December 5, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Environmental Notification Form (ENF) for the I-90 Allston Interchange Project

MEPA #15278

Dear Secretary Vallely Bartlett:

We sincerely hope that the Allston I-90 Interchange Improvement Project will bring a wide variety of benefits to the Commonwealth, the City of Boston, and those who live, work, and commute in the area. This project, a major change to our urban environment, affords many opportunities to advance important local and state policies and objectives and protect the adjacent neighborhoods from avoidable adverse impact during and after the reconstruction of the rail and highway infrastructure.

Over the last six months, our organizations have been afforded the opportunity to serve on the Task Force organized by MassDOT to provide advice on the conceptualization of how this infrastructure can be redesigned to lay the groundwork for transportation and environmental goals for a new economically viable regional urban center in the midst of Allston. Through our participation in the Task Force we have been greatly encouraged by the degree to which there is evidence of strong consensus on many issues, and the evolution of MassDOT thinking to apparently embrace many of the multi modal and open space enhancement, and city building aspects of this opportunity.

Now that MassDOT has submitted the project ENF, we are deeply concerned that these and other aspects of the current design and process are not being proposed for adequate analysis, consideration and action.  We urge that the MEPA scope provide that improved transparency and consideration of environmental consequences and we request that MEPA scope require serious attention to the issues which we identify.

Key concerns include:

• MassDOT should completely integrate planning and construction of the relocated Pike and the new West Station.
• In the area of West Station, the Turnpike and rail lines should be decked over to enable Smart Growth air rights development and to permit attractive and useful pedestrian, bicycle and bus access to West Station and between North and South Allston. Decking is essential to mitigate the nose and visual impacts from the rail and highway operations so close to residences.
• A wide riverside park, the “Allston Esplanade,” should extend between the BU Bridge and the River Street Bridge. This is appropriate mitigation for the adverse impact to DCR parkland that appears to be inevitable during construction.
• Where Soldiers Field Road is parallel to the Turnpike, it should be moved closer to or under the Turnpike viaduct to allow a widening of the park along the Charles River.
• The Turnpike viaduct should not be widened beyond its current width and should not encroach on the Charles River parkland between the viaduct and Soldiers Field Road.
• Pedestrian and bicycle paths should extend across the project area, across Soldier’s Field Road (on a new bridge structure) and into the Allston Esplanade, both as key elements of the purpose and need of the project and as essential elements of mitigation for likely adverse impacts during construction.
• MassDOT should have an ongoing planning process for the Turnpike Relocation and West Station that involves residents and advocacy groups by incorporating the existing task force as a project Area Committee to provide public involvement throughout the finalization of planning and design and oversight during implementation.

With the exception of the first item – the recent integration of the I-90 Interchange project with West Station – none of these concerns are reflected in the ENF. We hope that with MEPA’s review of the ENF, and the scoping of the DEIR, clear guidance and requirements will be set for the elements of study to address the significant concerns and questions that we detail in the comments below.

Thank you for your attention.

Allston Village Main Streets
Alana Olsen, Executive Director

Allston-Brighton Community Development Corp.
Carol Ridge-Martinez, Executive Director

Allston Board of Trade
Marc Kadish

Allston Civic Association
Paul Berkeley, President

Allston/Brighton Bikes
Galen Mook

Boston Cyclists’ Union
Pete Stidman, Executive Director

Charles River Conservancy
Harry Mattison

LivableStreets Alliance
Matthew Danish

MassBike
Barbara Jacobson

WalkBoston
Wendy Landman, Executive Director

Residents of Allston:
Matthew Danish
Rochelle Dunne
Paola M. Ferrer, Esq.
Anabela Gomes
Bruce Houghton
Wayne Mackenzie
Rich Parr
Jessica Robertson

Cc:
Francis A DePaola, MassDOT Highway Division
James Cerbone, MassDOT Highway Division
Mike O’Dowd,MassDOT Highway Division

Introduction

The Environmental Notification Form submitted by MassDOT has a limited focus that addresses only the Turnpike reconstruction, ramps to neighborhood streets, and West Station. Though these elements may indeed be focal, they are not the only elements of a project that will have enormous environmental impacts on Allston and adjoining neighborhoods. The ENF has omitted many of the important issues and options that have been the focus of Task Force comments, and that would lead to meeting the strongly expressed community goals of reconnecting neighborhoods with transportation facilities, creating an enhanced mix of walking, biking and transit options, and providing for mixed use development opportunities in the future.

