December 11, 2019

Jeffrey McEwen
Division Administrator
Federal Highway Administration
55 Broadway, 10th Floor Cambridge, Massachusetts 02142
Jeff.McEwen@dot.gov

Michael O’Dowd
Acting Director of Bridge Project Management
Massachusetts Department of Transportation
10 Park Plaza, Suite 6340, Boston, Massachusetts 02116
Michael.ODowd@dot.state.ma.us

Mr. McEwen and Mr. O’Dowd,

Thank you for the opportunity to comment on the Allston I-90 NEPA Scoping Report. This project, which includes rebuilding the I-90 Allston interchange and creating a major new transit station, will have a huge and lasting impact on hundreds of thousands of people who both live in and travel through Allston daily by car, train, bus, on foot, and bike. It will alter the street pattern of Allston, the shoreline of the Charles River, the air, water and noise environment in myriad ways for decades to come, and has the potential to create positive transformative benefits for the neighborhood and the region if and only if, we undertake the necessary study and analysis to assure that we make the best choices among real build alternatives based on data and understanding of tradeoffs.

Our comments on the Scoping Report will be organized into three sections: I. Purpose and Need, II. Alternatives Analysis, and III. FHWA role in the Public Process. We begin our comments by offering an outline of our comment letter with a brief summary of the key points in each section:

I.​ ​PURPOSE AND NEED

A. Omissions of Important Elements from the Purpose and Need

There are a number of project elements that we are pleased to see in the statement of Purpose and Need. However, very important considerations have been omitted, the most important of which is neglecting to include studying the long-term impacts that the existing I-90 has had on the Environmental Justice communities, parkland, and historic resources in the vicinity of the roadway over the seven decades since it was built.

B. Remove​ an Unsubstantiated Element from the Purpose and Need
Midday commuter rail layover is included in the Purpose and Need, despite the fact that the need for this layover has never been quantitatively demonstrated as part of the Allston I-90 planning process. Furthermore, in light of the recent MBTA Board vote to make major changes to the commuter rail system, any previous analyses of midday layover needs are obsolete.

II.​ ​ALTERNATIVES ANALYSIS

A. Selection of a Single “Build” Alternative for the DEIS

We cannot overstate the deficiency of a Scoping Report that restricts its work to studying a single “build” alternative for such a huge and complicated project. Such a limitation does not respect the intent and spirit of the NEPA regulations. Studying a single “build” alternative will not allow us or you to arrive at sound, well-documented decisions that will earn the full public support this project needs. There are too many important project elements that are either unresolved at this point or they are not reflected in the proposed build alternative.

B. Inaccuracies in the “No Build” Alternative

The “No Build” alternative includes midday commuter rail layover, yet this use has never existed in Beacon Yards and would introduce new environmental impacts to the surrounding area. It is inaccurate and inappropriate to include midday layover in the “No Build” alternative.

C. Deficiencies of the Proposed “Build” Alternative

There are two crucial deficiencies in the single “build” alternative proposed in the Scoping Report; namely, 1) the proposed design of West Station unacceptably limits the potential frequency of service at West Station and is incompatible with the MBTA Board’s endorsement of the Regional Rail Vision; and 2) the construction phase of the “Modified Hybrid” throat alternative will cause severe negative impacts to the Charles River.

D. Alternatives that Should Not Be Dismissed from Further Study

The Scoping Report proposes to cease analysis of the original “Flip” alternative for West Station, thus ignoring the fact that the station design performs much better than in the “Modified Flip”. The original Flip includes a linear buffer park and the Cambridge Street bypass to buffer adjacent neighborhoods from highway and rail impacts, and the original “Flip” also provides direct multimodal connections from Allston Village to West Station and the Charles River. The Report proposes to study a single alternative for the “Throat” section, eliminating the all at-grade alternative. However, the severity and duration of the construction impacts of the Modified Hybrid are such that evaluating a single “build” alternative does not meet the NEPA and Section 4(f) standard of “all possible planning” to avoid, minimize, and mitigate impacts.

E. Additional Alternatives that Must Be Analyzed

Several additional important alternatives are absent from the Scoping Report and must be added to and evaluated in the DEIS, including: 1) Regional Rail frequency of service at a multimodal West Station; 2) elimination of the proposed layover yard; and 3) elimination of the proposed express tracks.

F. Additional/Modified Project Elements that Must Be Included in All Alternatives

A number of stakeholder priorities that are compatible with any of the West Station and Throat alternatives should be incorporated into the Scope, including: 1) constructing–rather than not precluding–a bicycle and pedestrian bridge from Agganis Way to the Paul Dudley White Path; 2) a design for the Franklin Street crossing that eliminates switchbacks; and 3) designs for Cambridge Street and the new surface streets that adhere to Complete Streets and Vision Zero principles.

G. Additional Topics of Analysis that Must Be Included in the DEIS

Every build alternative will result in significant environmental impacts, yet the Scoping Document and the MassDOT planning process to date contain little discussion of mitigation for those impacts. In order to properly evaluate alternatives, it is necessary to consider the opportunities for mitigation that each alternative entails so that the tradeoffs can be considered. In addition, a maintenance of mobility plan must be developed for the ten-year construction period, and this essential part of the project should be included in the DEIS.

