Commonwealth of Massachusetts 

Executive Office of Energy & Environmental Affairs 

DEVAL L, PATRICK 

Governor 

TIMOTHY P. MURRAY 

Lieutenant Governor 

Department of Environmental Protection 

One Winter Street Boston, MA 02108 • 617-292-5500 

RICHARD K. SULLIVAN JR. 

Secretary 

KENNETH L KIMMELL 

Commissioner 

MassDEP 

Bureau of Waste Prevention 

Division of Consumer and Transportation Programs 

310 CMR 7.36: 

Transit System Improvements 

Background Document and Technical Support for Public Hearings on 

the Proposed Amendments to the 

State Implementation Plan for Ozone 

Regulatory Authority: Massachusetts General Laws, Chapter 111, 

Sections 142A through 142M 

August 2012 

This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622 or 1-617-574-6868 

MassDEP Website: www.mass.gov/dep 

Printed on Recycled Paper 
TABLE OF CONTENTS 

Section Page 

I. INTRODUCTION 1 

II. BACKGROUND 1 

III. SUMMARY OF PROPOSED AMENDMENTS TO 310 CMR 7.36 4 

IV. AIR QUALITY IMPACTS 5 

V. ECONOMIC IMPACTS 5 

VI. IMPACT ON OTHER MASSDEP PROGRAMS 5 

VII. AGRICULTURAL IMPACTS 6 

VIII. IMPACT ON MASSACHUSETTS MUNICIPALITIES 6 

IX. MASSACHUSETTS ENVIRONMENTAL POLICY ACT (MEPA) 6 

X. PUBLIC PARTICIPATION 6 

APPENDICES 

Appendix A - July 1, 2011 letter from the Massachusetts Department of Transportation to the 

Massachusetts Department of Environmental Protection requesting an amendment to the Transit 

System Improvements regulation, 310 CMR 7.36, and the State Implementation Plan. 

Appendix B - Proposed Amendments to 310 CMR 7.36 
Background Document and Technical Support for Public Hearing 

To Consider Amendments to: 

310 CMR 7.36: Transit System Improvements 

July 2012 

I. INTRODUCTION 

The Massachusetts Department of Environmental Protection (MassDEP) is proposing 

amendments to the Transit System Improvements Regulation (the Transit regulation), 310 CMR 

7.36, and the State Implementation Plan (SIP). The proposed amendments delete the requirefnent 

that the Massachusetts Department of Transportation (MassDOT) complete the final design of 

the Red Line/Blue Line Connector from the Blue Line at Government Center to the Red Line at 

Charles Station by December 31, 2011. The amendments were requested by MassDOT in a letter 

submitted to MassDEP dated July 1,2011 (Attachment A). 

The proposed amendments also modify the existing public process requirement that MassDEP 

hold a public meeting on the annual update and status report within 60 days of its July 1st 

submittal date. The 60-day public meeting deadline would be lengthened to 75 days to avoid 

potential conflicts with the Labor Day holiday. Finally, all references to the Executive Office of 

Transportation (EOT) are replaced with the Massachusetts Department of Transportation 

(MassDOT). 

II. BACKGROUND 

Air Quality Mitigation Commitments for the Central Artery/Tunnel Project 

In December 1990, the Executive Office of Transportation and Construction (EOTC) (now 

MassDOT), the Massachusetts Department of Public Works (MDPW) (now MassDOT, Highway 

Division), and the Conservation Law Foundation (CLF) signed a Memorandum of 

Understanding (MOU), which committed EOTC and MDPW to implement air quality mitigation 

measures for the Central Artery/Tunnel (CA/T) project. Among these measures was a list of 

transportation system improvement projects designed to maximize the use of mass transit. The 

MOU was endorsed by the Boston Metropolitan Planning Organization (MPO) as a proposed 

amendment to the SIP and was submitted to MassDEP. In response, MassDEP promulgated 310 

CMR 7.36 in 1991 and submitted the regulation to EPA as a SIP Revision. EPA approved the 

SIP revision in October 1994. 

