PARTNERS. 

An integrated 

founded bu 

and 

Massachusetts 

General Hospital 

September 24, 2012 

:t uj 

Real Fume ami Facili 

Jerome Grafe 

MassDEP Bureau of Waste Prevention 

One Winter Street, 6th Floor 

health eat e system 

Boston, MA 02108 

RE: Proposed Amendments to the Transit System Improvements Provisions of 

Brigiwm and the Slate Implementation Plan 

Women's Hospital 

Mr. Grafe, 

I write on behalf of Partners HealthCare System, Inc. and its affiliate, the 

Massachusetts General Hospital (collectively, "Partners") to comment on the 

proposed amendment to the State Implementation Plan's Transit System 

Improvements regulations which would, among other provisions, delete the 

requirement that the Massachusetts Department of Transportation 

("MassDOT") complete the final design for the Red Line/Blue Line 

Connector. 

Partners remains a strong supporter of the MBTA transit system and of the 

Red Line/Blue Line Connector, which we believe would provide a critical 

missing link in the MBTA system and provide substantiliTbenefits to the 

MBTA and the people and communities that it serves. One year ago we 

submitted comments on the 2011 Transit Commitments Status Report 

requesting that DEP deny MassDOT's request to amend the SIP and that 

MassDOT instead reconvene the Red Line/Blue Line Connector Project 

Working Group (of which we were a member) to develop a process and 

schedule for bringing design of the Connector to the point where it could later 

be used as the basis for a design-build bidding package. A copy of those 

comments is attached to this letter. Unfortunately, the SIP amendment 

process has proceeded and MassDOT never reconvened the working group 

nor consulted with those stakeholders most affected by its decision to abandon 

planning for the Connector. 

Partners continues to believe that MassDOT should invest the modest sum -

which we believe is nowhere near $50 million - necessary to complete the 

MEPA review process and advance the design of the Connector. Whether or 

not the Connector ultimately remains in the SIP, it is a project with substantial 

transportation benefits, allowing for productive use of excess capacity on the 

Partners HealthCare System, Inc., Prudential Tower, Suite 1150, 800 Doylston Street, Boston, MA 02199-8001 

Tel: 617 278-1037, Fax: 617 278-1048, email: kwest#parrners.org 
Blue Line and thereby enabling the MBTA to grow its ridership. As established by 

the draft Environmental Impact Report, a combined Red and Blue Line station at 

Charles/MGH - an area with one of the largest concentrations of jobs in Boston -

would be one of the busiest Blue Line stations in the MBTA system in the year 2030. 

Partners remains hopeful that the severe financial constraints currently facing the MBTA 

and MassDOT will ultimately be addressed by increased state and federal investment in 

transit. Even now, MassDOT is preparing a "baseline assessment" of the state 

transportation system's future capital needs required by section 13 of Chapter 132 of the 

Acts of 2012. Partners strongly believes that the Connector should be included as part of 

this and other plans by the Commonwealth to invest in a strong regional transit system 

serving metropolitan Boston. 

We therefore request that DEP leave intact the SIP commitment to advance the design of 

the Red Line/Blue Line connector. Thank you for your consideration of these comments. 

Respectfully submitted, 

Kathryn E. West 

Vice President of Real Estate & Facilities 

Partners HealthCare System, Inc. 

CC: Secretary Richard A. Davey, MassDOT 
PARTNERS. 

September 20, 2011 

An integrated 

health care system 

founded by 

Brigham and 

Women's Hospital 

and 

Massachusetts 

General Hospital 

Kathryii E. West 

Vice President of 

Kate Fichter Reel Estate end Facilities 

MassDOT Office of Transportation Planning 

Room 4150 

Ten Park Plaza 

Boston, MA 02116 

Jerome Grafe 

MassDEP Bureau of Waste Prevention 

Boston, MA 02018 

RE: State Implementation Plan - Transit Commitments 2011 Status Report Submitted to 

MassDEP on July 27, 2011 by the Massachusetts Department of Transportation 

Ms. Fichter and Mr. Grafe, 

I write on behalf of Partners HealthCare System, Inc. and its affiliate, the Massachusetts 

General Hospital (collectively, "Partners") to comment on the State Implementation Plan 

- Transit Commitments 2011 Status Report submitted to the Massachusetts Department 

of Environmental Protection ("MassDEP") on July 27, 2011 by the Massachusetts 

Department of Transportation ("MassDOT"). Specifically, I am writing with respect to 

one element of the SIP and regulatory requirements in 310 CMR 7.36, the requirement in 

subparagraph (i) of paragraph 2 that requires that "[bjefore December 31, 2011, 

[MassDOT] complete final design of the Red Line/Blue Line Connector, from the Blue 

Line at Government Center to the Red Line at Charles Station." 