III. ​FHWA AND FTA CONTINUING INVOLVEMENT IN THE PUBLIC PROCESS

Over the past five years, the Mass Pike Task Force has worked collaboratively with the MassDOT team, and the project has improved immensely as a result. We are deeply concerned that FHWA has ceased its participation in the Task Force. It is essential that FHWA and FTA participate in the Task Force, even if only as a regular observer throughout the remaining steps in the process, in order to gain a first-hand understanding of all the discussions that will occur.

Thank you for your consideration of our comments on the NEPA Scoping Document. We believe this project has the potential for once-in-a-lifetime benefits for people traveling on all modes through the project area, for people living and working in surrounding neighborhoods, and for historic and natural resources, and thus we urge you to make the following modifications to the project purpose and scope.

SECTION I. PURPOSE AND NEED

We were encouraged to see that several elements which are longstanding stakeholder priorities are included in the Purpose and Need. Specifically, in Section 2.2, Project Need, C.2 acknowledges the growing ridership on the Worcester Main Line and the need for new multimodal connections; D.2 cites the deficiencies of the Paul Dudley White Path in the project area; D.3 and D.4 recognize that the existing infrastructure alignments have long created barriers and that new multimodal connections throughout the project area and to the Charles River are needed. ​We applaud FHWA for looking not only at the highway itself but also including in the Project Purpose key stakeholder priorities such as addressing the visual impact of the viaduct, building West Station, and improving the Paul Dudley White Path.

Nonetheless, we want to elaborate on several items of concern regarding the Purpose and Need.

I.A. Omissions of Important Elements from the Purpose and Need

1. Franklin Street bridge and Cambridge Street overpass
   The need to replace both the Franklin Street bridge and Cambridge Street overpass has never been disputed and should be included in the Purpose and Need.
   The I-90 Viaduct is not the only structurally deficient viaduct in the project area: the Franklin Street pedestrian bridge and Cambridge Street overpass were both identified as structurally deficient before the I-90 interchange project began. Indeed, the northwest sidewalk on Cambridge Street has been closed since 2012. The Franklin Street pedestrian bridge is a crucial and heavily-used connection between Allston Village and Lower Allston, as well as for bicycle traffic from Cambridge, Somerville, and points north, to Brookline and the Longwood Medical Area and points south. The existing bridge is not designed to ADA standards, the steep grades make travel difficult for people with mobility impairments or pushing strollers, and the bridge becomes treacherous in snowy conditions.

2. SafetyItem B of the Project Purpose, ​Address Safety Issues​, should include redesigning Cambridge Street to improve safety for all users, and ensuring that new surface streets are designed in accordance with MassDOT’s and the City of Boston’s guidelines for urban multimodal streets and the City of Boston’s Vision Zero policy and 25 mph speed limit.

   The Purpose and Need correctly identifies safety as an important aspect of the project purpose. However, it is too narrowly worded in considering only the safety issues associated with the highway and its on-ramps. Multimodal safety along Cambridge Street was one of the first issues raised when the project was initiated in 2014. Since the original construction of the Mass Pike, Cambridge Street has been treated like an extension of the on- and off-ramps. both because of its design, and–as a result of that poor design–in the behavior of motorists. This condition​ ​has significantly deterred use of Cambridge Street by cyclists, pedestrians, and bus riders,​ ​and tragically has had deadly consequences for some of these non-vehicular users who have braved Cambridge Street.

3. Mobility and Transportation AccessItem D of the Project Purpose should be revised to acknowledge the need to connect the two halves of Allston to each other, and to assert that multimodal (pedestrian, bicycle and bus) connections will be built–not just not precluded–to serve the land that is being opened for development.

   Item D of the Project Purpose, ​Improve Mobility and Transportation Access within the Project Area,​ rightly emphasizes new connections from surrounding neighborhoods to the Charles River and acknowledges the need to provide access to the new mixed-use district that will be created nearby as a result of the project. However, there are two shortcomings with how this item is written. First, the Allston, Brighton, Brookline, and Boston University neighborhoods need new connections to the Charles River, AND they need new and improved connections to each other. Second, the Project Purpose states: “The Project would ​not preclude​ multimodal transportation access within the Project Area” (emphasis ours). Multimodal transportation access must be more than not precluded; it must be constructed.

4. Environmental JusticeImprovement to noise and air quality conditions for residential neighborhoods that abut the highway and rail infrastructure must be included in the Project Purpose.

   The project area is surrounded by Environmental Justice communities that have long been subjected to damaging noise and air pollution, which have been proven to have a multitude of damaging health impacts. According to the FHWA: “Transportation also is a source of pollution, generating air, soil, water, and noise pollutants, including particulate matter, carbon monoxide, nitrogen oxide, and carcinogens. Reports by the American Public Health Association and others have linked air pollution to negative health outcomes, including asthma, respiratory illness, heart disease, poor birth outcomes, cancer, and premature death.” ​Yet the Project Purpose as currently written omits any mention of the impact of I-90 and rail infrastructure on air quality and noise levels in adjacent residential areas and parkland. This must be corrected.

