Green Line Extension Draft Environmental Impact Report Testimony

(Submitted to EOEA 1/3/10)

January 3, 2010

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
MEPA Office, Attn: Holly Johnson, MEPA Analyst
EEA number #13886
100 Cambridge Street, Suite 900
Boston MA 02114

Via e-mail:


* Draft Environmental Impact Report/Environmental Assessment (DEIR/EA).
* Draft Section 4(f) Statement for the Green Line Extension Project.
* Additional Maintenance Facility Alternatives Analysis.

Dear Secretary Bowles:

I wish first to thank the Commonwealth for extending the Green Line into Somerville, a project long overdue. I believe that a Final Environmental Impact Report should be produced in order to deal with the following issues, among others:

1. The current DEIR does not present enough details about the stations’ designs to allow readers to evaluate the stations' compliance with the Americans with Disabilities Act (ADA). This is a major concern, because the MBTA has been ordered by the courts to retrofit existing stations to meet ADA requirements.

2. The Executive Summary takes the position that the presence of the Green Line in Somerville will not increase economic activity, only change the location of infill development. The history of Harvard Square, Porter Square, and Davis Square suggest that this is short-sighted. The areas around all of these Red Line T-Stops enjoyed significant increases in property value and economic activity in the years after the Red Line came in.

Somerville has little undeveloped land, and much of the developed land is residential. Residential land is difficult to repurpose without disrupting the neighborhood. However, some of the proposed T-stops, such as the Lowell Street and Brickbottom stops, are near old industrial sites that could be easily converted into high-value office and R&D development. The MBTA should include in the Final EIR an assessment of the economic development potential of each proposed T-Stop, including the implications for each city's tax base.

3. The proposed Maintenance Facility should not be placed at Yard 8. In that position it would not only disrupt the lives of the Brickbottom residents, it would permanently cut off significant parts of the Inner Belt area and make economic development there very difficult, to the sure detriment of the Somerville tax base. Please consider placing the Maintenance Facility in a location detached from all future development, such as under the I-93 right-of-way. If this is not feasible, the Facility should be placed at the better of Option L and Mirror H (see #4).

4. The Maintenance Facility Alternatives Analysis presented by the T is significantly flawed.

a. Ability to Meet Project Schedule: The analysis gives a +1 to Yard 8 because design work has already been done. This is misguided for two reasons.

First, it sets a bad precedent. The MBTA should have informed the community and listened to their response before making a decision as important as placing the Maintenance Facility at Yard 8. By this precedent, any project, no matter how poorly conceived, could be forced through simply by investing in design work before informing the community.

Second, this analysis assumes that the Brickbottom residents are complaisant, which they obviously are not.

I am not a lawyer or a Brickbottom resident, but it seems to me that if this issue went to court, the Brickbottom residents would have a strong case. They would have legal standing as direct abutters, they would be uniquely damaged by the Yard 8 development, and they would have opposed the development at every opportunity.

Statements I have heard in public meetings imply that the Brickbottom residents have already sought legal advice. If the MBTA went forward nonetheless, the residents would almost certainly go to court to block the development and would almost certainly win the case on its merits. Yard 8 should be given a -1 for this reason. It would be very optimistic even to give it a 0.

b. Operational Impacts: According to the analysis, Option L (and Yard 8) would affect Pan Am Railway’s operations, but only to the extent that the railway would have to start using the seldom-used, but existing, Yard 10 lead. This minimizes the operational impact of both, which should have 0 instead of -1.

c. Future Vision Transportation Access: According to the analysis, Option L provides a direct connection to the Union Square branch, which neither Yard 8 nor Mirror H provide. This is important for future transportation access. It has been proposed that the Union Square spur be extended through South Somerville to Porter Square, which along with the Medford branch would place a T-stop within a quarter mile of almost every part of Somerville, as well as parts of northeast Cambridge. Option L should be given a +1 for this unique advantage.

The updated scores are:

* Yard 8 = -1
* Mirror H = -3
* Option L = +2

5. In public meetings I have attended as part of the Green Line Community Corridor process, a consistent theme has been apprehension that the Green Line extension would harm existing Somerville neighborhoods. To mitigate this problem, the MBTA should support public advisory committees for each T-Stop that could work with the T and residents to meet neighborhood concerns. Later, these advisory committees could also coordinate economic development around each T-Stop, as was done by the Davis Square Task Force after the Red Line came into Davis Square.

6. A long-standing problem with the Commuter Rail service is that the trains are diesel powered. Diesel engines produce large amounts of fine particulates that pollute the air in nearby, densely-populated neighborhoods, damaging the hearts and lungs of residents. Converting commuter rail trains to dual-mode diesel and overhead electric would significantly reduce this burden.

To support the Green Line Extension, the T is already required to erect pylons and catenaries. Please consider placing the pylons so that they will span both the Green Line and Commuter Rail tracks, or at the very least consider moving the Commuter Rail tracks to a location that would allow room for a pylon between them and the wall. Doing this would make it much easier to add catenaries over the Commuter Rail tracks and electrify the Commuter Rail trains at a later date.

7. Many of the stations seem to be accessible only from one side of the street and thus do not adequately integrate with the adjoining neighborhoods. This has implications for ADA compliance as well as for conformity with urban design principles. Apparently this is because the standard station design consists of a large enclosed space at street level connecting to a center platform below. This large enclosed space would be very expensive to provide on both sides of the street.

A less expensive alternative design could consist of 2 columnar enclosures, one on each side of the street. Each enclosure could contain an ADA-compliant elevator surrounded by a stairway down to platform level. At platform level, these could be connected by a heated enclosure passing under the street. The heated enclosure could change to a semi-enclosure with infrared heating extending away from the street in both directions along the platform. This design would allow vulnerable riders to stay in the heated enclosure under the street and less vulnerable riders to move away from the center as more riders arrived.

8. Somerville and Medford are densely-settled inner suburbs, not sparsely-settled, car-oriented outer suburbs. The majority of the riders will be reaching the T-stops on foot. It is neither necessary nor appropriate to provide parking or extensive drop-off facilities for these T-Stops, particularly those not termini. The resources saved should be diverted to the Community Path and to neighborhood integration.

Despite my concerns, I feel that the Green Line Extension is an exciting development and I look forward to the day it is complete. Thank you for providing this opportunity to comment.


David Dahlbacka