Reevaluation of the Three Remaining Transit Projects Required by 310 CMR 7.36 

In 2005, MassDEP, MassDOT, and the Massachusetts Bay Transportation Authority conducted a 

public process to reevaluate the three outstanding projects required by 310 CMR 7.36 and 

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whether these projects should be constructed. The outstanding projects that had not been 

completed were: 1) the Green Line Arborway Restoration; 2) the Red Line/Blue Line 

Connector1; and 3) the Green Line Extension to Ball Square/Tufts University. The purpose of 

MassDOT's reevaluation was to ensure that the best transportation projects be pursued while 

meeting its air quality commitments. As part of this process, MassDEP provided MassDOT with 

the air quality goal (i.e., the level of emission reductions) that any potential project substitutions 

would be required to meet under a revised regulation and the SIP. In response, MassDOT 

developed a preferred alternative to the outstanding projects, which included the following three 

projects: 

1. Green Line extension beyond Lechmere to the West Medford and Union Square areas; 

2. Fairmount Line improvements; and 

3. 1,000 additional park and ride parking spaces serving commuter transit facilities in 

Boston MPO region. 

Subsequently, MassDOT submitted a request to MassDEP to amend 310 CMR 7.36 and the SIP 

to include the three alternative projects. MassDEP agreed to propose amendments to the Transit 

regulation to include the alternative projects and delete the Red Line/Blue Line Connector 

project. MassDEP held a public hearing on the amendments on December 21, 2005. 

Also in 2005, the Conservation Law Foundation ("CLF") filed a complaint against the 

Commonwealth for failing to complete transportation improvement projects required under the 

1991 Transit regulations (310 CMR 7.36) and the SIP approved by US EPA in 1994.2 In its 

complaint, CLF alleged that the Commonwealth was in violation of the SIP because it failed to 

complete certain public transportation improvement projects, including completion of the Red 

Line/Blue Line Connector Proj ect by December 31, 2011. In order to resolve the litigation, on 

November 28,2006, the parties in CLF v. Romney entered into an out of court settlement 

agreement that allowed the Court to dismiss the case with prejudice. The relevant section of the 

settlement agreement required MassDEP to adopt final amendments to the Transit regulation that 

deleted the requirements for the original three transit projects, including the Red Line/Blue Line 

Connector, added the requirements for the three alternative transit projects and also required 

MassDOT to complete the design phase of the Red Line/Blue Line Connector by December 31, 

2011. The settlement agreement did not require MassDOT to complete the construction of the 

Red Line/Blue Line Connector. 

On December 1, 2006, in response to comments on the proposed amendments to the Transit 

regulations, and in accordance with the November 28, 2006 settlement agreement in CLF v. 

Romney, MassDEP promulgated amendments to the Transit regulation that included MassDOT's 

preferred alternative projects and required MassDOT to complete the design phase of the Red 

Line/Blue Line Connector project by December 31, 2011. MassDOT was no longer required to 

construct the Red Line/Blue Line Connector project.3 EPA approved the regulation as a SIP 

revision on July 31, 2008. 

1

 This project would connect the Red Line's Charles Street station to the Blue Line's Bowdoin Street station. 

2

 CLF v. Romney, et al. United State District Court for the District of Massachusetts Civil Action No. 05-10487 (hereafter 

referred to as CLF v. Romney) 

3 See 310 CMR 7.36(2)(i) which became effective on December 1, 2006. 

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2007 Determination of Air Quality Emission Reductions of the Preferred Alternative 

In accordance with 310 CMR 7.36 (8), Determination of Air Quality Emission Reductions, 

MassDOT was required to calculate the emission reductions that would need to be achieved from 

the preferred alternative (i.e., the projects included in the 2006 amendments to 310 CMR 7.36 

including the Fairmount Line improvements, 1000 new park and ride parking spaces, and the 

Green Line extension to Medford Hillside with a spur to Union Square) and to demonstrate that 

these projects will achieve 110% of the emissions reductions that would have been achieved if 

the Arborway Restoration, the Red Line/Blue Line Connector, and the Green Line extension to 

Ball Square/Tufts University had been built. This calculation or emissions analysis was required 

to satisfy the anti-backsliding provisions of the federal Clean Air Act and the requirement in the 

previous version of 310 CMR 7.36 that any substitute projects achieve equivalent or greater air 

quality benefits. MassDOT was also required to complete a report documenting the technical 

analysis, release it for public comment, respond to public comments, in writing, and submit the 

"administrative record" to MassDEP for approval. 