5. Impacts on Parkland and Historic Resources
   Improving the quality and extent of the river parklands, providing for the storage and treatment of stormwater, prohibiting degradation of the ecological health of the river, and acting on the need to provide significantly greater human access to the river’s edge must be included in the Project Purpose.
   While upgrading the Paul Dudley White Path as a pedestrian and bicycle facility is included in the Project Purpose, discussion of the historically-protected parkland in the Charles River Reservation is omitted, as is any mention of the impact of I-90 and Soldier’s Field Road on water quality and the ecological conditions of the Charles River.

I.B. Remove an Unsubstantiated Element from Purpose and Need

1. Regional Rail/layover yard study
   It is premature to include midday commuter rail layover in the Purpose and Need. Instead, the layover yard and its relationship to Regional Rail should be included as one of the alternatives to be analyzed in the DEIS and compared with non-Allston sites for effectiveness and costs.Item C.3 in section 2.2 Project Need states that “The MBTA has determined that the layover capacity is insufficient to store trains and conduct midday servicing activities. While there is the possibility of increasing layover capacity at other facilities, the MBTA currently identifies Beacon Park Yard as the best layover location to address current and future layover deficiencies from South Station to points west.” Since the concept of commuter rail layover was introduced to the project, MassDOT and MBTA have been asked repeatedly to share with the public and the Mass Pike Task Force their analyses of the MBTA’s layover needs, of alternative layover sites, and how the sites studied would relate to future rail service. Furthermore, the ​MBTA Fiscal Control Board voted on November 4, 2019 to advance the concept known as Regional Rail, which would involve increasing the capacity of the passenger rail service during both peak and off peak hours, using available equipment for significantly increased midday service, rather than midday layover. This decision highlights the necessity to study midday layover in Allston as an alternative to be analyzed, not an element of the Project Need.

SECTION II. ALTERNATIVES ANALYSIS

At the heart of the NEPA and Section 4(f) regulations is the requirement to consider a reasonable range of alternatives that accomplish the purpose and needs of a project while avoiding, minimizing, and mitigating impacts. We therefore offer below our comments for modifications and additions to the proposed “Build” alternative that need to be analyzed in the DEIS​.

We greatly appreciate that the Allston I-90 NEPA Scoping document incorporates many project improvements that have emerged out of the collaborative process between the MassDOT team and the Task Force over the past five years. Some of these positive examples include:

• The project was shifted from a suburban interchange design to an urban design early in project development.
• Cambridge Street and new streets in Beacon Yards were designed to become part of the urban grid and adhere to Complete Streets guidelines.
• The multimodal West Station was included in the project and, in an improvement over the DEIR, is no longer delayed to a future phase.
• A bus, bike, and pedestrian connection from West Station to Malvern Street was included in the project.
• Soldiers Field Road was shifted west into Beacon Yards to allow for a more generous park along the Charles River.
• An at-grade bicycle and pedestrian connection from Cambridge Street South to the expanded Charles River parkland was added over a sunken Soldiers Field Road.
• An alternative that places the turnpike at grade through the entire project area was selected.

These are big changes and are applauded by Task Force members. However, we are concerned that some important alternatives and elements of the project have been omitted from the NEPA scoping report, at the same time as other alternatives–which have broad support–are being dismissed from further consideration. The paragraphs below focus on the necessity to modify the Scope so as to include the full analysis of specific alternatives so that the DEIS can serve its intended purpose, namely to understand and compare the relevant options presented for the I-90 Allston Multimodal Project in terms of engineering, traffic and transportation, environmental conditions, parklands, constructability, costs and other criteria.

II.A. Selection of a Single “Build” Alternative for the DEIS

Additional “build” alternatives must be part of the DEIS. We ask MassDOT to consult with the Task Force in establishing additional alternatives as described in the comments below.​ ​We are concerned that the NEPA Scoping Report proposes to study a single “build” alternative. This does not respect the intent and spirit of the NEPA regulations, and does not provide an opportunity to address deficiencies of the proposed “build” alternative nor does it provide a way for official comparison of the favored option with alternatives containing separate and distinct elements that have been eliminated from further public discussion.

II.B. Inaccuracies in the “No Build” Alternative

The No Build alternative must not include a layover facility, a use that has never existed in the location.​ ​The description of the No Build option in section 3.2.1 of the Scoping Report states, “MassDOT would continue to use the existing tracks, as of by right [sic], for layover of commuter trains within the MBTA easement, needing only minor modifications to the yard leads.” These tracks have never been used for MBTA layover, and therefore the word “continue” is inaccurate and in fact this would be introducing a new use, and new impacts, in the project area.

II.C. Deficiencies of the Proposed Build Alternative

1. Service at West StationThe design of West Station in the “Modified Flip” alternative (the only “build alternative” carried forward the NEPA Scoping Report) introduces unacceptable operational constraints that severely limit the frequency of service at the station.

   On November 4, 2019, the MBTA’s Fiscal Management and Control Board voted that: “the assets of the commuter rail system of the future will be more similar to rapid transit providing all day service at intervals on its most dense corridors at 15-20 minute headways”. This directive is incompatible with MassDOT’s current planning for West Station based on the MBTA’s 2017 Service Delivery Policy which provides for only 3 trips during the 4-hour AM Peak, 4 trips during the 3.5-hour PM peak, and one train every three hours at all other times. The current three-track West Station design would permit only this minimal level of service, and not higher-frequency, bidirectional service.