We are particularly disheartened by the lack of transparency evidenced by specific assertions in the ENF that the Task Force has vetted the particular approach expressed in the document during its ten meetings. Exactly the opposite is true. An example is the assertion by MassDOT that the viaduct will be reconstructed to consist of four travel lanes in each direction, incorporating shoulders and a breakdown lane. This proposal by MassDOT would require that a portion of the viaduct be built in or cantilevered over existing parklands. The Task Force expressed concerns about this option, that it would actually make the road less safe by encouraging higher speed travel, and that MassDOT should not permanently take Charles River parkland to widen the highway.  However, MassDOT has not adequately evaluated reconstructing the viaduct in its present dimensions and avoiding taking of any parkland.

The example cited above has guided our investigations of the ENF contents. We are deeply concerned that conclusions drawn by MassDOT are not transparent and that a comprehensive and detailed examination of the future of the area is not included in the presently proposed work activities for the DEIR. The DEIR should address the community’s concerns about access, development and implementation.

A. STUDY AREA BOUNDARIES

The study area boundaries do not adequately include adjacent parts of the community where the project will have impacts. The study area boundaries should be modified to permit a full analysis as listed below. Other environmental concerns such as water quality may require study area changes in addition to those described below.

• Connections to the Allston Esplanade

The study area should extend to Cambridge Memorial Drive (it now stops at Soldiers Field Road) to incorporate the esplanades on both banks of the Charles River, the reconstruction of the existing structurally deficient two track Grand Junction bridge, and an appropriate pedestrian and bicycle connection between the Cambridge and Boston Esplanades. The proposed stairs and ramps of a new pedestrian crossing adjacent to the river will be partially outside of the presently defined study area, and require a change in the study area boundary to detail the best connections of the new crossing into the narrow strip of land between Soldiers Field Road, the river’s edge, and the existing path through the parkland.

• Connections to Commonwealth Avenue

The study area on the south side of the highway and rail yard should extend to Commonwealth Avenue, because of the need to examine the potential for cross-town pedestrian, bicycle and bus access connecting North Allston to West Station, Commonwealth Avenue and the MBTA’s Green Line. The study should include potential changes in land use and employment in and near Commonwealth Avenue, where institutional development will have a significant impact on future pedestrian, bicycle, bus, Green Line, and West Station traffic.

• Noise and vibration impacts

Noise and vibration impacts should be studied in adjacent neighborhoods in the Allston sections of the Turnpike reflecting highway, rail storage yard, West Station and rail operations. Noise impact analysis should extend north of Cambridge Street into North Allston along the Lincoln Street frontage of Allston – an area with recurring noise and vibration impacts from the Turnpike. Noise impact analysis is also required, as requested by residents, in the nearby neighborhoods in Cambridge which are particularly exposed to noise from the elevated Turnpike.

• Air quality impacts

Air quality analyses should be performed for adjacent neighborhoods in both Boston and Cambridge, on all sides of the projects area, but now outside the study area.

• Traffic impacts

The study area should include Harvard Avenue and Linden Street, Western Avenue, River, Malvern, Alcorn and Babcock Streets, and Commonwealth Avenue for a fuller understanding of traffic and land use impacts. Auto and truck traffic should be examined separately because trucks are not allowed on Storrow Drive and therefore use neighborhood streets for access into the Longwood Medical Area, Back Bay and elsewhere.

B. NEED FOR THE PROJECT

Discussion of the need for the project is minimal and there is room for significant improvement. For example, as cited by the ENF, defining a major need: “The Beacon Park Yards and the I-90 interchange have prevented direct and convenient access from Cambridge Street in North Allston to areas of Allston south of the rail yard.” (ENF, page 4)

• The DEIR should include detailed analysis of current and potential connections between North Allston, Cambridge Street and Commonwealth Avenue to evaluate the possibilities for pedestrian, bicycle, bus and general traffic, improving neighborhood cohesion, and minimizing cut-through traffic that negatively impacts residents and businesses on streets including Cambridge Street, Linden Street and Harvard Ave.

