Secretary Stephanie Pollack
Massachusetts Department of Transportation
10 Park Plaza
Boston, MA 02116

Chairperson Joseph Aiello
Fiscal and Management Control Board
10 Park Plaza
Boston, A 02116

April 23, 2018

Dear Secretary Pollack and Chairperson Aiello:

As members of the task force appointed to participate in the planning of the Allston interchange project, and as interested parties who have commented extensively on the DEIR, we are writing to urge you to exercise policy direction over the next phase of the FEIR for the Allston I-90 Interchange Project. Based on the overwhelming majority of stakeholder comments to the DEIR, we urge you to take decisive action to narrow the options that remain so that MassDOT will have a focus to the analysis supporting the FEIR.

We think that there is now sufficient evidence to eliminate the HV 3 viaduct option and move forward with the ABC and AMP options. That evidence is as follows:

There are three overarching principles embraced in stakeholder’s DEIR comments which we urge you to embrace: 

1. Rail service options must become central to the project. This multi-modal project must lay the groundwork for a much better future than the current congested condition of accessibility in the western corridor and excessive spillover traffic into the adjacent communities. This priority is encapsulated in the broad stakeholder consensus on the need to maintain present and future rail service to the Western Corridor, that West Station must be part of the project at the earliest feasible point in the reconstruction, and that the two-track Grand Junction passenger rail connection to Kendall not be precluded as a future option. 
2. The adverse impact on western corridor commuters and neighbors must be minimized during the reconstruction process and must be limited in duration. All possible planning must be done to maintain two-track passenger service on the Worcester branch throughout the construction period. However, the widened viaduct option is a threat to the accessibility and environmental quality of the entire western corridor from Worcester through metro west and Newton, Brighton Allston and Cambridge, and should be definitively rejected.
   • The proposed construction sequencing of the widened viaduct scheme as described in the DEIR involves changing the existing two-track service on the Worcester Branch, to a commuter rail service that operates on a single track between the BU Bridge and Allston, restoring the problematic condition that existed for far too long in the past.
   • According to the MassDOT DEIR, this constraint would be imposed at least for two years at the very beginning of the new construction, when the eight lane turnpike would also be constrained to six lanes during the same period, creating difficult travel conditions for western commuters, with neither road nor rail options to maintain accessibility.
   • Both of the at-grade options avoid such a single track two year constraint until very late in the construction sequence, for at most one year, based on the description of construction impacts included in the MassDOT DEIR. 

     Further improvements to benefit western corridor commuters might include expanding mid-day service at least through this reconstruction, and minimizing the disruptiveness of the construction process by postponing any introduction of mid-day layup storage until the end of the reconstruction process.

3. Finalization of the FEIR should include serious consideration of the WalkBoston/Charles River Conservancy boardwalk plan as an element of construction mitigation.  The WalkBoston/Charles River Conservancy plan promises to introduce a much improved esplanade edge to the river, in keeping with the legal obligation to pursue all possible planning to mitigate adverse impact on DCR parkland by the redevelopment of the interchange, and provides the opportunity to improve and simplify the construction process by relocating the Paul Dudley White Path out of the construction zone, onto a boardwalk section adjacent to the river bank.

DISCUSSION

The elimination of the viaduct option, and focusing on the two at grade options for the throat, the flip, and the WalkBoston/Charles River Conservancy plan are essential tasks to complete the FEIR.

A. A two-track Grand Junction Link from West Station to Kendall and North Station must not be precluded. This transit link is seen by all of the undersigned as the only significant hope to increase accessibility from the western corridor to the growing Kendall area without further exacerbating the growing congestion in the western turnpike corridor, the Allston and Brighton local streets already suffering from spillover traffic, and Cambridge local streets. However, the viaduct option precludes two tracks on the Grand Junction right of way:

• There is insufficient physical space between the Soldiers’ Field Road and the proposed widening of the Viaduct to provide for two tracks.
• The single-track Grand Junction right of way is steep, and requires a sharp curve at the top of an incline to reach the Grand Junction river crossing bridge
• The Grand Junction alignment has very constrained headroom, likely precluding the possibility of eventual electrification.
• The Grand Junction alignment also has a bad reverse curve between the bridge over the river and West Station.