   With a single-track crossover at each end, service could be provided in only one direction. Four tracks are required to provide adequate bidirectional service, which is necessary due to plans for a very large mixed-use development surrounding West Station which will generate new travel demands in both directions, as well as transfers to and from future service on the Grand Junction line. Additionally, requiring trains to cross over mainline tracks to access West Station, rather than simply straight-lining all trains through West Station, will cause disruptions to service on both tracks of the main line, leading to cascading delays for any conflicting movements. Finally, the additional interlockings required for the turnouts to and from West Station will add significant capital costs and operational expenses to the portion of the railroad for an unproven, and likely negligible, benefit.

2. Negative impacts to Charles River/Parklands and Soldiers Field Road
   MassDOT’s proposed construction phasing for the “Modified Hybrid” Throat Alternative creates severe negative impacts to the Charles River, Soldiers Field Road, and parklands with no analysis of or commitments to parkland improvements and ecological restoration in the final condition.MassDOT proposes to line the riverbank with sheet piling, reconstruct Soldiers Field Road in the river on a 1⁄4 mile long, 81’ wide bridge, place the Mass Pike partially on fill in the Charles River, and at the conclusion of the 10-year construction period, remove the pilings, fill, and bridge, which would disrupt the river’s ecosystem when built and cause harm to the river all over again when removed. ​This decade-long relocation of highway infrastructure into the river and its parks is being labeled “temporary,” however the level of disruption to the River is so severe that it must be treated as permanent for permitting purposes.

   These construction impacts were not known when Secretary Pollack wrote in January 2019 that MassDOT had “all of the information needed to select the Preferred Alternative”. ​Due to the severity of the construction impacts of the “Modified Hybrid” Throat Alternative, the following issues must be analyzed in the DEIS​:
   
   a. Fully document the need for the trestle structure as well as the impacts of both constructing and then removing it (these are separate actions separated by as many as ten years). Topics for analysis must include – for each of these actions – disruption of sediment contaminated with heavy metals and toxic chemicals; increased storm water runoff leading to more toxic algae blooms; harm to the aquatic ecosystem including fish, birds, and wildlife; and impacts on river users such as boaters of all kinds.
   b. Evaluate options for the alignment of temporary roadways in the river to minimize the constraint on the watersheet.
   c. Evaluate alternative designs for moving Soldiers Field Road into the river during construction, including placing the temporary Soldiers Field Road entirely on fill instead of a trestle structure.
   d. Comparison of the options should be made via an analysis of permanent improvements to the river and parks that would result from each construction option.

II.D. Alternatives that Should Not Be Dismissed from Further Study

1. The original “Flip” alternative for West Station.
   The original “Flip” alternative with a four-track West Station should continue to be analyzed.​ Specifically, an alternative that includes ​West Station with four tracks, built to accommodate 15-minute, all-day service per the recent FMCB vote, ​must be analyzed in the DEIS. This alternative can be designed to facilitate express trains that run through the station, as they currently do at Boston Landing.

The proposed dismissal of the Original Flip from further study is also unacceptable because it incorporates the buffer park, the People’s Pike pathway, and the Cambridge Street bypass, which are essential elements that serve multiple important goals of the project​:
a. The Buffer Park​ along the south edge of the project was conceived to more completely separate the nearby residential properties from transportation activities on this site. Homes are very close to rail property lines here, with some as close as 30’ away from potential noise sources. The park would be wide enough for a multipurpose path with landscaping and trees. With a tall noise wall perhaps topped with a roof above the rail tracks, the buffer helps reduce noise and vibration impacts on residential property. The park should be designed with input from residents.
b. The People’s Pike pathway​ provides a direct, safe, off-road route for bicycles and pedestrians between Allston Village and the remainder of the proposed development focused on West Station. It could also reach the Charles River with very few conflict points with roadway traffic via the proposed bicycle/pedestrian bridge at Agganis Way. Removing the proposed express tracks from the plan provides sufficient width for the People’s Pike Path and buffer park.
c. The Cambridge Street Bypass​ provides an alternative vehicular route into and out of the interchange, reducing future traffic volumes on Cambridge Street South and connecting streets. ​This proposed street should be included in traffic analyses in the DEIS.

2. A second build alternative for the Throat.
There are a number of positive aspects of the final condition for the “Modified Hybrid” Throat alternative. However, the disruption of mobility and environmental damage that will be caused in order to construct it are severe. A second alternative must be considered; the all at grade option for the Throat has the most potential to fulfill the project Purpose and should continue to be analyzed.

In January 2019, MassDOT selected a preferred alternative for the “throat” portion of this project at the time, many stakeholders were pleased with the selection of the “Modified Hybrid” option, in large part because it allowed for a widening of the Charles River parkland in the Throat and a bicycle/pedestrian connection to the river from Agganis Way. However, MassDOT has not committed to building the Agganis Way connection, and has subsequently elected to widen the I-90 cross section, eating away at the available land for the park so much so that there is no room for trees for a significant portion of the Throat.