The shape and type of future land development should help determine the street network, the pattern of development parcels, and access by motor vehicles, pedestrians, bicycles and buses to sites of future development, both north and south of the Turnpike. The 150-acre study area is very significant in terms of land made available for private and institutional development because of the implementation of this project.

• The DEIR should examine potential land development patterns and how they are affected by different project alternatives including street layout, vertical geometry of streets and ramps, vehicle and pedestrian access into and out of parcels as affected by ramp vs. street configurations, traffic patterns, and parcel size and depth.
• The DEIR scope should include the identification of specific actions to mitigate the historic damage to neighborhood connectivity and to establish appropriate connections to support a thriving unified urban district. 

The study area being so large provides an excellent location for institution of the MassDOT mode shift goals that call for tripling the mode share of transit, walking and biking, a basic transportation need for the future sustainability of service provided by all modes.

• The MEPA scope should reference and flesh out the transportation options and opportunities resulting from this project and emphasize options that provide for user-friendly, pleasant access by walking, biking or taking transit between Commonwealth Avenue and Cambridge Street and connections to the rest of the study area.

C. COMPONENTS OF THE PROJECT

The components of the project described in the ENF should be more comprehensive and clearly analyzed in the DEIR.

1. I-90 Viaduct

The proposal to completely reconstruct the viaduct to modern interstate highway design standards is stated in the ENF to consist of four travel lanes in each direction, incorporating shoulders and a breakdown lane in each direction. This requires a portion of the viaduct to be built in and/or cantilevered over existing parklands and is the only alternative presented to date.

• Alternatives for the design of the viaduct should be clearly stated and analyzed in the DEIR including an option that maintains the viaduct at its existing width and location. This option is preferred by many Task Force members but not included or mentioned in the ENF. The consequence of cantilevering a highway over parkland will raise 4(f) questions and result in air quality and noise impacts to the parkland.
• Additional options for the design of the viaduct are possible, including an on or below grade which could provide further mitigation for adverse construction impacts from the reconstruction process. 

Lowering the design speed of the Turnpike could allow modifications to vertical and horizontal geometry that will minimize impacts and improve opportunities for Smart Growth economic development.

• The I-90 viaduct alternatives should include an option based on a reduced design speed to benefit the land use and open space impacts of the project and improve safety on the Turnpike. Since MassDOT recently constructed the Big Dig with significant variations from FHWA interstate design standards, we know Massachusetts has the capacity and ingenuity to fit highway projects into constrained urban environments in a manner to allow future multi-modal, mixed use and open space benefits to the surrounding community. Big Dig design exceptions explored and implemented in Chinatown, the Financial District, the Waterfront and the North End should be explored in Allston.
• “No access” limitations on the proposed ramps and street network options should be revealed in the DEIR, in both maps and text. MassDOT should present alternatives that minimize the extent of these restrictions, as limiting general access to local streets and Turnpike connections negatively impacts land development and will affect roadway speeds throughout the area, which in turn promotes safety for all modes.

2. Soldiers Field Road

Moving Soldiers Field Road away from the riverbank is an essential element of the project.

• The proposal to move Soldiers Field Road away from the river should extend fully between the BU Bridge and the River Street Bridge to provide new parkland, paths and local street connections.  Planning for Soldiers Field Road should be a principal and formative element of the Turnpike interchange project that feeds the roadway, parkland and path network in the new community being created as part of this project.
• The Boston Society of Architects has suggested such a park-like entrance to the study area, framed by a crescent relocation of Soldiers Field Road and we request that the MEPA scope include development of such an improvement as mitigation for the construction impact on parkland and as a part of the basic purpose and need of the project. 

Alternatives studied for the Soldiers Field Road portion of the study area should include:

• Relocation of Soldiers Field Road away from the river, resulting in new parkland – the Allston Esplanade – and pedestrian and bicycle paths along the river between the Turnpike viaduct and the River Street Bridge.
• New egress and access with Soldiers Field Road’s eastbound traffic to help diminish dangerous conditions at nearby intersections.
• A new pedestrian and bicycle bridge over Soldiers Field Road (this would currently be difficult to build because of limited land at the riverside end of a bridge).
• Westbound access from Soldiers Field Road directly into the westbound turnpike frontage road via a vehicle overpass or underpass.