These spatial constraints will not change no matter how much further analysis is done. By contrast, both of the at grade options provide for the two track Grand Junction right of way with more moderate curvature than exists today, and enhance the service pattern we seek.

For the past two years, many of us have called for analysis that shows how the two-track Grand Junction alignment can be feasible, including cross sections at the critical location where the viaduct would need to pass over the Grand junction tracks as they reach ground level. The DEIR did not include such analysis, apparently because the widened viaduct does not provide the space for a workable alignment even for a single track, let alone the two that are required for frequent and useful passenger rail service.

We understand that the MBTA Fiscal Control Board has just begun a study of the conversion of all or part of the commuter rail network to European style Regional rail, which encompasses this West Station to Kendall shuttle service, and that final decisions may not be forthcoming in timely fashion, so not precluding this option is essential in the Allston Interchange reconfiguration.

B.  The design of the viaduct option within the throat perpetuates existing design deficiencies.

• The existing reverse curve in the horizontal alignment of the Turnpike near the BU Bridge is repeated in current designs for the new viaduct.
• The steep profiles of the turnpike are maintained, in a roller coaster pattern similar to that of the existing mainline of the turnpike, according to the descriptions of the MassDOT DEIR.
• The slight widening of the roadway proposed in the viaduct width for a very short section between the BU bridge to on-and off -ramps at the Allston interchange at a location is complicated by a slope in the main roadway profile that would lead to a risk of excessive speed as the vehicles exit the turnpike onto the local street system.
• In the at-grade options, the transitions for motorists from high-speed turnpike traffic to city streets occurs on up-ramps, helping to moderate speed and transition safely to city streets.
• The two at-grade options in the throat eliminate the steep grade and reverse curvature of the existing turnpike, resulting in a superior horizontal and vertical alignment.

C. Existing and proposed parkland is degraded by the viaduct option.

All three of the options in the throat rely on significant use of the DCR-owned parkland, particularly at the most constrained section of the transportation corridor where the Grand Junction rail alignment currently comes to grade and passes between the River, the very minimal Paul Dudley White Path, Soldiers’ Field Road and the Turnpike.

• The HV 3 viaduct option exacerbates the constraint by putting much of the modest remaining parkland in perpetual shadow because of the height of the viaduct located to the south of the usable parkland.
• The at-grade options do not cast any shadow, and provide for an expanded Paul Dudley White Path in this most constrained section of the Esplanade by replacing the 90-year-old rail bridge and concrete abutment with a more slender bridge support system a solution supported by DCR, the owner/ advocate of the DCR parkland.
• The AMP at-grade option involves less use of DCR land than the viaduct, and requires no alteration to the edge of the Charles River, and provides for a “Peoples’Pike ” bike and pedestrian connection from Agganis way to the Paul Dudley White Path. The ABC at-grade option does involve use of a very small inlet in the edge of the Charles, which could be achieved with a boardwalk or fill; it also provides the opportunity for a pedestrian and bike connection from Agganis Way to the Paul Dudley White Path..

D. Travel lanes and shoulder widths proposed for the Turnpike viaduct option are excessive for this location.

The MEPA certificate requires that MassDOT should continue to evaluate potential reductions in travel lanes, shoulder widths, and other roadway features. In determining these features, it is important to recognize the current setting of the Turnpike and Soldiers Field Road.

