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Comment letters on the DEIR must be sent by Friday, January 8. Keep reading for details.
STEP urges strong and considerate support for the efforts of MassDOT to move the Green Line forward with the release of the Draft EIR. The state has committed over $1 billion to the Green Line Extension.
We support a continued “Green Light for the Green Line” AND proceeding with care.
We must “DO IT RIGHT” if this project is to sustainably serve the next three generations.
Somerville and its citizens applaud the release of the Green Line Extension DEIR and offer sincere thanks to MassDOT for committing to a Route 16 terminus, to full design of the Community Path, and to continued analysis of alternate locations for the maintenance and storage facility. The DEIR represents a critical milestone in the public evaluation process and allows for preliminary project engineering to begin. We appreciate the opportunity to comment on MassDOT’s work thus far. We encourage fellow residents, our neighbors and local business owners to submit written comments prior to January 8, 2010.

Station Design & Siting

• Green Line stations must connect as seamlessly as possible with all other clean modes of transportation, including current and re-routed buses. Station design should accommodate bus drop off and pick-up (for example, using bus pull-out pockets or curb extensions) with maximum integration of transit modes and minimal street disruption. Optimized bus routes connecting to Green Line stations should be implemented simultaneously with the start of Green Line service, as was done for the Red Line northwest extension.
• Station designs should allow for car drop off, but not parking, and present ease of pedestrian and bicycle access by locating station headhouses on major streets whenever possible, with station access from both sides of the street and in all directions of travel. Sidewalks leading to headhouses should be widened and additional crosswalks considered near stations. This will maximize transit use.
  • Mass DOT, working with community representatives should reconsider station designs to maximize ease of access particularly where riders will access stations at overpass bridges to maximize ease of access, efficiency and lower construction costs. Pedestrian and bus access to stations and high station visibility from major streets should be prioritized.
• Stations should provide adequate bicycle storage. This should be calculated based on a percentage of 3 to 5% of boardings at the stations. Bicycle storage should be sheltered from the elements, especially at Route 16, Lowell Street, and Union Square stations, to enable all-weather access.
• The Federal Transit Administration has issued a proposed change to bicycle/pedestrian access to public transportation recognizing the importance of maximizing multi-modal access. The proposed policy states:
  • For purposes of determining whether a pedestrian or bicycle improvement has a physical or functional relationship to public transportation, regardless of whether it is funded as a capital project or public transportation enhancement, all pedestrian improvements located within one-half mile and all bicycle improvements located within three miles of a public transportation stop or station shall have a de facto physical and functional relationship to public transportation. According to a test of activity and use, pedestrian and bicycle improvements beyond these threshold distances may be eligible for FTA funding if the improvement is within the distance most people can be expected to safely and conveniently walk or bicycle to use that particular transit service. Federal Register: November 13, 2009 (Volume 74, Number 218), http://edocket.access.gpo.gov/2009/E9-27240.htm.
• The new Green Line stations should be designed with elevators and should not include escalators, which are expensive to install and maintain. Wide staircases and ADA elevator access are sufficient. Reallocate the escalator budget for other station elements recommended in this letter.
• Constructing the new station platforms with ADA-compliant level boarding for low-floor Green Line cars that have sliding rather than accordion doors currently used on Green Line cars.
  • System-wide accessibility should be the goal of the MBTA. To accomplish this the MBTA should replace accordion-style Green Line car doors with sliding doors that are compatible with level boarding. Raise all other station platforms in the Green Line system for level boarding, and order sliding doors in the new Type 9 rolling stock and retrofit all existing Green Line cars. This system-wide change would eliminate the need for time-consuming wheelchair ramps and mobile wheelchair lifts, while speeding up all passenger boarding.
• Station and station area designs must be developed through a formal and interactive community participation process to ensure that they fit into existing neighborhoods and support appropriate future mixed use development. Takings should be minimized to save the state money and to preserve land uses.
• Design for the relocated Lechmere Station should pay particular attention to the East Cambridge Planning Team’s pedestrian-friendly area design ideas and old Lechmere Station re-use suggestions. The terminus at Route 16 should incorporate MGNA’s ideas for minimizing takings.
• Station design and siting should involve active participation of knowledgeable transportation accessibility advocates to ensure accessibility requirements are adequately addressed.