In March 2007, MassDOT submitted to MassDEP an analysis prepared by the Central 

Transportation Planning Staff (CTPS) for MassDOT's Office of Transportation Planning on the 

amount of emissions reductions it expected to achieve by implementing the three alternative 

projects. The analysis confirmed that the three alternative projects would achieve greater 

emission reductions than the initial transit projects included in the 1991 regulation. The analysis 

document explicitly stated that "This analysis does not assume any air quality benefits associated 

with the Red/Blue Connector in that the SIP commitment to that project is limited to design and 

no actual benefits will result unless the project is constructed. At that point, it will be 

appropriate to attribute the air quality benefits."4 

In Junes2007, MassDEP issued a letter to MassDOT acknowledging that MassDOT had met the 

requirements of 310 CMR 7.36 (8). MassDEP supplemented its December 13, 2006 request to 

EPA to amend the SIP with MassDOT's submittal to satisfy the air quality analysis requirements 

for a SIP revision. As noted above, EPA approved the SIP revision on July 31, 2008. 

On July 27, 2011, MassDOT submitted its annual Transit Commitments Status Report (the 

"Status Report") to MassDEP.5 MassDOT stated in the Status Report "that spending scarce 

transit project funding to complete the design of the Red Line/Blue Line Connector by the 

December 31, 2011 is not a wise use of available funds." MassDOT further claimed that the 

design phase of the project neither provides air quality benefits nor were any benefits assigned to 

it in the SIP. MassDOT also stated that "in addition to the lack of tangible air quality benefits 

associated with the Red Line/Blue Line Connector requirement, final design of the projects 

comes at a considerable financial cost (most recently estimated at more than $50 million. Given 

the many other competing needs for [the] limited transportation funding, the Commonwealth has 

not included the project in the Regional Transportation Plan (RTP), which lists projects 

4

 See "Description of Modeling Assumptions and Analysis Methodology for the State Implementation Plan Transit Commitments 

Projects Current and Proposed Substitutions," CTPS, March 15, 2007, as revised. 

5 MassDOT is required to submit an annual Status Report to MassDEP pursuant to 310 CMR 7.36(7)(a). 

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prioritized for construction in the next 25 years." As required under the Transit regulations, 

MassDEP held a public hearing and comment period on the Status Report. 

III. SUMMARY OF PROPOSED AMENDMENTS TO 310 CMR 7.36 

MassDEP is proposing two substantive revisions to 310 CMR 7.36. These revisions include: 

1. Deleting the requirement that 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 

("the Red Line/Blue Line Connector") now required by 310 CMR 7.36 (2)(i); and 

2. Modifying the existing public process requirement that MassDEP hold a public meeting 

on the annual update and status report within 60 days of its required July 1st submittal 

date now required by 310 CMR 7.36 (7)(b). 

Deletion of the Design of the Red Line/Blue Line Connector 

310 CMR 7.36 (2)(i) requires MassDOT to complete final design of the Red Line/Blue Line 

Connector by December 31,2011. In response to this requirement, MassDOT took a number of 

steps to advance the Red Line/Blue Line Connector design including, but not limited to, 

allocating resources to advance the conceptual design, completing a Draft Environmental Impact 

Report, and forming and meeting with a working group. However, MassDOT has determined 

that allocating additional and scarce transportation funding to the final design of the project is 

not justified. Therefore, in July 2011 MassDOT requested that MassDEP remove the Red 

Line/Blue Line Connector design from the regulation and the SIP. 