The “Modified Hybrid” option has the most complex construction phasing of any of the Throat alternatives that have been studied. To date, MassDOT has been unable to produce a construction plan that does not restrict the Worcester Line to a single track for up to half of the ten-year construction period. The reduction of service and impact on reliability that this would entail, at the same time that the Mass Pike will be reduced from eight lanes to six, will have a devastating impact on mobility and quality of life for the entire Worcester Line corridor.

Most importantly, MassDOT has disclosed significant new information about the damage to the environment that would be caused by the “Modified Hybrid” Alternative due to the stated need to replace the riverbank with sheet piles for several thousand feet and place Soldiers Field Road on a structure in the river for up to a decade. The all at grade alternative was dismissed due entirely to its potential impact on the river. Yet in light of the new information about the extraordinary 10-year, so-called “temporary” impacts that the Modified Hybrid Alternative will have on the Charles River, it is unclear which of the two options would have greater adverse impacts. Because a viable avoidance alternative has not been identified, Section 4(f) requires “all possible planning” be utilized to mitigate adverse impacts and ​“the alternative that will cause the least overall harm (after factoring in mitigation measures) must be selected”. Therefore the all at grade option must be carried forward for analysis in the DEIS.

II.E. Additional Alternatives that Must Be Analyzed

1. High-frequency, all-day service at West Station
   The build alternative described in the Scoping Document should be analyzed as a minimum possible future level of service; a second build alternative should be added that incorporates a level of service that acknowledges the Regional Rail vision and incorporates connections to passenger service on the Grand Junction and robust bus connections to and through West Station.

The Scoping Report states that the Build alternative assumes “at least three morning and four afternoon peak period, peak direction train stops at West Station…[and] 180-minute headways at a minimum during off-peak periods. Urban rail train service was not incorporated within the ridership model horizon because a future build year has not been determined and service frequency has not been defined.” The travel demand model being run by the Central Transportation Planning Staff to inform the project is also using this assumption for service at West Station. This is unacceptable. Furthermore, it is grossly inconsistent with the recent MBTA Board vote to pursue a transformation of the commuter rail system into Regional Rail with significantly higher frequencies during both peak and midday periods. While we understand that a build year has not been determined, the permitting and construction period for the I-90 project will last at least 12 years, during which time the MBTA Board will almost certainly further define and begin implementing the Regional Rail Vision. More importantly, the infrastructure built as part of the I-90 project will need to last for many decades after construction is completed. It is extremely shortsighted to assume that 60 years from now the level of service on the Worcester line will be no different from today, when there is a clear intent by the MBTA to increase the level of service.

In Cambridge, the various landowners and stakeholders along and adjacent to the Grand Junction line are in the conceptual phase of planning for the railroad corridor to fast-growing Kendall Square. These landowners have committed to a fully two-track corridor, which would allow frequent service between Allston, Kendall Square and North Station. If implemented, this will create demand for many if not all trains to stop at West Station given the ability to access Kendall Square and North Station. A West Station which permits only minimal service on the Worcester Line is inconsistent with the stated objectives of the City of Cambridge, landowners abutting the Grand Junction, and stakeholders in both Kendall Square and Metrowest.

2. A build alternative with no layover yard
   The rail network within this project would operate more efficiently without the layover yard; the DEIS must include an analysis of the rail services with and without the layover yard.The Allston I-90 planning has never included an analysis of alternatives for rail layover nor has it included a justification for the number of consists proposed for storage in Allston. Any analyses conducted for other studies such as the South Station Expansion are now obsolete in light of the recent MBTA Board vote to move toward a regional rail system with higher frequencies throughout the day, as well as other considerations since the SSX Alternatives Analysis was finalized in 2013. Furthermore, the presence of a layover yard causes dimensional and operational constraints that lead to a) the proposed reduction of tracks serving West Station, which, in turn, limits the station’s effectiveness in meeting the Project Purpose; and b) the introduction of separate express tracks, which is an unnecessary expense and precludes the inclusion of the People’s Pike and buffer park, which are highly valued project elements.
3. A Build Alternative with no separate express tracksA comparison of the project with and without express tracks should be included in the DEIS. ​This analysis should consider MassDOT policy that “​commute times and trip times in general must be made more predictable and reliable, even if not necessarily much faster or shorter​” (Congestion in the Commonwealth – Report to the Governor 2019) and that 31% of peak Worcester Line trains were more than 5 minutes late during the 30 days ending November 17, 2019. The need for express tracks has not been demonstrated, given geometric speed restrictions on either side of the site. With a 60 mph curve at Market Street and a 50 mph curve at Nickerson Field, there is only 1.4 miles where trains would be able to accelerate and decelerate at higher speeds, saving at most 5 to 8 seconds of run time by using express tracks. Additionally, any drawings must take into account the removal of “wide freight” rights east of Framingham which preclude the need for any freight bypass tracks.