Community Path Integration & Preservation of Corridor Transit Potential

• Track design and construction should enable adding future stations – between Lechmere and Washington Street / Union Square, between College Avenue and Route 16, and along a future Green Line extension to Porter Square that could serve both Cambridge and Somerville neighborhoods.
• The Community Path and its important station connections must be designed and constructed simultaneously with the Green Line extension in order to facilitate direct pedestrian and bicycle access to the stations and to ensure a safe, attractive, and highly-functional Community Path.

Economic Development & Regional Corridor Planning

• Track, station and Green Line corridor area designs must provide full roadway and community access to Brickbottom Inner Belt and Lechmere Station through reconstruction of Route 28 as a neighborhood and local business friendly surface boulevard that serves pedestrians and bicyclists as well as cars. Improved connectivity between both sides of Route 28 is crucial for economic development, pedestrian station access, and improved quality of life.
• State and other leading Transit-Oriented Development guidelines should be utilized to promote strategic regional economic development within a mixed use context in the Brickbottom Inner Belt and Union Square Boynton Yard districts. Maintaining diversity in people and businesses while improving the natural environment is critical. Access to open space and greenery promotes health.
• The design and siting of the maintenance facility should not prevent development of a street grid in Inner Belt/Brick Bottom that enables access from North Point, McGrath-O’Brian Highway and Washington St.

Maintenance Facility & Regional Environmental Justice

• More detailed analysis of Mirror H, Option L and Option L alternative is necessary. The siting of the maintenance facility and storage yards should not increase the transportation infrastructure and environmental burdens in Somerville or interfere with proposed economic development in the Brickbottom Inner Belt area.
• Current use of the Boston Engine Terminal for the maintenance of diesel engines serving the commuter rail network south of Boston needs to be phased out and a new facility built south of Boston to eliminate the unsustainable and unjustifiable shuttling of trains through Cambridge.

Public Participation

• A project-wide Citizens Advisory Group should be maintained throughout detailed design, engineering, construction and start-up phases with smaller local advisory groups established to work with the MBTA and consultants to address specific station design, land use, connectivity, and construction and mitigation issues.
• A procedure for determining remedies and/or compensation, incorporating community representation, should be required to handle instances when project mitigation proves insufficient to meet pre-agreed impact standards for noise, vibration, pollution and other environmental burdens.
• MEPA should require collaborative planning, with community involvement and public coordination that should intensify immediately, before this project progresses and require that senior project staff work our of a centrally located field office to maximize access.

Public Comment Process
Public comments on the DEIR/EA should be made to the Secretary of Energy and Environmental Affairs, through the Commonwealth’s MEPA process. The federal government conducts its own review of the document to ensure adequacy of the document under the federal National Environmental Policy Act (NEPA) process, and accepts public comment to the NEPA process in two ways:
First, the comments made at the November 18 Public Hearing will be included in a transcript that will be submitted to the Federal Transit Administration (FTA).
Second, EOT will compile the comment letters submitted through the MEPA process, along with responses to these comments, and provide them to the Federal Transit Administration after the completion of the DEIR comment period.
There has been considerable discussion about whether to accept the DEIR as a Final Environmental Impact Report (FEIR) or to require that it be treated as a DEIR and demand that changes be made in a subsequent FEIR.
To avoid the significant delay that a separate FEIR would entail, the most critical issues with the DEIR could either be addressed in a Supplemental EIR, or in Addenda to the FEIR. These issues include:

• Eliminate the Yard 8 Option for the Maintenance Facility and require a full analysis of Scheme L and the alternate Scheme L designs.
• Commit to a collaborative public process for the next phase that would provide oversight and station area participation and develop a process for addressing mitigation concerns.
• Integrate the Community Path into the design, planning and funding of the Green Line extension.
• Coordinate the Green Line extension with calming of the McGrath/O’Brien Highway in Cambridge & Somerville.
• Designing and constructing the Mystic Valley Parkway / Route 16 terminus at the same time as the rest of the project.

All written comments must include EEA #13886
And be submitted by email, fax or mail to:
Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
MEPA Office
Attn: Holly Johnson, MEPA Analyst
EEA #13886
100 Cambridge Street, Suite 900
Boston, MA 02114
Email: Holly.S.Johnson@state.ma.us
Fax: 617-626-1181