• The number of lanes on the Turnpike would be difficult to reduce without major changes throughout the length of the highway between Downtown Boston and Route 95/128. Current options envision 8 lanes for the Turnpike.
• Without reducing the number of Turnpike lanes, MassDOT can provide the same dimensions for lane widths consistent with those used in the cross section used for most of the turnpike between the BU Bridge and South Station, especially noting the nearby recent reconstruction of the turnpike just east of the BU Bridge. These lanes are uniformly 11.5’ wide.
• Breakdown lanes on the Turnpike vary significantly. The current viaduct proposal provides breakdown lanes on right-side edges and on left-side edges that exceed widths used on the Turpike between the BU Bridge nd South Station.
• Each option calls for 4 lanes for Soldiers Field Road. Without reducing the number of lanes on Soldiers Field Road, MassDOT can provide 10’ wide lanes as used elsewhere on parkways.
• Breakdown lanes on Soldiers Field Road are minimized at 2’ in all options.

E. The viaduct option requires constraining the two-track Worcester Branch of the commuter rail service to a single track. This seriously degrades service quality, simultaneously with reducing the width of the eight-lane turnpike for at least two years at the very beginning of the construction process. In the DEIR this problem is compounded by introducing an additional construction phase to introduce a mid-day layup facility constraining the space available for contractor lay down area, necessary for efficient construction, and complicating commuter rail flow with additional non passenger repositioning movements. This additional construction phase, and constraint of contractor lay down area increases the disruption of rail services, and lengthens the duration of disrupted flow on both the commuter rail and turnpike, adversely affecting all western corridor commuters.

F.  The “flip” option should be coupled with temporary increase of mid-day service on Worcester Branch commuter rail service. These steps help to mitigate the adverse impact of the turnpike six-lane constraint, and construction disruption of off peak as well as peak traffic, and should replace the DEIR extra construction phase for early action layup. This strategy will maximize the availability of contractor lay down areas to expedite economical and expeditious reconstruction of the Allston Interchange. The study of the possibility of replacing commuter rail services with European type regional rail service, just recently initiated by MBTA can benefit from real time evaluation of the utility of increased mid-day service, with less mid-day lay up. Whatever mid-day layup capacity eventually makes sense in Allston can then be added at the end of the construction process, when the contractor lay down area is no longer needed, two-track commuter rail service is restored, West Station and connecting bus services to Commonwealth avenue and Cambridge street are in place, and the eight-lane turnpike traffic pattern is restored.

The flip also supports a better buffer edge for the Pratt street neighborhood, a safe alignment for the “People’s’ Pike, a good location for the Cambridge street Bypass, and good layout for decking over the rail and Highway alignments to support serious air rights development from the outset, rather than leaving the land full of difficult to develop “holes ” in the urban fabric similar to most of the turnpike alignment through the downtown area. 

None of these opportunities to improve on the DEIR have been adequately analyzed, and/or discussed with the community, nor been the subject of public feedback and comment.

G.  The possible introduction of the WalkBoston/Charles River Conservancy plan should be evaluated as part of the FEIR. Its long run value lies in being a very significant component of fulfilling the federally required exercise of “all possible planning” to mitigate the adverse impact on the DCR parkland of the Allston Interchange redevelopment. It would result in significantly improved conditions for pedestrians, bicycle riders, and joggers in comparison to the very skimpy facility now available as the Paul Dudley White Path. It would also release the space currently used by the Paul Dudley White Path for new landscaping to restore more of a “parkway” feel to Soldiers’ Field Road.

During construction, it would remove pedestrians and cycles from-harm’s way in the construction zone, and should facilitate a more economical and effective construction process, because of the expanded construction zone available.

H. Construction and future maintenance costs for the viaduct option are substantially higher than the ABC option.

• Based on information provided to the MassDOT Board, the viaduct option would cost about one hundred million dollars more than the ABC at-grade alternative.
• The life cycle costs for maintenance of a new viaduct will exceed the current costs that are approximately $800,000 per year. Future costs over a 50-year period will exceed an estimated $50,000,000.
• These significant differences in cost would provide for either significant cost savings for MassDOT, or provide the financial support to significantly mitigate other aspects of the turnpike replacement.
• At the end of the useful life of the new viaduct proposed in the viaduct plan, the commonwealth would again be confronted with the very difficult problem of how to rebuild a structurally failing viaduct which carries eight lanes of traffic, and the cost of that further reconstruction.

