lead EOEA to conclude that AC agrees with the remainder of the MBTA’s cost calculation for the project, which is alleged to be $58 million. (EENF, p. 1-12) In 2001, the MBTA estimated the cost of Green Line restoration to be $30.8 million absent the cost of additional cars, project design, mitigation, and project administration. Now the EENF calculates the cost to have risen to $45.5 million absent the same factors. It is not clear why within the intervening two years, with inflation and interest rates at very low levels, the cost of the project has increased by $15 million. Nonetheless, whether $30.8 million or $45.5 million or $58 million, the project is cost effective. By way of comparison, the MBTA has agreed to upgrade station stops on the Indigo Line from Hyde Park to South Station at a cost of approximately $70 million. The $70 million covers the upgrade of only eight stations.

C. No additional alternatives analysis (EENF, pp. 2-1 to 2-4)

AC concurs with the MBTA that “no additional alternatives analysis is necessary in the EIR….” (EENF, p. 2-4) The reasons are legal, practical, and fiscal.

Legally, further alternatives analysis is not justified under the regulation. Regulation 310 CMR 7.36 (4)(a) states:

EOTC may substitute other transit improvement projects in place of those listed in 310 CMR 7.36. To replace a project EOTC must demonstrate to the Department that a specific project listed in 310 CMR 7.36 is infeasible….

The regulation invites a substitute project, and by implication the alternatives analysis necessary to support such a project, either pending an infeasibility determination of the listed project or subsequent to an infeasibility determination of the project. Once the listed project is ruled feasible, however, as is the case with Arborway Green Line restoration, the reason and purpose for an alternatives analysis cease to exist. If the project is deemed feasible, there is no legal basis for substitution. If there is no legal basis for substitution, there is no legal reason for performing an alternatives analysis. An alternatives analysis would serve no purpose.

Practically, a further alternatives analysis would be ill-considered. First, any alternative project would be governed by 310 CMR 7.36 (2)(d), which mandates “restoration” of Arborway service. Arborway service has been defined as service from Arborway to Park Street. (DEP Decision on Arborway Restoration Petition, p. 2, September 1, 2000) The alternative project would, therefore, have to provide either a direct one-seat bus ride to Park Street, or a transfer to Park Street from some intermediate point, e.g., Ruggles Station or Copley Square. The direct one-seat ride by bus to Park Street would create more problems than it would solve (Vuchic) and an intermediate transfer would incur a significant ridership loss and concomitantly far higher emissions than Green Line restoration. Second, an alternatives analysis would be ill-considered because it would be conducted by the MBTA, an entity which has come to merit the distrust with which many view it. Third, further alternatives analysis would needlessly incur additional delay in restoring Green Line service, which was mandated to have been restored in 1997. Fourth, further alternatives analysis would require EOEA and DEP to engage in additional and repetitive oversight of a project that has already consumed an inordinate amount of the agencies’ time and resources.

Fiscally, more alternatives analysis would add to the cost of the Arborway project. The expenditure of funds for the implementation, conduct, and oversight of repetitive and duplicative studies is not justifiable in good or bad economic times.

D. Air quality impacts (EENF, pp. 4-8, 4-9)

AC does not agree that the “air quality study presented in the EIR will identify and quantify the air quality benefits of the Arborway Restoration Project.” (EENF, p. 4-8) Because the study area does not include the entire Arborway Corridor, only a partial evaluation of air quality benefits will be undertaken. No account will be taken of air quality benefits of restored service in the northern portion of the corridor from Heath Street to the Back Bay.

For example, the EENF proposes quantifying benefits resulting from the elimination of diesel bus service from Heath Street to Forest Hills. (p. 4-8) Although Arborway restoration will also remove diesel bus service from Heath Street to the Back Bay, the EENF does not propose a similar evaluation of air quality benefits for this portion of the route.

Further, the EENF proposes quantifying “any increases in the emission of pollutants of concern…caused by increased traffic congestion or delays following the restoration of light rail service….” (p. 4-8) While the notion that increased congestion would result from Arborway restoration is ill-founded and disputed by two previous studies (1987 and 2001), the EENF does not propose quantifying any decreases in emissions resulting from the removal of 800 buses per day from the traffic mix along the northern portion of the Arborway Corridor. For instance, what is the air quality impact of removing 800 buses per day from Copley Square, or from Brigham Circle, or from the intersection at Huntington Avenue and Ruggles Street?

As contemplated, the EENF will provide only a partial evaluation of the air quality impacts of restored Arborway service. Therefore, AC recommends extending aspects of the air quality analysis to the northern portion of the corridor.

E. Simulation software packages and projections (EENF, p. 4-1)

AC supports the utilization of either the VISSIM or PARAMICS simulation software packages for calibrating the operations parameters of restored Green Line service. It appears that these packages are better suited for light rail operations than is the standard package used by the Boston Transportation Department. The BTD package is not sophisticated enough to account for urban light rail operations.