3. West Station

A new major transit station is a welcome component of the project, and a connection between West Station and North Station via the Grand Junction alignment is already included in MassDOT FY2014 – FY2018 Capital Investment Plan. Options for rail connections under the Turnpike viaduct should be included in the DEIR to assure the feasibility of this connection. Options should include examination of the Charles River rail bridge, (now just outside the study area) along with pedestrian and bicycle routes over the bridge.

All options reviewed for the location of West Station should be included in the DEIR, along with a comparative analysis of each location. Analysis of the options should include, for example, these impacts on residences that abut the rail tracks:

• Noise, vibration and air quality impacts resulting from anticipated daily train traffic passing through the station, as well as periodic traffic arriving for vehicle services in the rail yard.
• Noise and vibration impacts resulting from operations of the proposed power substations, the proposed wheel truing track and building, the proposed pit track, the proposed covered track, the crew quarters, and the proposed car wash.

Analysis of West Station layout options should include a detailed discussion of potential operations and these effects on design:

• Location of head house(s) or other access points
• Ridership using commuter rail services.
• Walk-in traffic from both north and south of West Station.
• Bicycle traffic from both north and south of West Station.
• Cross-town or local bus traffic from both north and south of West Station.
• Idle and temporary bus storage near West Station.
• Kiss-and-ride traffic from both north and south of West Station.
• A bus or vehicle garage near West Station.
• Service access for West Station and employee parking.
• Efforts to minimize private vehicle access to the station, and emphasize pedestrian, bicycle and transit access.

4. Transit routes

Examination of local and regional rail and bus services have not yet been provided. All options for potential bus connections across the study area should be explored, and include details of potential connections:

• West Station with rail connections to Back Bay, Downtown and the Seaport area via the route to South Station and to Kendall Square, East Cambridge and the Bulfinch Triangle via the route to North Station
• East-west transit, such as express bus services to Back Bay and Downtown via West Station.
• Local buses
• Links to Green Line stations along Commonwealth Avenue
• North-south transit routes, such as a possible Circumferential Bus transit route connecting transit stations such as Harvard Square and Ruggles with alternative, more direct routes to desired employment destinations between Harvard Square in Cambridge, Boston University, Longwood and BU’s Medical Center in South End.

Options for bus routes serving the study area should be examined, including:

• A bus-only or other connection between Cambridge Street and Commonwealth Avenue across the Turnpike and rail yards via Malvern, Alcorn or Babcock Streets.
• Local bus routes, such as Route 66, diverted into West Station.

Bus access to West Station is extremely important and should receive special attention in the DEIR. We request that the MEPA scope require a thorough examination of future cross-town, local and express bus services, as well as the use of air rights to provide bus access both to and from the station and the adjacent area south of the station nearer Commonwealth Avenue.

5. Bicycle and pedestrian connections

Proposals for pedestrian/bicycle routes should be made to maximize their potential future use.

• The DEIR should explore a network of pedestrian/bicycle connections that are not tied to the web of roadways to provide service in the 3,000 foot distance between Babcock Street and the Cambridge Street overpass of the Turnpike.
• Pedestrian and bicycle connection options should also be examined for Malvern and Alcorn Streets, each very close to the proposed West Station, crossing north-south over the Turnpike and the rail yards.
• The DEIR should thoroughly explore options for walking and biking connections between Babcock Street and the Paul Dudley White Path at the easternmost edge of the study area. Details of the Babcock Street connection to the river should show how it may serve as access to and from West Station. Analysis should include required elevation changes to make the connection.
• Additional north-south pedestrian/bicycle connections across the study area should result in options that provide access to West Station, BU and the local residential community.
• The projected replacement of the existing Lincoln Street pedestrian bridge should be linked to future pedestrian and bicycle routes throughout the study area.