II.F Additional/Modified Project Elements that Must Be Included in All Alternatives

1. Pedestrian Connections
   a. A bicycle and pedestrian bridge from Agganis Way to the Paul Dudley White Path. This proposed bicycle and pedestrian connection has long been a priority of many stakeholders, and was one of Secretary Pollack’s key reasons for selecting the Modified Hybrid throat alternative The design of this proposed bridge is integral to the design of the elevated Soldier’s Field Road above the Eastbound Turnpike, and the overall design of reconstructed roadways will assure that the bridge is feasible, according to MassDOT. However, the proposed bridge is not fully incorporated as a funded project element. The Agganis Way bridge connection should be included as a project element to be constructed.
   b. An improved design for the Franklin Street Pedestrian Bridge.
   The Crossing of the train tracks and Mass Pike at Franklin Street is an essential route for people walking and biking and one of very few connections between the two halves of Allston. This crossing route had the highest percentage of cyclists in the City’s 2017 Boston Bike Counts report. MassDOT’s proposed design with three switchbacks on the south side and one switchback on the north side is unsafe and would unacceptably hinder walking and biking. One or more alternatives should be included in the DEIS that evaluate a footbridge with no switchbacks and/or a tunnel. (Significantly longer walk/bike tunnel precedents can be found in ​Seattle​, ​Rotterdam​, and ​London).
   c. A bicycle/pedestrian connection from Commonwealth Avenue at the BU Bridge to the Paul Dudley White path. The original construction of the Mass Pike and Soldiers Field Road cut off Commonwealth Ave from the Charles River. Even with the construction of new bicycle and pedestrian connections at Malvern Street and Agganis Way, there will still be a gap of more than a mile between ADA accessible pedestrian connections to the Paul Dudley White path. This project provides an opportunity to create a new connection from Commonwealth Avenue at the BU Bridge to the Charles River paths. The MassDOT team has begun to study this connection; it should be included as a project element.
2. Safer designs for Cambridge Street and the new streets in Beacon Yards
   One of the first and most important community priorities expressed as part of the I-90 Allston planning process was the need to transform Cambridge Street into a human-scaled street that would function like a neighborhood connector, not a highway on-ramp. MassDOT’s current designs fail to show this transformation. Instead, they have replicated the existing dangerous, overbuilt conditions on Cambridge Street and repeated them on every new proposed street. ​Only a single block of a single street within Beacon Yards is shown as two lanes; most streets are four lanes with additional turning lanes at intersections. This is radically out of line with the City of Boston’s Complete Streets Guidelines and all modern best practices for street design in dense urban areas.

   The proposed design more than doubles roadway capacity, rebuilding the four-lane Cambridge Street we have today with additional turning lanes, and adding a five-lane Cambridge Street South. There is no logical justification for this expansion, as every single existing street that the new streets will connect with is two lanes wide. Furthermore, increasing roadway capacity has been proven not to address traffic, but to induce it.

   The 2018 Massachusetts Strategic Highway Safety Plan states that “For the Commonwealth of Massachusetts, one life lost on our roadways or altered by a serious injury is unacceptable.” However, the 4 and 5 lane roads currently proposed in the new street grid in Beacon Yards create a severe safety risk for people walking and biking. The FHWA publication “Pedestrian Safety at Intersections” states: ​“Although intersections represent a very small percentage of U.S. surface road mileage, more than one in five pedestrian deaths is the result of a collision with a vehicle at an intersection. Research indicates that increasing the lanes on a roadway from four to six or more lanes increases the percentage of fatalities represented by pedestrian crashes by 64 percent.” ​MassDOT’s Municipal Resource Guide for Walkability notes that “designing roadways with built-in physical features that make pedestrians more visible and require motorists to travel at lower speeds can improve safety.” Raised crosswalks and speed tables are recommended in that MassDOT report and should be included in this study. ​MassDOT must propose alternative designs for all new streets that 1) reduce the number of lanes on most or all proposed streets and 2) are designed for a speed limit of 25mph​ (Boston’s current citywide limit) and the 20 mph limit supported by Mayor Walsh.

3.  Full reconstruction of the Cambridge Street overpass
   The Cambridge Street viaduct on the westerly edge of the project was identified as structurally deficient by MassDOT more than five years ago. It should also be considered functionally deficient, as the excessively severe vertical curve obstructs the visibility of pedestrians and bikes posing safety risks for users traveling along the bridge and attempting to cross it,. That this route is a very strong desire line is clear from the large number of people that use it every day despite the high-speed traffic and poor visibility. The overpass abutments follow the current curve of the Mass Pike, and therefore likely constrain future alignments of the turnpike and rail as well as potentially introducing complications for construction sequencing. ​The DEIS should document how the Cambridge Street overpass does or does not constrain other project elements, and evaluate the value of a full bridge replacement rather than a deck replacement as was previously planned.