As you know, Partners is a strong supporter of the MBTA transit system and of the Red 

Line/Blue Line Connector, which we believe would provide a critical missing link in the 

MBTA system and would - as the completed Draft Environmental Impact Report 

("DEIR") documented - provide substantial benefits to the MBTA system and the people 

and communities that it serves. Partners is also a member of the Red Line/Blue Line 

Connector Project Working Group, which worked with MassDOT staff and consultants 

during the process of developing the DEIR for the Connector. Partners is therefore 

disappointed that MassDOT has, by letter dated July 1, 2011 (but provided to the working 

group only in early August), requested that MassDEP "undertake the steps necessary to 

amend the Transit System Improvement Regulations and the SIP to remove the 

requirement to complete final design of the Red Line/Blue Line connector" - and that this 

step was taken without any prior consultation with or notice to the Working Group, 

Partners HealthCare System, Inc., Prudential Tower, Suite 1150, 800 Boylston Street, Boston, MA 02199-8001 

Tel: 617 278-1037, Fax: 617 278-1048, email: kwest@partners.org 

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which includes many of the stakeholders most interested in and affected by plans for the 

Connector. 

By these comments, Partners respectfully requests that DEP deny MassDOT's request to amend 

the Regulations and SIP at this time and instead request that MassDOT reconvene the Working 

Group and develop a process and schedule for completing a final Environmental Impact Report 

and "final design" for the Connector that would complete the MEPA process, fulfill the SIP 

requirement as it is currently written and lay the groundwork for a design-build construction 

process for the Connector at some point in the future when construction funding becomes 

available. We make this request for three reasons: 

• The Red Line-Blue Line Connector has been demonstrated to be a valuable addition to 

the MBTA transit system; 

• MassDOT has failed to demonstrate that the SIP should be reopened, especially given 

that completion of a "final design" for this project sufficient to fulfill the SIP 

commitment and lay the groundwork for future construction of the Connector could be 

accomplished at a cost far lower than the $49-50 million repeatedly cited by MassDOT; 

and 

• MassDOT has failed to consult with the key stakeholders and participants in the Red 

Line/Blue Line Connector Project Working Group about its decision to terminate all 

environmental review and design work on the Connector and request deletion of the SIP 

requirement. 

The Red Line-Blue Line Connector is a Valuable Project 

Partners, along with others including A Better City and the Conservation Law Foundation, has 

long argued that construction of the Red-Blue Connector will provide substantial air quality and 

transportation benefits, particularly, but not only, in the core areas of Revere, East Boston, 

Boston proper and Cambridge. Residents of communities along the entire Blue and Red Line 

service areas would use the Red-Blue Connector not only for direct service to the Massachusetts 

General Hospital and to the other, major medical facilities in the Charles/MGH area, but also to 

reach the many other employment centers and other destinations along these two rapid transit 

lines. The Connector would also benefit the transit system as a whole. The Red and Blue Lines 

remain the only two transit lines in the Boston transit network that do not directly intersect and 

the lack of a direct link forces double transfers on passengers and extra loading on two of the 

most overloaded links in the T network - the Green Line from Government Center to Park Street 

and the Red Line from Charles Street to Park Street - causing overcrowding for passengers on 

the Red and Green Lines, as well as to Blue Line riders whose trips go beyond Government 

Center. The lengthening of stations on the Blue Line to permit 6-car trains, rather than 4-car, and 

the new equipment to support this, means that the Blue Line is about to have 50% more capacity, 

the only one of the rapid transit lines with extra capacity. The Connector will help to use this 

capacity productively and allow the rapid transit system to grow its ridership. 