AC understands, however, that the value of any software package depends upon the information fed into it. For example, the mesoscale analysis to be conducted by the Central Transportation Planning Staff (CTPS) (EENF, p. 4-9) raises some concern for AC in that the analysis will be based upon ridership analyses already developed by CTPS. Previous CTPS ridership and emissions projections made for the Arborway alternatives analysis that was submitted to DEP in July 2001, raised many questions regarding their reliability. Yet, these projections, which AC rejected as consistently underestimating both potential ridership and beneficial air quality impacts of restored Arborway Green Line service, appear in the current EENF. (pp. 1-8 and 4- 8) As AC stated in its 2001 testimony, “…EOTC and its consultants have submitted a report so biased in favor of its proposed bus substitute as to be meaningless.” (AC Testimony, pp. 9-12, 2001, in the accompanying blue booklet)

For these reasons, AC cautions EOEA against relying upon any statements in the current EENF that project ridership or emissions levels resulting from Arborway restoration. (pp. 1-8 and 4-8) Further, AC requests that ARRPAC have ready and regular access to CTPS during the running of any and all computer analyses for the EIR.

F. Proposed mitigation measures (EENF, p. 5-2)

AC makes the following recommendations regarding mitigation measures proposed for study in the EIR:

1. A one-way traffic flow system for Centre and South Street is both impractical and unnecessary. This measure should be omitted from study.
   
   
2. Elimination of parking at certain locations along Centre and South streets might prove beneficial. This measure should be studied in consultation with ARRPAC.
   
   
3. Creating a pedestrian mall along certain sections of the corridor is a novel suggestion. While this measure may meet with initial resistance and may ultimately prove to be impracticable, it ought to be studied.
   
   
4. From the language of the proposed emergency response controls mitigation measure, it is unclear what is contemplated by the MBTA. To assist in fashioning an emergency response protocol, AC suggests that the MBTA undertake a review of emergency protocols that exist in other North American cities that operate light rail systems in street, e.g., Toronto and Philadelphia. The MBTA should also consult with experienced members of the Boston Carmen’s Union. That having been said, however, it remains AC’s view that concern regarding emergency response is exaggerated and seems incorporated into the EENF for political purposes only. (AC Testimony, pp. 21-22, and Appendices 21 and 22, in the accompanying blue booklet)
   
   
5. Transit control measures are important elements of mitigation. Headways, dwell times, and consist size are, therefore, important to consider. Regarding headways, 5-minute, 6-minute, and 7-minute peak headways should be studied. Regarding consist size, AC encourages the MBTA to include in its study the operation of single car service. It is clear from Arborway Green Line service in the 1980s that double-car operation during peak is likely necessary. The great promise of Arborway Green Line service is its potential to increase transit ridership significantly over current Route 39 passenger counts. For instance, when Arborway Green Line service last operated in 1985, it carried 50,000 daily riders, or 15.3 million riders annually. (Arborway Study, p. 5, 1987) While essential during rush hour, however, double-car operation seems neither required nor desirable during off-peak weekday hours and during weekends. Therefore, all impacts and mitigation measures studied for double-car service should also be studied for single car service.
   
   
6. Traffic signal coordination options should be studied.
   
   
7. Redesign of on-street parking to optimize parking capacity should be studied.
   
   
8. The construction of new parking lots or garages adjacent to Centre Street in the vicinity of new station locations should not be contemplated or studied for the EIR. In the context of the southern portion of the Arborway Corridor, new parking lots and garages would constitute poor urban planning. Such lots and garages would act as magnates for commuters to drive to Jamaica Plain to catch the Green Line. This would exacerbate traffic issues rather than alleviate them. What might be helpful, however, is an investigation of the benefits of converting to public use the existing privately owned and under-utilized parking lot behind the Galway House in the Centre Street business district. This could be studied for use as a long-term parking facility for business owners and employees in the business district or as a second short-term lot to supplement the public lot on the west side of Centre Street.
   
   
9. Finally, although not mentioned amongst the mitigation measures, BTD must be encouraged to become fully engaged in the Arborway project. BTD must play a positive and proactive role in preparing a traffic management plan for both the immediate and future time periods.

G. Additional comments: parking (EENF, p. 3-9) and cycling (EENF, p. 3-5)

AC has consistently maintained that issues of parking are not within the contemplation of 310 CMR 7.36 (2)(d) and seem to be raised for political purposes only. AC also maintains that parking impacts are not relevant to the EENF process. Nevertheless, AC notes with interest the MBTA’s assessment that parking along the study corridor is not at capacity. “Occupancy rates in excess of 85 percent generally indicate that parking is at capacity.” (EENF, p. 3-9) Table 3.1-3 indicates a range of occupancy between 60.89% and 76.47%. While there is consensus that parking along the Arborway Corridor, and particularly within the business district, ought to be optimized, current occupancy rates appear to allow for some flexibility in reaching decisions regarding parking.