The scope of MassDEP's review of MassDOT's request is to determine whether the removal of 

the Red Line/Blue Line Connector design would have an impact on the air quality emission 

reductions calculated for the projects included in the regulation and approved by EPA as part of 

the SIP. MassDEP has determined that because there are no air quality benefits associated with 

the design of the Red Line/Blue Line Connector project, removal of this design requirement will 

not affect the total emission reductions achieved from the remaining projects included in the 

Transit regulation. 

Modification of existing public process requirement that MassDEP hold a public meeting on the 

annual update and status report within 60 days of its required July 1st submittal date 

310 CMR 7.36 (7), Public Process Requirements, requires MassDEP to conduct a public meeting 

on MassDOT's project update and status reports, required to be submitted each year on July 1s t. 

Because MassDEP is required to conduct the public meeting within 60 days, there have been 

conflicts with the Labor Day Holiday and the end of summer season. Therefore, MassDEP is 

proposing to lengthen the public meeting deadline to 75 days to avoid these conflicts. This will 

still result in a timely hearing on MassDOT updates and reports, and should enable more 

stakeholders and members of the public to participate. 

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Replacement of the term "Executive Office of Transportation (EOT) " with "Massachusetts 

Department of Transportation (MassDOT) " 

MassDEP is also proposing to replace the term "Executive Office of Transportation (EOT)" with 

"Massachusetts Department of Transportation (MassDOT)" to reflect Chapter 25 of the Acts of 

2009, "An Act Modernizing the Transportation Systems of the Commonwealth of Massachusetts, 

(as amended by Chapter 26 of the "Act."). In June 2009, Governor Deval Patrick signed this 

transportation reform legislation that integrated transportation agencies and authorities into 

MassDOT. 

A copy of the proposed revisions to 310 CMR 7.36 is included as Appendix B. 

IV. AIR QUALITY IMPACTS 

As noted in Section II above, MassDOT's air quality analysis of the projects included in the 

2006 amendments of 310 CMR 7.36 (which was required pursuant to 310 CMR 7.36 (8), 

Determination of Air Quality Emission Reductions) concluded that the three projects that 

comprise the "preferred alternatives" would achieve greater emission reductions than the initial 

transit projects included in the 1991 regulation. See discussion of MassDOT's air quality 

analysis in Section II above. 

310 CMR 7.36 (2)(i) requires MassDOT to complete the final design of the Red Line/Blue Line 

Connector, but does not require that the project be constructed. Therefore, there are no air 

quality impacts of removing the project as a regulatory requirement. 

V. ECONOMIC IMPACTS 

In its July 1,2011 letter to MassDEP on the design of the Red Line/Blue Line Connector, 

MassDOT provides its most recent estimate of the costs to complete final design of the project. 

MassDOT projects the design costs to be more than $50 million, an increase well above the $29 

million cost estimate included in the 2009 Boston Metropolitan Planning Organization (MPO) 

Regional Transportation Plan. Given that MassDOT and the Boston MPO have not included the 

project in the RTP, the project is not prioritized for construction. MassDEP agrees with 

MassDOT's assessment that spending available transportation funding to complete final design 

of the Red Line/Blue Line Connector is not a wise use of public funds and removal of the project 

from the regulation and the SIP will allow funding to be allocated to other projects and 

programs, including the three alternative projects still included in the Transit regulations. 

VI. IMPACT ON OTHER MASSDEP PROGRAMS 

Air Toxics 

Air toxics are a group of chemical air contaminants, defined by EPA, that have been associated 

with wide-ranging and significant adverse health effects such as cancer, birth defects, and central 

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nervous system impairments. EPA regulates air toxics under the Clean Air Act. In addition, 

MassDEP controls air toxics through its Toxics Use Reduction Program and other programs that 

are aimed at reducing ozone. Many air toxics are VOCs, which are regulated as ozone 

precursors. These proposed amendments will not have any effect on air toxics emissions. 

Toxics Use Reduction 

Toxics use reduction is defined as in-plant or in-process practices that reduce or eliminate the use 

and emissions of toxic materials into the environment. Implementation of toxics use reduction, 

when possible, is a MassDEP priority. The proposed regulations do not regulate in-plant or inprocess practices and therefore will not have any effect on the use and emissions of toxic 

materials. 