The many deficiencies associated with the viaduct documented in the MassDOT DEIR for the I-90 project are unlikely to be avoided or mitigated, based on the extensive analysis already dedicated by MassDOT to analyze the viaduct options in the throat area. However, significant further improvement is feasible for the at-grade options, so it makes sense at this point for MassDOT to eliminate the viaduct from further consideration, and focus on the at-grade options.

For the above reasons, we respectfully urge that MassDOT definitively eliminate the HV-3 viaduct option from further consideration, and focus on the improvement of at-grade options. Of the two at-grade options, we prefer the ABC scheme, as it is considerably less expensive than either of the other two options.

Thank you for this opportunity to comment on next steps for this project.

Sincerely

Members of the I-90 Allston Interchange Project Task Force

Anthony D’Isidoro, Allston Civic Association
Tom Francis, Interim Executive Director, MassBikes
Wendy Landman, Executive Director, WalkBoston
Bob Sloane, WalkBoston
Stacy Thompson, Liveable Streets
Ari Osevit, Liveable Streets
Andrew McFarland, Liveable Streets
Jason Desrosier, Allston/Brighton C.D.C.
Renata Von Tscharner, Executive Director, Charles River Conservancy
Laura Jasinski, Future Executive Director Charles River Conservancy
Emma Walters, Executive Director, Allston Village Main Streets
Becca Wolfson, Executive Director, Boston Cyclists Union
Paola Ferrer, Esq., Allston resident
Galen Mook, Allston resident Allston-Brighton bikes
Harry Mattison, Allston resident
Richard Parr, Allston resident
Jessica Robertson, Allston resident

Cc:

Sen. William Brownsberger, Second Suffolk and Middlesex District
Sen. Sal DiDomenico, Middlesex and Suffolk District
Sen. Joe Boncore, First Suffolk and Middlesex District
Sen. James Eldridge, Middlesex and Worcester District
Sen. Karen Spilka, Second Middlesex and Norfolk District
Sen. Michael Moore, Second Worcester District
Sen. Cynthia Creem, First Middlesex and Norfolk District
Rep. Carmile Gentile, 13^th Middlesex District
Rep. Mary Keefe, 15^th Worcester District
Rep. Frank Smizik, 15^th Norfolk District
Rep. Jeffrey Roy, 10^th Norfolk District
Rep. Brian Murray, 10^th Worcester District
Rep. Jim O’Day, 14^th Worcester District
Rep. Jennifer Benson, 37^th Middlesex District
Rep. Jonathan Hecht, 29^th Middlesex District
Rep. Ruth Balser, 12^th Middlesex District
Rep. Kay Khan, 11^th Middlesex District
Rep. Chris Walsh, 6^th Middlesex District
Rep. David Linsky, 5^th Middlesex District
Rep. Alice Peisch, 14^th Norfolk District
Rep. Jay Livingstone, 8^th Suffolk District
Rep. Michael Connolly, 26^th Middlesex District
Rep. Michael Moran, 18^th Suffolk District
Rep. Kevin Honan, 17^th Suffolk District
Boston Mayor Martin Walsh
Mark Ciommo, Boston City Council
Michelle Wu, Boston City Countil
Andreae Downs, Newton Councilor-at-large, Ward 5
Susan Albright, Councilor-at-large, Ward 2
Alan Ciccone, Jr., Councilor-at-large Ward 1
Maria Scibelli Greenberg, Ward 1 Councilor
Neil Wishinski, Brookline Select Board
Benjamin Franco, Select Board
Nancy Heller, Select Board
Bernard Greene, Select Board
Heather Hamilton, Select Board
Cambridge Mayor McGovern
Vice Mayor Devereux
City Manager Louis DePasquale
Councilor Carlone
Councilor Zondervan