Comments regarding the transportation model underlying project design and operational decisions
Re: Comments regarding the transportation model underlying project design and operational decisions
Dear FHWA Administrator McEwan and MassDOT Acting Director O’Dowd,
The I90 Allston Task Force met last night (December 11, 2019), the evening before today’s deadline for comments on the Allston I-90 NEPA Scoping Report.
The entire meeting (2+ hours) was consumed by a conversation about the model being used by CTPS (also to be used by MAPC on an additional study) to evaluate the requirements and impacts of the project. As became clear during the course of the presentation and Q&A, the assumptions about transit service that are built into the model will lead to results that point to very low use of West Station (45-60 minute headways during peak hours) and no use of the Grand Junction line (no service at all). The Task Force asked the project team for information about these assumptions a year ago because we were concerned about this issue and its potential impacts on the project review.
We ask that FHWA and MassDOT incorporate the meeting minutes of the Dec. 11 Task Force as WalkBoston’s comments about the Scoping Report because they reflect the serious questions needed to be answered about the basis on which project plans and designs will be made.
Most notably, if the model assumptions lead to results that show little to no use of West Station we fear that a number of decisions will be based on incorrect data:
- West Station will be put at risk because it will show such low ridership use
- Grand Junction components of the project will be at risk because there will seem to be no travel demand
- Bus, walking and biking elements of the West Station area will seem to be of little use because West Station will be shown as having very low use
- Sizing of roadway elements of the project (both highway and street elements of the project) will expand because almost all of the trips to be served will be modeled as vehicle trips – because such inadequate transit service has been baked into the model assumptions
- West Station and the rail service included in the project assessment will be at odds with the MBTA’s own plans for regional rail as recently voted on by the FMCB – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans
- The I90 “Allston Multimodal Project” will be at odds with Massachusetts policies and goals regarding the reduction of GHG emissions because it will be premised on a vehicle-based transportation system – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans
Thank you for the opportunity to provide comments, and for including the comments of the I90 Task Force in the project record.
Wendy Landman
WalkBoston Senior Policy Advisor and Task Force Member