II.E. Additional Topics of Analysis that Must Be Included in the DEIS

1. Mitigation
   Mitigation must be included as an integral part of the planning process​, especially for an enormous and complicated project such as this one. The Scoping document seems to treat mitigation as something that is undertaken once a preferred alternative has been selected. Our understanding of the federal environmental process is that mitigation must be included during the project formation and selection process in order to have the data necessary to arrive at the best overall option. Mitigation helps shape a project to arrive at an acceptable package of elements that all participants and advising agents can agree upon. None of the options under consideration will avoid impacts to parkland, historic and natural resources, and residential areas either in their final condition or during the lengthy construction period. Mitigation elements that are critical include:
   a. Noise, vibration, and air pollution protection for impacted residential areas.​ ​MassDOT proposes to build express tracks and a rail yard for midday storage of diesel locomotives next to the Wadsworth Street neighborhood, while also moving I-90 closer to these same homes. These actions would inflict great harm to nearby residents in the form of air pollution (tailpipe emissions and wear from tires and brakes), noise pollution, and vibration. The simple barrier wall that MassDOT proposes along the backyard property line is grossly inadequate for several reasons, including that noise barriers can shield only the lowest floors of a building and that a barrier wall is most effective when it is as close to the noise source (traffic lanes) as possible. The highly desired buffer park provides sufficient width to include a berm, trees, and vegetation that are together much more effective in mitigating air pollution, noise, and vibration. Furthermore, the Cambridge Street Bypass would put a roof over the rail lines closest to homes, providing a much greater air and noise pollution barrier.

   b. Mitigation for impacts to the Charles River​. ​MassDOT’s construction plan proposes to fill significant areas of the Charles River and replace the entire riverbank with sheet piling for several thousand feet, for up to a decade. This is in no sense a temporary impact: “temporary” implies that the riverbank can be restored to its previous state. A river is an endlessly dynamic resource and in no way will it be able to be “restored” after ten years of flow and forces that will react to the rigidity of pilings and addition of fill. “Restoration” of the riverbank to its current state is not possible, nor is it desirable, as it is currently eroding, unstable, and unattractive.

   This project creates an opportunity to make positive, ecologically-driven changes in this degraded section of the river, by providing for separate walking and biking paths, introducing more trees and other plantings throughout the Throat, providing adequate storage and treatment of stormwater, and making improvements to the ecological health of the river. Permanent changes to the river are not necessarily “adverse impacts”. Projects such as the North Shore Riverfront Ecosystem Restoration Project on the Ohio River in Pittsburgh, Pennsylvania and Chicago Riverwalk are recent examples of permanent and positive riverbank changes that can inform the I-90 Allston alternatives analysis.

   The entire I-90 project area was originally marshland, and therefore, to the extent that a softer water’s edge can be restored, the river will be healthier and stormwater will be more effectively managed. In addition, significant trees and other plantings are necessary in the Throat to address noise and air pollution from the adjacent highways (as described in the US EPA publication Recommendations for Constructing Roadside Vegetation Barriers to Improve Near-Road Air Quality) and shade the biking and walking paths. Plantings will also provide visual benefits when seen from riverfront paths and roads on both sides of the river. The strategic reuse of some bridge piers to support a boardwalk or a modest amount of permanent landfill–without impeding the active use of the watersheet–could allow for separated walking and biking paths and new planting areas throughout the throat.

   c. Landscaped buffers
   Provide added dimension for landscaped aprons on the bridges that span above the highway and rail alignment to provide noise, air quality, and visual buffering and support a comfortable pedestrian and bicycle environment.
   The City of Boston’s I-90 Allston Interchange Placemaking Study makes this recommendation, noting that “These bridges will span hundreds of feet of active highway and rail facilities. Although air rights development may eventually line the new streets and cover the transportation infrastructure, it is important to have an attractive environment for everyone using these important new links as part of the initial construction.”

   d. Decking over the highway and railyard
   Building decks over highways becomes exponentially more expensive, difficult, and disruptive when they are in use by cars and trains. Decking over the highway and Worcester Line tracks as part of this project and before they are operational should be studied for its value ​to minimize and mitigate adverse air and noise pollution and visual impacts while also creating the conditions for technically feasible and economically viable transit-oriented air rights development.

   e. Mitigation for the disruptions caused by construction.
   The Mass Pike, which carries hundreds of thousands of vehicles per day, will have reduced capacity for much of the ten-year construction period. This is sure to cause increased congestion on the turnpike and spillover traffic in surrounding neighborhoods, with resulting impacts on air quality, economic activity, and safety, unless a comprehensive plan is implemented to facilitate increased usage of non-vehicle modes during construction.

   f. Replacement of the Grand Junction Bridge superstructure over the Charles River.
   The Grand Junction Bridge over the Charles River dates to 1928, and required emergency repairs in 2012 to remain operational. The shutdown of the Grand Junction during the project will allow ample time to replace the superstructure of the bridge (and inspect the substructure as well) so that it can provide frequent transit service once the line is reopened. This should also include bicycle and pedestrian facilities to connect the “People’s Pike” to trails and paths in Cambridge.

2.  Regional, multi-modal maintenance of mobility plan
   A systematic program is needed to maintain mobility throughout the upcoming decade of reconstructing the interchange.​ In a project of this magnitude and duration, the impact on the region’s traffic pattern during the construction process will be a critical concern. The Boston region’s growth is expected to continue, especially in locations like Kendall, Downtown and the Seaport, and the Longwood Medical Area. Demand for access from the western corridor will reflect that growth. Our roadway capacity is finite, and will even be reduced during the construction process. Passenger demand for public transportation will grow disproportionately during this 10-year construction period and after. It is essential that a central part of the Allston Interchange I-90 project be a program to sustain regional mobility even as roadway capacity is reduced.