6. Motor vehicle and truck connections

The community has expressed significant concern that roadway connections should be explored that extend from Cambridge Street to Commonwealth Avenue. The DEIR should include an analysis of options that connect Cambridge Street and Commonwealth Avenue that include:

• An option that provides access for pedestrians and bicycles only
• An option that provides access for buses, pedestrians and bicycles only
• An option that provides access for commercial vehicles, buses, pedestrians and bicycles only
• An option that provides access for non-commercial vehicles, buses, pedestrians and bicycles only
• An option that provides access for all motor vehicle traffic, buses, pedestrians and bicycles.

Without an investigation of these options, all traffic going between the Turnpike and areas south of the Turnpike (Back Bay, Longwood Medical Area, Brookline) must either use Storrow Drive or go through Allston via Harvard Street. Because of restrictions on Storrow Drive, this pattern requires ALL trucks to travel through the community.

We request that the MEPA scope require an analysis and comparison of connectivity options between Commonwealth Avenue and Cambridge Street, including access for pedestrians, bicycles, buses, autos, taxicabs and trucks, specifically identifying the impacts on existing problem areas such as Linden Street, Harvard Avenue, Cambridge Street, River Street and the BU Bridge. We also request this analysis to form the basis for an open and transparent discussion with the communityof the options that will be carried forward in the preferred alternatives for both highway and transit connections.

7. Decks over the Turnpike and the rail yards

This large area above the Turnpike and rail tracks, with good regional access and in close proximity to downtown, Longwood Medical Area, Harvard and BU, will generate interest in air rights development from developers and institutions.   Air rights are already a major component of the proposal because they must be used to provide access to West Station. We request that the DEIR include specific options for stages of decking, along with an examination of the methods and means to provide for their construction

The location of the West Station head house, and vehicular and pedestrian/bicycle connections will generate options for future decking.  Potential alternative uses for the decks should be explored and footing locations for air rights development should be included in all designs.

The DEIR should also explore options that use decking to aid in noise and vibration reduction and air quality improvement for nearby residential communities and future development. This is especially important in the area near Pratt and Wadsworth Streets.

Options for the design and integration of West Station into the surrounding parcels should be studied, including the impact on residential quality of life, accessibility of the station, and economic development opportunities. At a minimum, this study should compare designs for West Station comparable to Back Bay Station, Assembly Square Station and Yawkey Station and the ways they would be affected if they were served by decks over the transportation facilities.

We urge that the MEPA scope require the analysis of where decking will be most useful, and require that the project include such decking as part of the initial construction, because decking at the time of original construction is most cost effective and least disruptive, and often the only feasible way to protect abutting land uses from adverse noise and visual effects of rail and highway activities. 

8. The route of the People’s Pike through the development area

The ENF describes routes for a bicycle route at the perimeter of the study area, along either Cambridge Street or along the edge of the Turnpike viaduct/frontage road. New options for the People’s Pike should be explored, including likely desire lines across the middle of the study area. The proposed Pike alternatives should be laid out to go through or adjacent to development areas, and to the Charles River in the large triangular study area south of the new, parallel Cambridge Street and north of the Turnpike. This area currently has no proposals for streets and paths east-west through it.

Options to be studied for the street cross-sections and the street grid should include a People’s Pike with the layout and dimensions of Commonwealth Avenue Mall in Boston’s Back Bay.

Options for a network of connections provided by the People’s Pike should be explored. The need to connect North Allston with the Charles River suggests the DEIR should examine a sidewalk and two-way cycle track along the north side of the existing alignment of Cambridge Street. Similarly, to connect North Allston with the new crossing over Soldiers Field Road, a diagonal alignment through the study area should be one of the options.

The People’s Pike is not only east-west. The DEIR should include options for north-south movement, including but not limited to the paths along the Charles River. These alternative routes should connect with other People’s Pike alternatives with West Station and Commonwealth Avenue.

We urge that alternative routes for the People’s Pike be included in the MEPA scope for the project, as the Pike should be a central, formative element and integral portion of the road and street network to be constructed on the site. As it forms a major circulation connection between parkland and residences and new business opportunities that will come to this site. the Pike should not become an adjunct of either Cambridge Street or the Turnpike ramp and main line network, constructed on left-over right-of-way.