The Cornmonwealth's own air quality modeling has also demonstrated that this project would 

provide substantial air quality benefits. In 2008, when MassDEP and subsequently the 

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Environmental Protection Agency approved changes to the State Implementation Plan removing 

the commitment for construction of the Connector, the air quality benefits attributable to the 

Connector were calculated to be roughly the same as those attributable to the Green Line 

extension. The last round of changes to the SIP were designed to secure the eventual benefits of 

both of these important projects by "locking in" a commitment to construct the Green Line 

extension by a date certain while at the same time continuing with and completing final design of 

the Connector in order to lay the groundwork for its eventual construction. 

The Draft Environmental Impact Report completed in 2010 confirmed what Partners and other 

proponents of the Connector had long argued: that this project would increase transit ridership, 

reduce driving and resulting air pollution and greenhouse gases, increase the capacity of the 

MBTA system and improve mobility and access to jobs, education and health care for transit 

users, particularly those in communities served by the Blue Line. According to the DEIR, daily 

boardings at Charles/MGH station would increase from 10,050 in the no-build case to 22,390 in 

2030 if the Connector is built. Even netting out the riders who would no longer board at 

Bowdoin station, Blue Line ridership as a whole would increase by 8,800 (boardings and 

alightings) daily in 2030. Charles/MGH would be one of the busiest Blue Line stations in the 

MBTA system in 2030, far busier than Aquarium and nearly as heavily used as the busiest Blue 

Line stations in 2030, Government Center and State. As noted in our comments on the DEIR, 

Partners believes that even these ridership estimates may be low because the underlying land use 

data on both jobs and housing used to calculate ridership underestimated the likely growth in 

population and employment in the rapidly growing areas that the Connector would serve. 

The DEIR also confirmed that the Connector would benefit the MBTA rapid transit system as a 

whole—not just the Red Line and Blue Lines—because it would serve as an essential link for all 

transit riders passing through the heart of the MBTA system. In addition to the projected 

increase in Blue Line ridership, Red Line boardings at Charles/MGH would grow by 3,600 daily 

compared to the 2030 No Build case, as MBTA riders take advantage of the ability to transfer 

lines farther from the crowded downtown stations. The DEIR acknowledges (at page 2-3) that 

the "Project is needed to relieve congestion pressure at other subway stations in the Downtown 

Boston area." The DEIR also calculated that vehicle miles traveled would be reduced by 5,249 

per day as a result of the overall increased transit ridership and improved transit system 

performance, which would in turn would reduce greenhouse gas emission by nearly 1200 

tons/year. In short, the Red Line/Blue Line connector represents a substantial opportunity to 

increase transit ridership, reduce driving and reduce greenhouse gas emissions - but only if 

MassDOT maintains its commitment to design this important project in order to lay the 

groundwork for its eventual construction. 

MassDOT has Failed to Demonstrate that the SIP Should be Reopened 

Reopening the SIP, amending the state regulations and proceeding through federal approval 

would be a time-consuming and costly process which MassDEP should agree to undertake only 

after MassDOT has demonstrated that such a step is essential and in the best interests of the 

3 
Commonwealth's environment and transportation system. MassDOT has failed to make such a 

demonstration and so MassDEP should not, at this point in time, grant MassDOT's request to 

initiate changes to the SIP. Instead, MassDEP should encourage MassDOT to develop a path 

forward for completing a "final design" for the Connector that is sufficient to fulfill the SIP 

commitment and lay the groundwork for future construction of the Connector without spending 

anywhere near the $49-50 million cost estimate repeatedly cited by MassDOT. 

The funding needed to complete final design of the Connector is provided for in the "immediate 

needs" Transportation Bond Bill of 2007 and necessary funding is also included in the Financial 

Plan for the Long-Range Transportation Plan currently in the final stages of approval by the 

Boston Metropolitan Planning Organization. Even though the funds are in fact available to 

MassDOT under the bond bill and long-range plan, and despite our strong support for the 

Connector, Partners agrees with MassDOT that it does not make sense at this time to invest an 

additional $50 million in the design of the Connector. We do not, however, agree that the only 

choice is between spending that amount of money and completely abandoning the 

Commonwealth's longstanding commitment to the Connector. 

As MassDOT's filing indicates, to date only $3 million has been spent to complete both an 

Expanded Environmental Notification Form and DEIR. While the Secretary declined to treat the 

draft EIR as a final EIR, the May 28,2010 Certificate on the DEIR lays out a relatively modest 

scope of additional work that would be required to complete the MEPA environmental review 

process for the Connector. Certainly the MEPA process could be completed for a relatively 

modest additional expenditure, an investment that would help make Massachusetts more 

competitive should discretionary federal funds ever become available for projects such as the 

Connector. 