Regarding cycling, AC believes that every reasonable measure consistent with restoration of Green Line service ought to be taken to assure cycling safety along the Arborway Green Line alignment. Such safety measures undertaken ought to be proportionate to cycling demand, however. It is instructive to note that the number of cyclists along the corridor is generally “less that 10 per hour” although during rush hour the number sometimes reaches 20. (EENF, p. 3-5) This number pales in comparison to the thousands of public transit riders in the corridor.

The EENF concludes that cyclists generally seem not to choose to ride along Centre and South streets because the narrowness of the streets does not provide an adequate or safe cycling environment. While cycling should be encouraged as an alternative means of transit, it should not be encouraged under any transit scenario along routes that are already too narrow for safe cycling. Fortunately, however, there are two safe and convenient alternatives for cyclists in Jamaica Plain. These are the Jamaicaway bike path and the Southwest Corridor bike path, both within a half mile on either side of Centre and South streets. (AC Testimony, p. 20 and Appendix 20, 2001, in the accompanying blue booklet)

H. Factual inaccuracies

For the record, AC notes the following inaccuracies and misstatements in the EENF:

1. “Approximately 90 diesel bus one-way trips per day will be removed from service.” (EENF, p. 4-8) This is inaccurate. The number of diesel bus one-way trips per day that will be removed from service as a result of Green Line restoration is 401. (Service Review: Route 39, p. 4, 1996) A casual review of the current Route 39 timetable will confirm the number.
   
   
2. “Although no vibration induced damage from train operations is predicted, ground borne vibration generated by Green Line trains will result in an increase of vibration events per day, rather than higher levels.” (EENF, p. 5-3) This is inaccurate. The number of vibration events per day resulting from Green Line restoration will decrease from the current 802 events caused by passing buses to less than 600 caused by passing streetcars. For example, the current Route 39 bus schedule lists rush hour bus service at every 4 minutes. Green Line rush hour service has never been contemplated as operating at 4-minute headways. In fact, the Arborway Alternatives Analysis contemplated 6-minute headways. (Arborway Alternatives Analysis, pp. 12, 18, 2001) Therefore, Green Line service is bound to result in a reduction of vibration events, not an increase.
   
   
3. “The Orange Line also serves the corridor and runs in the Southwest Corridor from downtown Boston to the Forest Hills Station…approximately 0.5 miles east of the Arborway corridor.” (EENF, p. 1-7) This is misleading. While portions of the Arborway Corridor and the Southwest Corridor are within one-half mile of each other, other portions of the corridors are more than one-half mile away from each other. (This is similar, for example, to the Riverside and Beacon Street Corridors in Brookline.) Further, and more importantly, because Orange Line station locations are spread out along the corridor, the walking distance to an Orange Line station for most residents within the Arborway Corridor, particularly along its western and northern perimeters, is far more than one-half mile. In addition, the Arborway Corridor serves destinations different from those in the Southwest Corridor. For example, the following destinations among others are in the Arborway Corridor, but not in the Southwest Corridor: Jamaica Pond and much of the Pondside neighborhood, Olmstead Park, the VA Hospital, the Brigham and Women’s Hospital, Children’s Hospital, Arlington Street, Commonwealth Avenue, and most of South Huntington Avenue.
   
   
4. “The Arborway Streetcar Restoration Project may require issuance of a Curb Cut Permit from the Metropolitan District Commission (MDC)….” (EENF, p. 1-13) This is unlikely. Access for streetcars into the Arborway Yard already exists through current curb cuts on both the western and eastern sides of the Washington Street-Arborway intersection. With proper planning, no additional cuts would be needed.

IV. CONCLUSION

While AC is determined to work with the MBTA, BTD, EOEA, and DEP to bring Arborway Green Line restoration to a successful conclusion, two items of concern still need to be addressed.

First, DEP has not yet approved a final schedule for the design and construction of the Arborway project. In its order of November 7, 2001, DEP stated: “The Department requires by this letter that a schedule for the design and construction of the Arborway Project be provided to the Department by December 31, 2001. The schedule shall include benchmarks, milestones and action items and shall be subject to approval by the Department.” To date, it appears that the MBTA has not complied with this order. AC, therefore, urges EOEA and DEP to enforce the order either by prevailing upon the MBTA to comply or by imposing theirown schedule on the MBTA.

Second, the MBTA has provided no funding for the construction of the Arborway project in its current Capital Improvement Program 2003-2008 (CIP). AC views this as a breach of the MBTA’s obligation under the order of November 7, 2001. It is also a violation of the State’s obligations under the State Implementation Plan.