9. Profiles and alignment of the rail and I-90 main lines

The vertical profiles of future rail and I-90 main lines will affect noise and vibration impacts on adjacent residential areas, and can significantly impact future use of air rights over the Turnpike and rail yards. To date, only one possible profile for the highway has been explored. Rail line profiles are also at issue – not only the current single track of the existing Boston-Worcester commuter rail service, but also the rail line service proposed to connect to the Grand Junction tracks for the new rail service between West Station and North Station, via Kendall Square, East Cambridge and the Bulfinch Triangle. No alternative profiles for the rail lines have yet been explored, yet both the Worcester and the Grand Junction pass directly beneath the Turnpike viaduct that is to be totally reconstructed. They will thus become a part of the construction staging for the viaduct, and their final profiles should be examined early in the project.

The assessment of profile options for the rail lines and I-90 main lines should include lower profiles so that the cross streets connecting to West Station and between Commonwealth Avenue and Cambridge Street could be less steep. We request that the scope of the DEIR include examination of lower profiles that might be attained by removal of earth contaminated by 100 years of railroad use of the property. We also request that the MEPA scope require a precise discussing of construction sequence of these essential elements.

10. Land use changes resulting from new development

Proposed development plans in the ENF cover only street and highway options. Options for private or institutional development of the blocks formed by transportation routes should be incorporated into the DEIR. Future land use will be an input to all area traffic models, and the DEIR should show, in maps and text, the land use options that underlie the traffic analysis. Densities of development (which could be quite high in this central and very attractive area for development) should be discussed, along with the residential, business, academic development or recreation possibilities in this significant area in the center of the region.

Land use patterns should also be examined for their relevance to the design of all roads and streets in the area, in terms of cross-sections, pedestrian and bicycle services, landscaping, urban design and access to developable parcels, whether they give access to residential, business or academic uses.

While the provisions of Complete Streets guidelines require sidewalks and bicycle accommodation, certain streets can be expected to have driveways and breaks in adjacent curbs. We request that the MEPA scope of study should define the streets or portions of streets that will not provide access to and from development parcels.

11.  Regional impacts of the project

Travelers using vehicles to pass through this interchange include those going to Back Bay, Downtown, Kendall Square, the Innovation District and the Longwood and BU Medical Areas. Private vehicle drivers have many parkway and local street options for distribution, but trucks from around the region are constrained to use Cambridge Street, Harvard Avenue and Brighton Avenue. An investigation of options outside the study area for new Turnpike connections to Park Drive, Beacon Street or other locations should be undertaken by MassDOT as a method of reducing general traffic in the study area and mitigating impacts during the construction of this project. New connections would reduce traffic impacts on neighborhoods which now serve as a pass-through for many trips with destinations outside the area.  We request that the MEPA scope require a full exploration of these truck-related issues, and recommend appropriate mitigation of the already unacceptable burdens the current traffic pattern imposes.

The western corridor of the region, served by commuter rail, rapid transit, express buses and the Turnpike, remains one of the most heavily used in the region. The Turnpike bears a heavy traffic load and is already congested at many locations in the regional growth centers inside Route I-95/128. Unfortunately, the Turnpike is not expandable and parallel routes are also beyond capacity. If the highly desirable economic growth of the region is to continue, the public transportation mode share must expand exponentially to attract vehicles away from the Turnpike so that it can operate at a more reasonable level of service. We request that the MEPA scope include a requirement for development of an overarching regional context with public input for use in evaluating the planning and design options in Allston.

12.  The Beacon Park Yard Layover Facility

The area around the I-90 Interchange project includes the currently vacant rail tracks known as the Beacon Park Yard, proposed in the South Station Expansion Project (EEA number 15028) to become a major rail layover facility and in this ENF to become the principal layover facility for MBTA commuter rail trains to and from the West/Southwest. The analyses of the South Station/Beacon Park Yard Layover Facility should be included in the DEIR to show its relationship to the rail network, West Station and the I-90 Interchange project, and also the additional impacts brought to the site by the layover facility.

