A BETTER CITY 

33 Broad Street | Suite 300 | Boston, MA 02109 

Tel: 617-502-6240 | Fax: 617-502-6236 

WWW.ABETTERCITY.ORG 

Jerome Grafe 

MassDEP 

One Winter Street 

Boston, MA 02108 

Via email to Jerome.grafe@,state.ma.us 

Sept. 24, 2012 

Re: Amendments to 310 CMR 7.36: Transit System Improvements ("Red/Blue Connector) 

Mr. Grafe: 

A Better City (ABC) is pleased to submit to you comments on the proposed amendment 

to 310 CMR 7.36, in particular the deletion of the requirement that MassDOT complete 

design of the Red Line / Blue Line Connector Project. 

A Better City is a nonprofit membership organization that provides the business and 

institutional leadership essential for ensuring progress and tangible results on 

transportation, land development, and public realm infrastructure investments that are 

vital to sustaining and improving the Boston area's economy and quality of life. 

The ABC Board of Directors comprises leaders from over 100 major businesses and 

institutions in greater Boston and represents a broad range of industries, including 

financial services, real estate, legal services, construction, higher education, cultural 

institutions, life sciences, hospitality, utilities, and more. The Board has an established 

history of civic engagement and is actively engaged in the work and issues that comprise 

ABC's mission. 

ABC has served on the Working Group for the Red/Blue Connector since it was 

established and has offered comments on the evolving design and construction strategy in 

that forum. 

We have reviewed Mass DEP's materials and MassDOT letter requesting the deletion of 

Red/Blue design from the State Implementation Plan commitments. We understand the 

scope of DEP's review of this matter is limited to the air quality impacts of the proposed 

change, and that, as a design requirement only, there are no adverse air quality impacts 

associated with removing the project. We are also sympathetic to MassDOT's fiscal 

constraints and the escalating costs associated with the project. 

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 Red/Blue Connector design 

requirement from the SIP is short-sighted and would effectively kill a project that, if 

constructed, would achieve significant environmental and economic benefits. We urge 
Mass DEP to reject the proposed amendment and maintain the requirement to bring the 

project to final design. 

The proposed extension of the Blue Line to connect to the Red Line at Charles Station 

offers some obvious benefits for users of the transit system by relieving congestion in the 

central subway and by providing better connectivity between the Red Line and.Blue Line 

corridors, particularly between Cambridge and the northwest and the North Shore along 

the Blue Line. This connection would take advantage of the available capacity of the 

Blue Line while reducing congestion at the Park Street and Government Center stations. 

A Better City recently co-sponsored, with the Urban Land Institute, a report on transit 

capacity and project real estate development in the MBTA service area. That report found 

that many of the downtown transfer stations in the system are approaching or over 

capacity. At the same time, proposed development, both in the downtown "hub" of the 

transit system and farther out along the "spokes", will generate additional transit ridership 

and exacerbate capacity constraints. One of those potential future developments is the 

proposed casino complex at Suffolk Downs, which is served by the Blue Line. The 

Red/Blue Connector would alleviate these capacity concerns in the downtown transfer 

stations and enhance transit access to the casino site. 

A Better City is sympathetic to the fiscal constraints facing MassDOT. Our organization 

is actively involved in efforts to advance a comprehensive solution for transportation 

finance in the Commonwealth, and we are hopeful that such an effort may be taken up by 

elected leaders early next year. In fact, the legislature has instructed MassDOT to deliver 

a transportation finance plan for their consideration by January 2013. Further, the state's 

casino legislation sets aside funding for transportation improvements related to accessing 

the casino site. The Red/Blue Connector would be an excellent candidate for funds 

related to a casino at Suffolk Downs. 

If such a plan is adopted, it is reasonable to assume that the fiscal constraints on 

MassDOT will be eased somewhat. As the state's Draft Environmental Impact Report for 

the project notes: 

Should additional resources for MBTA expansion projects become available, the 

Red Line/ Blue Line Connector will be one Of the projects considered for 

implementation. When such a priority setting effort takes place, it would be 

informed by the level of environmental review, and design and engineering work 

conducted between now. and the end of 2011 in order to satisfy the SIP 

commitment. (DEIR, ES 1-2) 

In other words, the degree to which a project is designed helps determine its eligibility for 

construction funding — not the other way around. As the state itself acknowledges, the 

project's inclusion in the SIP commitment is a factor that determines "the level of 

environmental review, and design and engineering work" that MassDOT will commit to 

the project. For MassDOT to contend that it need not continue with the design of the 
project because it does not currently have construction funding is therefore something of 

a circular argument. 

We believe that it is prudent to advance the design of the Red/Blue Connector as far as 

possible, so that ^ We also 

believe that this project would be an excellent candidate for an alternative procurement 

method, which could help address some of the technical challenges which have caused 

the increase in the project's projected cost. At the same time, it is also important to note 

that much of that project costs is related to the 40% contingency currently associated with 

the project. As MassDOT notes in its letter to MassDEP, this conservative contingency is 

related to "the conceptual stage of design" of the project. It is reasonable to assume, then, 

that the contingency could be reduced as the design is advanced and open questions 

related to design choices are resolved. That would in turn reduce both the total 

construction cost for the project and its design costs, which are estimated as a percentage 

of construction costs. 

While the design of the Red/Blue Connector does not have specific air quality benefits 

attached to it, it is important to recognize that it is a binding legal commitment and the 

result of a settlement of legal action brought to enforce the SIP commitments. We 

believe, then, that if the design requirement is removed from the SIP, there ought to be 

some substahtive-mitigafioYin^ into the SIP-commitments in its place. Any 

alternate mitigation considered should attempt to serve the same transportation corridor 

and populations that would have benefited from the Red/Blue Connector as fully built. 

These are challenging times for transportation — indeed, for all of state government. 

There is a temptation in tough times such as these to hunker down, to look to the tasks at 

hand instead of the horizon. We urge MassDEP to avoid this temptation. The 

Commonwealth cannot afford to limit its vision for the future if it hopes to continue to 

compete economically and improve environmentally. Planning ahead for projects like the 

Red/Blue Connector is essential if the MBTA system is to continue to accommodate 

future economic growth and real estate development. 

Richard A. Dimino 

President and CEO 

A Better City 

CC: Scott Hamwey, MassDOT