With respect to completing "final design" of the Connector as required by the SIP, Partners 

believes that MassDOT's assertion that such final design would cost nearly $50 million rests on 

(1) an inflated cost estimate that has never been fully presented for public review and (2) an 

incorrect interpretation of the SIP requirement for completion of "final design". Partners' 

comments on the Connector DEIR raised serious concerns about the projection that the 

Connector would cost $748 million rather than the $290 million that had been estimated only 

two years earlier. The $49 million design cost seems to be based on the assumption that roughly 

10% of a project's construction cost (without considering the large construction contingency 

included in the $748 million figure) would need to be spent on design. MassDOT has never 

satisfactorily presented the basis for these cost projections, either to the Working Group or in the 

draft EER. Given that the primary reason cited by MassDOT for requesting the deletion of 

Comiector design from the SIP is that "MassDOT does not believe that spending up to $50 

million to complete the project design is a wise use of public funds," it is essential that MassDEP 

require MassDOT to present the details behind this design cost estimate and allow Working 

Group members and the general public to review those details and assumptions before relying on 

them as the primary basis for reopening the SIP. 

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Partners also respectfully believes that it would be possible for MassDOT to comply with the 

requirement to complete "final design" without spending the funds necessary to bring the project 

up to the traditional definition of 75% or 100% design. The transit regulations do not define the 

phrase "final design." At a time when MassDOT is increasingly using design-build and designbid-build processes to expedite and streamline projects, "final design" no longer means 

something akin to construction drawings. Instead, Partners believes that MassDOT need only 

complete the MEPA process (responding, of course, to the comments that have remain 

unanswered for more than a year) and bring design to the point where it could be used as the 

basis for a future "design-build" bidding package. This would require far less design detail and 

therefore involve a far lower price tag. Partners believes that bringing the Connector to such a 

"final design" would in fact constitute a "wise use of public funds" on a project that has 

demonstrated air quality and transportation benefits for the Comnionwealth. 

MassDOT has Failed to Consult with Key Stakeholders including the Red Line/Blue Line 

Connector Project Working Group 

MassDEP frequently reminds commenters in the annual process of reviewing MassDOT's status 

report on the SIP commitments that its primary role is that of overseeing and ensuring the 

integrity of the review and revision process. As part of its critical role in ensuring the integrity 

of the process, Partners respectfully requests that MassDEP postpone any action on MassDOT's 

request to reopen the SIP and delete the requirement concerning final design of the Connector 

until after MassDOT has consulted with key stakeholders on the project, including the Red 

Line/Blue Line Connector Project Working Group. That group has not been convened since 

early in 2010 and was not consulted at all about MassDOT's decision to suspend all work on the 

Connector and request its removal from the SIP. Only after the Status Report was filed with 

MassDEP did the working group even receive a copy of MassDOT's letter to DEP on the 

Connector. 

It is particularly important that MassDEP require MassDOT to convene and consult with the 

Working Group because the Status Report asserts that "many" members of the Working Group 

raised concerns as the revised cost projections were presented and that "many" of them "question 

the merit of completing design on the project given the significantly higher design cost." In fact, 

Partners raised concerns about the validity of the "significantly higher" design and construction 

costs as did other members of the Working Group. MassDEP should not grant MassDOT's 

request to reopen the SIP without first ensuring that the Working Group's questions - which 

have gone unanswered for over a year - are addressed and without obtaining additional feedback 

from the Working Group and other stakeholders about the potential for solutions other than 

simply abandoning the commitment to the Connector, such as that proposed by Partners in these 

comments. 

5 
In closing, Partners respectfully requests that DEP deny MassDOT's request to amend the 

Regulations and SIP at this tune and instead request that MassDOT reconvene the Working 

Group and develop a process and schedule for completing a final Environmental Impact Report 

and "final design" for the Connector that would complete the MEPA process, fulfill the SIP 

requirement as it is currently written and lay the groundwork for a design-build construction 

process for the Connector at some point in the future when construction funding becomes 

available. Thank you for your consideration of these comments. 

Respectfully submitted, 

Kathryn E. West 

Vice President of Real Estate & Facilities 

Partners HealthCare System, Inc. 

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