VII. AGRICULTURAL IMPACTS 

Pursuant to Massachusetts General Laws, Chapter 3 OA, Section 18, State agencies must evaluate 

the impact of proposed programs on agricultural resources within the Commonwealth. The 

proposed amendments do not impose any requirements upon agricultural operations and will not 

have any effect on agriculture. 

VIII. IMPACT ON MASSACHUSETTS MUNICIPALITIES 

Pursuant to Executive Order 145, State agencies must assess the fiscal impact of new regulations 

on the Commonwealth's municipalities. The proposed amendments do not impose any 

additional direct costs, recordkeeping, reporting, or other requirements on local governments. 

IX. MASSACHUSETTS ENVIRONMENTAL POLICY ACT (MEPA) 

The proposed amendments are exempt from the "Regulations Governing the Preparation of 

Environmental Impact Reports," 301 CMR 11.00, in that no MEPA review threshold set forth in 

310 CMR 11.03 is met or exceeded. In addition, these proposed amendments do not reduce 

standards for environmental protection, nor do they reduce opportunities for public participation 

in review processes or public access to information generated or provided in accordance with the 

regulations. (See MEPA review threshold pertaining to promulgation of regulations at 301 CMR 

11.03(12)). 

X. PUBLIC PARTICIPATION 

As required by M.G.L. c. Ill , Section 142K and M.G.L c. 30A MassDEP gives notice and 

provides the opportunity to review background and technical information at least 21 days prior to 

proposing the regulation amendments at a public hearing. To assure more adequate notice for 

processing a rule as an amendment to the SIP, formal notice will be issued 30 days before the 

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public hearing. The hearing will be held in Boston. A copy of the proposed amendments and 

this background document are available on MassDEP's website at: 

http://vww.mass.gOv/dep/service/regulations/newregs.htm#proposed 

Copies can also be obtained at MassDEP's headquarters at One Winter Street, Boston. 

Please send comments to: Jerome.grafe(g),state.ma.us or Jerome Grafe, MassDEP, One Winter 

Street, Boston, MA 02108. 

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APPENDIX A 

Deval L Parrieft, Governor 

TimoOw R Murray, Lt. Governor 

Jeffrey B, Mutlan, Secretary & CEO Massachusetts Department of Transportation 

July 1,2011 ' 

Kenneth L. Kimmell, Commissioner 

Department of Environmental Protection 

1 Winter Street 

Boston, MA 02108 

Re: Red Line/Blue Line Connector, 310 CMR 7.36 2(i) 

Dear Commissioner Kimmell: 

1 am writing to request an amendment to MassDEP's Transit System Improvement regulations, 

310 CMR 7.36, and the State Implementation Plan (SIP), specifically as they relate to the final 

design of the Red Line/Blue Line Connector (310 CMR 7.36 2{i)). As set forth in greater detail 

below, the requirement to complete final design of an extension of the Blue Line from 

Government Center Station to Charles/MGH Station is a significant and expensive commitment 

that provides no actual air quality or transit benefits in and of itself. Funding for transit projects 

in the Commonwealth is exceedingly scarce and there are many competing demands for those 

funds that do exist. Given the lack of transit or air quality benefits associated with this purely 

procedural requirement, MassDOT does not believe that spending up to $50 million to complete 

the project design is a wise use of public funds. MassDOT therefore respectfully requests that 

the Department of Environmental Protection (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. 

Background on Transit Commitments Under the SIP 

As you know, MassDOT, in partnership with the MBTA, has worked diligently over the past 

several years to implement the various SIP transit commitments. These efforts, which are 

described in greater detail in our monthly SIP State Report updates (available at; 

http://www.mass.gov/massdot/SlP') are summarized below: 

• Fairmount Line Improvements: The MBTA has already made significant upgrades to 

existing stations and bridges and has constructed a new interlocking on the Fairmourtt 

Commuter Rail Line. With the exception of Blue Hill Avenue station which is still in 

design, all remaining Fairmount project elements are currently under construction. 

• 1,000 New Parking Spaces: Multiple projects are contributing to the fulfillment of this 

commitment, and the anticipated completion of the new Wonderland Station garage will 

allow us to meet the 1,000-space target. 