   Passenger use of the Worcester Line has risen by more than 45% in the past six years, and should be expected to grow by an even larger amount during the upcoming decade. Improving public transportation capacity adequately to meet rising demand will require significant new capital investment, additional operating resources, and long lead time to implement the expanded services. That means the mobility plan must be initiated immediately in order to achieve timely results. Key strategies of such a plan include:
   a. Early implementation of West Station, or if that is infeasible, implementation of a temporary West Station on the existing WML tracks
   b. Maintenance of two WML tracks throughout construction
   c. Increased frequency on the WML
   d. Additional express buses/dedicated bus lanes on the Mass Pike during construction
   e. Expanded parking capacity at WML stations
   f. Temporary ramps in the vicinity of St. Mary’s Street/Beacon Street to reducing the number of drivers who use the I90 Allston exits or exit early and use surface streets through Allston-Brighton
   g. An ADA-compliant alternate route during reconstruction of the Franklin Street footbridge

SECTION III. FHWA AND FTA CONTINUING INVOLVEMENT IN THE PUBLIC PROCESS

It is essential that FHWA and FTA resume their participation in the Mass Pike Task Force for the duration of the project. ​The Mass Pike Task Force was convened in 2014 at the request of State Representative Kevin Honan, State Representative Michael Moran, State Senator William Brownsberger, and State Senator Sal DiDomenico. Over the past five years, the Task Force has worked collaboratively with the MassDOT team, and, all agree that the project has improved immensely as a result. The Task Force plays an essential role because the extraordinary complexity of this project makes it extremely difficult for members of the general public to fully understand and provide input when the only avenues for participation are brief time periods allotted at a typical public meeting.

The Task Force represents the public in this process—the nearby residents, people living in all the areas who will experience the impacts of this project as well as its long-term benefits, the many public-interest advocacy groups and individuals who represent the larger public, and others. We applaud MassDOT’s commitment to continue convening the Task Force throughout the project planning and construction. However, we are deeply concerned that FHWA has ceased its participation in the Task Force just as it initiates its active role in the project permitting. If, at this point, there was broad consensus about the direction and specific elements of the project, perhaps their role could be more circumscribed and the need for them to participate less urgent. But that is not the case, as evidenced by the issues detailed above that have yet to be resolved. These issues are complex and interconnected. Resolving them will require further study and analysis to arrive at the most feasible and beneficial build alternative. It is not possible to satisfactorily resolve all of these complex issues within the space of this current comment period, and one additional comment period before the selected alternative is chosen, and there is no way that the FHWA will be able to make informed decisions without being present and involved in the process. Therefore it is essential that FHWA and FTA participate in the Task Force, even if only in an observatory capacity.

The implementation of the Allston Intermodal Interchange redevelopment is expected to be by a design/build technique. It is essential that the environmental process be sufficiently precise and defined that future contractors will be bound to respect the environmental requirements established as a result of this NEPA process.

Thank you for your consideration of our comments on the NEPA Scoping Document. We believe this project has the potential for once-in-a-lifetime benefits for people traveling on all modes through the project area, for people living and working in surrounding neighborhoods, and for historic and natural resources, and thus we urge you to make the above modifications to the project purpose and scope.

We appreciate your attention to the important matters raised in this letter. We look forward to continuing our very effective collaboration to date with the Federal Highway Administration, MassDOT, and other City, State, and Federal agencies to help this project become a model for 21st Century sustainable mobility.

Sincerely,

Alex Cornacchini, Allston Village Main Streets and Task Force Member
Jason Desrosier, Allston Brighton Community Development Corporation and Task Force member Anthony D’Isidoro, Allston Civic Association, Allston resident, and Task Force member
Laura Jasinski, Charles River Conservancy and Task Force member
Wendy Landman, WalkBoston and Task Force member
Anna Leslie, Allston Brighton Health Collaborative
Harry Mattison, Allston resident and Task Force member
Galen Mook, Massachusetts Bicycle Coalition, Allston resident, and Task Force member
Michael J. Nichols, Executive Director, Esplanade Association
Ari Ofsevit, LivableStreets Project Lead, Cambridgeport resident, and Task Force member
Jessica Robertson, Allston resident and Task Force member
Hazel Ryerson, Allston resident and Task Force member
Fred Salvucci, Brighton resident
Bob Sloane, WalkBoston and Brookline resident
Stacy Thompson, Executive Director, LivableStreets Alliance
Jack Wofford, Cambridgeport resident
Becca Wolfson, Boston Cyclists Union

Cc: Governor Charlie Baker
Secretary of Transportation Stephanie Pollack
Secretary of Energy and Environmental Affairs ​Kathleen Theoharides Boston Mayor Marty Walsh
Cambridge Mayor Marc McGovern
Brookline Town ​Administrator​ ​Melvin Kleckner
Senator William Brownsberger
Senator Sal DiDomenico
Representative Michael Moran
Representative Kevin Honan
Chief of Streets Chris Osgood
Boston Planning and Development Agency Director Brian Golden Ken Miller, FHWA
Cassie Ostrander, FHWA