The current document for South Station and the Layover Facility points toward potentially severe impacts of noise, vibrations and air quality within short distances from adjacent residential areas along Pratt and Wadsworth Streets. The DEIR should provide a detailed map of the proposed layover facilities for commuter rail services and the need for including facilities that may generate severe impacts on adjacent residences, such as the proposed wheel truing track and building, the proposed pit track, and the proposed covered track. The DEIR should demonstrate how these and other impacts are magnified by the addition of noise, vibrations and air quality issues from the highway relocation and the new West Station, and how these impacts might be abated by alternative locations for each of these facilities at this site or elsewhere.

We are pleased to note that the South Station Expansion Project includes a role for Widett Circle as a layup facility closer to South Station. We request that the MEPA scope include an analysis of the degree to which a more robust facility at Widett Circle might permit some reduction in size of the new facility proposed for Beacon Park Yard, which could allow more flexibility to mitigate noise and other proximity effects, and consider requiring this modification as a mitigation measure in the study area.

13. Construction impacts

Removing a significant highway interchange is complicated and will involve many steps to accomplish safely for all users – highway, pedestrian, bicycle, bus, rapid transit and truck. The staging of construction should be detailed in the DEIR, to report on potential influences of staging on the final design of street networks and ramps, land development, pedestrians, bus and bicycle ways. Staging of construction has not yet been discussed, and both the area and the project are very complicated. Thus, staging should be considered an ever-present and potential reason for modifying the design and should include detailed discussions with the community.

D. COMPLIANCE WITH STATE POLICY GOALS

MassDOT should evaluate how its proposed improvements further the following Commonwealth of Massachusetts policy goals and how these goals work together to mutually reinforce one another and strengthen the Commonwealth’s efforts to reduce its dependence on single occupant vehicles. These policy goals are embedded in the MassDOT Transportation Impact Assessment (TIA) Guidelines, instituted in March of 2014.

1. MassDOT Mode Shift Goals
2. MassDOT’s Design Guide standards on Complete Streets
3. The Global Warming Solutions Act
4. The Massachusetts GreenDOT Policy Initiative
5. MassDOT’s Mode Shift Initiative
6. The inter-agency Healthy Transportation Compact
7. The Healthy Transportation Policy Directive
8. The Massachusetts Ridesharing Regulation
9. MassDOT’s Safe Routes to School

Each of the above policy initiatives must be supported through implementation of project elements that provide for a multi-modal transportation development review and mitigation process. These elements emphasize transportation-efficient development and enhancement of transit, bicycle, and pedestrian facilities, as well as foster implementation of on-going, effective Transportation Demand Management programs. We request that the MEPA scope require explicit use of these policies as drivers of planning and design as well as evaluation criteria for decision-making.

E. Further community involvement

This project is one of the most complicated and consequential MassDOT proposals in recent years. Because it involves so many actors and agencies, it is difficult for participants to grasp and understand. In particular, it is difficult for adjacent neighborhoods to monitor because the information provided is complex, but to date has been limited in its explanations, assumptions, and both the agency and the public decision-making process. In light of the investment in getting conversant with complex technical issues which has been made by the existing Task Force members, we propose that MEPA reconstitute the existing Task Force as the Project Area Committee for the remainder of the environmental process, development of design build contracts and eventual oversight of implementation.

To ensure continuous community monitoring, we recommend that the Secretary follow the precedent established by the September 14, 2007 certificate establishing a special review process for the Harvard University – Allston Campus 20 year Master Plan and create a Citizens Advisory Committee that should be empowered to:

• Meet with MassDOT and its consultants on a monthly basis.
• Hire its own third-party consultant to review and evaluate MassDOT’s preferred alternative and other related proposals and be supported with a budget of $300,000 provided by MassDOT to fund the consultant who will work for and under the direction of the CAC.

F. Funding considerations

We have been concerned to hear some discussion that only the highway portions of the Allston initiative have secure funding and fear that fundability could be a basis to undermine the environmental integrity of the process. We realize that project funding is not usually a part of MEPA review, but we believe that this project is unique and can readily be built in an integrated manner that will result in savings from designs that are interrelated and construction. This is true of not only the public expenditures, but also those of private developers and the principal landowner of the study area. We request that the MEPA scope include exploration of public-private methods of constructing the transportation facilities, including the required transit, pedestrian, bicycle and open space facilities, as well as early decking to promote air rights development over the transportation facilities.