• Green Line Extension! MassDOT is continuing to advance this enormously important . 

and complex capital project, which will extend light rail service into previously 

Leading the Nation in Transportation Excellence 

Ten Park Plaa Soite 3170. Boston, MA 021 i 6 

Tel; 617JJ73-700O, TDD: 617-973-7306 

www.mass.gov/massctot 

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underserved areas of Somerville and Medford. The Commonwealth has recently 

committed significant funds to advance the design of the project and purchase new Green 

Line vehicles to support the eventual operation of the Extension, In addition, the 

project's Final Environmental Impact Report received a Certificate from the Secretary of 

Energy and Environmental Affairs in 2010, and final federal environmental approval is 

expected later this year. An agreement for the purchase of right-of-way needed for the 

project was also recently completed with Pan Am Railways. 

As required by 310 CMR 7.36(8), Determination of Air Quality Emission Reductions, and EPA 

SIP requirements, MassDOT determined that the Fairmount Line Improvements, 1,000 New 

Parking Spaces, and the Green Line Extension projects would achieve daily reductions of 435 

kilograms of carbon monoxide (CO), 11 kilograms of nitrogen oxides (NOx), and 17 kilograms 

of volatile organic compounds (VOC) in 2025, The reductions in emissions are a result of a 

decrease in vehicle miles traveled because the projects encourage travel by public transit rather 

than by private automobile. 

Red Line/Blue Line Connector 

As noted above, the regulation and SIP require MassDOT to complete final design of an 

extension of the Blue Line from Government Center Station to Charles/MGH Station. Unlike 

the other transit project requirements in the regulation and SIP, however, there is no specific 

requirement or obligation to construct the Red Line/Blue Line Connector. As a result, the 

commitment to design this project, by itself, provides no air quality benefit to the Boston 

Metropolitan region. In fact, the air quality modeling for the regulation and SIP revision, as 

approved by EPA in 2008, did not include or assign any air quality benefits to the project1. 

MassDOT has, nonetheless, made a good faith effort to meet the commitment for the'design of 

the Red Line/Blue Line Connector. MassDOT has spent close to $3 million over the past two 

years to advance conceptual design of the project and complete the Draft Environmental Impact 

Report (DEIR). This effort was supported by the input of a working group consisting of 

individuals representing institutions, neighborhood associations, business groups, advocates, City 

of Boston agencies, and state and local elected officials. This group met on a bi-monthly basis 

and their input was in addition to that received in two public meetings held on the project. 

In addition to the lack of tangible air quality benefits associated with the Red Line/Blue Line 

Connector requirement, final design of the project comes at a considerable financial cost (most 

recently estimated at more than $50 million). Given the many other competing needs for our 

limited transportation funding, the Commonwealth and the Boston Region Metropolitan 

Planning Organization have not included the project in the Regional Transportation Plan (RTP), 

which lists projects prioritized for construction in the next 25 years. Therefore, committing $50 

' EPA issued final approval of the Slate Implementation Plan for Transit System Improvements on My 31» 2008 

including approval of air quality benefits assigned to the Green Line Extension to Union Square and Medford 

Hillside, Fairmount Line Improvements, and 1,000 park and ride parking spaces. 

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million in transportation funding to complete the design process - as well as dedicating 

additional resources to complete the environmental review and pennitting processes - for a 

project that is extremely unlikely to be built simply cannot be justified. 

Since environmental review and conceptual design began for the Connector in 2009, MassDOT 

has determined that the ultimate construction costs for the project will far outstrip the cost 

projections in place at the time that the SIP regulation was promulgated: $290 million at the time 

of the SIP regulation versus the current best estimate of $748 million (escalated to year of 

expenditure), MassDOT has already spent $3 million to advance the project through 

environmental review and conceptual design, but the $50 million estimate to complete final 

design far exceeds the $29 million last identified in the Boston MPO 2009 Regional RTP. 

