SIERRA 

CLUB 

Massachusetts Chapter 

September 24, 2012 

Mr. Jerome Grafe 

Department of Environmental Protection 

Bureau of Waste Prevention 

One Winter Street, 6th Floor 

Boston, MA 02108 

Re: Proposed Amendments to 310 CMR 7.36 

Central Artery Mitigation Transit Commitments 

The Massachusetts Chapter of the Sierra Club strongly supports the remaining Air Quality Mitigation Transit 

Commitments, which the Commonwealth has agreed to as part of its 1990 setdement as a condition for building the 

Central Artery /Tunnel Project. For those who live or work in the city and depend on public transportation every 

day, they remain as vital now as when they were first negotiated. We firmly believe that enlightened, responsible 

transportation policy, especially in a compact, congested urban area, should discourage use of the private automobile 

and encourage the utilization of more benign alternatives like transit, walking and bicycling. 

Thus we are appalled by the Massachusetts Department of Transportation's proposal to turn its back on yet 

another of the Mitigation Transit Commitments still outstanding under the State Implementation Plan: It seeks to 

abandon the final design process for the Red Line/Blue Line Connector that would extend the MBTA's Blue Line 

under Cambridge Street to Charles station, which would at last provide^'iclrrecFtrans'fef between these two transit 

lines. 

The Sierra Club has long advocated for the proposed Red/Blue connection between Bowdoin Square and 

Charles. We believe that this link would be of great benefit to the passengers who regularly travel these two transit 

lines, as well as to riders on the other lines who must use tine downtown transfer stations. For those who depend 

upon the Red Line or the Blue Line, the benefits are the most obvious: Travelers coming from Cambridge, Dorchester or Quincy would have to endure one less transfer to reach the Airport. Residents of East Boston and Revere visiting Massachusetts General Hospital or its many associated clinics and doctors' offices would save themselves two transfers, for a one-seat ride to their destination. The connection would also further the aims of environmental justice, connecting jobs-rich Kendall Square with more affordable housing north of Boston. This list 

could go on. 

Benefits for odier subway riders are equally evident: I live in Roxbury and work in Government Center, relying on the Orange Line every day. Frequently on my way home when I board the Forest Hills train at State station, 

I encounter people arriving from the Airport and carrying heavy baggage who must also squeeze their way onto the 

already crowded train—often to go just one stop to change again at Downtown Crossing. (The overcrowding is so 

bad that I often avoid State and go out of my way to board at Haymarket.) Both they and we would be better 

served by construction of the Connector, which would allow them a direct transfer to the Red Line while reducing 

congestion at the existing downtown transfer stations. 

The MBTA has claimed that the new "Silver Line" bus from South Station to the Airport obviates the need for 

the link underneath Cambridge Street. This ride, however, is slow, bumpy and unreliable, frequently getting delayed 

by traffic in the Ted Williams Tunnel and causing many Red Line Airport travelers to vote with their feet and continue to use the Blue Line. Too, the bus is of no use to people who live or work in East Boston or Revere and want 

to reach the Red Line or destinations like Mass. General. Future development along the Blue Line corridor, like the 

casino planned at Suffolk Downs, is almost certain to increase its ridership. While casino promoters anticipate that 

the majority of its patrons will be arriving by car, it is only fair to assume that a sizable minority will arrive by T, as 

will many of its workers. 

10 Milk Street Suite 632 Boston MA 02108 tel: 617.423.5775 fax: 617.423.5858 www.sierraclubmass.org 
SIERRA 

CLUB 

FOUNDED 1892 

Massachusetts Chapter 

The Connector is not a frill but a badly needed addition to the T system. We also need to consider the future 

of the Blue Line, the shortest of the MBTA's four transit lines and the only one terminating in downtown. Extending it to Charles cannot fail to increase its ridership—especially if the Line is ever extended on the other end to Lynn 

—fueling the need for more interconnectivity with the rest of the system. Over the years there have been various 

proposals to extend die Blue Line to the west, most notably to Kenmore Square and beyond, to relieve pressure on 

the overburdened Green Line through the Back Bay. These possibilities need to remain on the table and not be 

precluded by short-range financial considerations that are now being used to dictate the short-sighted "solution" of 

abandoning the Connector. Boston has long styled itself as a "world class city." Such a failure to invest in our own 

future would mock these aspirations. It would be tantamount to a declaration of economic defeat, a pathetic admission that we're not as competitive as we had once Hked to believe. 

After lavishing ever more money on the Central Artery project ($24 billion and counting!), it is interesting to 

hear the state now plead poverty in an attempt to wiggle out of another one of its 1990 Commitments. Far from 

being an extraneous add-on burdening its bottom line, these Commitments speak to the need to enhance transportation options for those of us who live or work in the Boston area. It is instructive to note that while the Commonwealth expands transit and commuter rail lines in all directions away from the center, it has systematically neglected any expansion to its downtown core—and the MassDOT application does not even bother to list any proposed remediation for failing to meet its deadline for designing die project. This imbalance of priorities must stop! 

It urgently behooves MassDOT to continue the planning for this link against the day that the money becomes available for its construction; if the final design of the Connector is never completed, we will not have any data on its 

costs should the occasion for funding it arise. Such lack of foresight has already prevented the MBTA from taking 

much advantage of the American Recovery and Reinvestment Act of 2009 (the "Stimulus package") because it had 

precious few projects on the table that were "shovel ready." 

In recent months the local press has carried numerous articles, letters and Opinion pieces addressing the nexus 

between the mushrooming cost of the Big Dig and the desperate state of our chronically underfunded and crumbling transit infrastructure. Most notable of these was "Surging ridership could overwhelm T" (June 14 Globe, 

http://www.bostonglobe.com/metro/2012/06/14/surging-mbta-ridership-could-overwhelm-system-reportwarns/gIaIU4WgfyKp'I'WClAodmoK/story.htmlV 

In contrast with comprehensive metro networks in cities like London or Paris or New York that cover far 

more of their metropolitan areas, Boston's rapid transit system can be best described as skeletal, with too many riders funneling into too few lines. At the very least, capacity in the downtown core needs to be significantly expanded, 

with service extended into many underserved areas, like central Roxbury and northern Dorchester. Sadly, we could 

have greatly improved the scope and coverage of our public transit system for a mere fraction of the cost of the 

overruns of the Big Dig. Given the expansion of commuter rail service and park and ride lots over the past two 

decades, primarily to serve suburban riders, the state's protestations of inadequate funding are actually a judgment 

that it views those of us living in the inner city who depend on its services every day—its "captive audience," so to 

speak—as second-class citizens. 

DEP, do your duty as public servants: This Central Artery Mitigation Transit Commitment must stand. 

Respectfully submitted, 

fohn Kyper, Transportation Chair 

Sierra Club, Massachusetts Chapter 

10 Milk Street Suite 632 Boston MA 02108 tel: 617.423.5775 fax: 617.423.5858 www.sierraclubmass.org