Design costs are typically estimated at 10% of total construction costs, so the $29 million 

estimate for final design at the time of the new SIP regulation was based on a $290 million 

estimated construction cost, which was escalated from the $237 million project cost carried in 

the 2004 Boston MPO RTP.. The dramatic increase in projected costs from the 2004 RTP to the 

$748 million figure included in the 2010 DEIR is attributable to a number of factors: 

Prior estimates relied on decades-old analysis. The Red/Blue Connector project had been 

included in several iterations of the Boston MPO RTP and the MBTA's Program for Mass 

Transportation (PMT). Although each of these planning efforts assigned an estimated 

construction cost to the project, these estimates were not based on new analyses of the project. 

Instead, the RTP and PMT estimates simply re-used the construction cost estimate from the last 

rigorous analysis of the project {the 1986 MBTA Bowdoin/Charles Connector Project report) and 

escalated those costs to me RTP or PMT year. The Red/Blue DEIR is, therefore, the first 

substantive analysis of costs for the Red/Blue Connector project in more than 20 years. 

New information gathered during conceptual design disproved old assumptions. The 

conceptual design work overseen by MassDOT starting in 2009 forced MassDOT and the 

consultant team to revisit previous assumptions. An example is the preferred tunneling method. 

Previous cost estimates had assumed 'cut and cover' construction, which is typically less 

expensive than is the use of a turmel boring machine (TBM). However, due to the density and 

complexity of the utility networks beneath Cambridge Street, it was determined by MassDOT 

during this most recent planning process that cut and cover construction in this environment 

would actually be at least as expensive as a TBM approach. As a result, the savings resulting 

from a cut and cover approach envisioned by past analyses of the project would likely not be 

realized. 

Budgeting for contingency is now much more conservative. In the late 1980s, the MBTAdeveloped cost estimates for the project included a 20 percent contingency. The DB1R cost 

estimate, which is informed by two more decades of project management, the experience from 

the Central Artery/Tunnel project, and guidance from the Federal Transit Administration, 

includes a more conservative 40 percent contingency. MassDOT believes that a 40 percent 

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contingency is appropriate given the conceptual stage of design, and the uncertainties inherent in 

a project involving tunneling under a dense and historic urban environment. 

DEIR cost estimate reflects a new project scope. The 1980s analysis of the Bowdoin/Charles 

Connector did not include project components that were determined to be essential by MassDOT 

in 2010. For example, the 1986 analysis assumed that Bowdoin Station would be retained and 

that the extension would make use of that station's existing tail tracks. However, the MBTA has 

since determined that it cannot allow revenue service - the operation of transit vehicles with 

passengers on board - on the Bowdoin loop. This is due to the challenges in safely evacuating 

passengers with disabilities from a train that might become disabled on this tight curve. As a 

result, whether or not Bowdoin Station is retained in the project, the tunnel construction will now 

extend several hundred more feet to the edge of Government Center Station. 

Design and permitting done now will need to be duplicated later. Finally, because the RTP 

does not include funding for construction of this project at any time in the next 25 years, it is fair 

to expect that the project will not actually be constructed during that time period even if the final 

design is completed. As a result, the final EIR and final design documents would need to be 

substantially, if not completely, revised and updated to reflect changed conditions and 

requirements at the time that the project was ultimately advanced for construction. There is no 

point in spending scarce public transit funds to develop documents that we know will need to be 

superseded later. 

At some point, a project's costs rise to the level where the pursuit of what was once a sound 

investment becomes simply unaffordable. I , therefore, respectfully submit this request for your 

consideration of removing the final design of this project, which by itself will generate no air 

quality benefits, from the Transit System Improvement Regulations and the SIP. Unless 

MassDEP removes this requirement, MassDOT "will continue to be required to do the design or 

risk being in violation of the regulation and the SIP. 

I look forward to your response, and we will work with you and your staff to address any 

questions or issues that arise from our request. If you have any questions, please do not hesitate 

to contact me at 617-973-7844 or david.mohler@state.ma.us. 

Conclusion 

Sincerely, 

David J.jMohler 

Executive-Director 

Office of Transportation Planning 

cc: Red Line/Blue Line Connector Working Group 

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