Kenneth J. Krause 

50 Mystic Street Medford, MA 02155 

781-396-0920 kenneth.krause@comcast.net 

September 24, 2012 

Jerome Grafe 

MassDEP, Bureau of Waste Prevention 

One Winter Street, 6th Floor 

Boston, MA 02108 

Dear Mr. Grafe, 

Thank you for the opportunity to comment on the proposed amendments to 310 CMR 

7.36, Transit System Improvements, as requested by the Massachusetts Department of 

Transportation (MassDOT). 

I am writing specifically to recommend that MassDEP oppose the request from 

MassDOT to delete the requirement that MassDOT complete the final design of the Red 

Line/Blue Line Connector as part of the State Implementation Plan - Transit 

Commitments. 

The need to connect the only MBTA heavy rail lines that do not intersect has never 

been greater. The corridor served by these two lines continues to experience explosive 

growth, particularly in new jobs and housing that has been created or is under 

development in Cambridge, South Boston, and East Boston. 

More significantly, Suffolk Downs - on the Blue Line in East Boston - is a leading 

candidate for a casino gambling license that, if granted, would trigger a huge 

redevelopment of the race track into a resort casino that would attract thousands of 

visitors and employees daily. (And, according to the Sept. 21, 2012 Boston Herald, a 

developer also is examining the possibility of South Station - on the Red Line in Boston 

- as a casino location.) 

The introduction of a casino in one of these locations is just one more reason why the 

Red/Blue Connector design should not be removed from the SIP transit commitments. If 

anything, this should elevate the importance of the project and jump-start work on the 

next phase - with the ^n^ciaL^sjjpport ofJ^fj^kiErolftns should it be granted a casino 

license, as is widely expected. 

Suffolk Downs officials already have pledged financial support for roadway 

improvements on Route 1 near the race track, but have overlooked the need to improve 

public transit service to the area. Meanwhile, other private entities have recently 

stepped up and offered financial contributions to the creation of commuter rail stations, 

most notably New Balance Company for its new campus in Brighton, and Raynham 

Park in Taunton should it receive a slot parlor license. Suffolk Downs should be 

approached for a similar commitment. 

Kenneth J. Krause - 2012 SIP Amendment 
I also find the amendment request by MassDOT to be extremely shortsighted and poor 

planning policy, backed by questionable rationale. 

There has already been a significant amount of work performed on the Red/Blue 

Connector, particularly in terms of environmental review, alternatives analysis and 

conceptual design, that should not be wasted by shelving the project. Moreover, this 

work has been completed at a reasonable cost of $3 million. 

That figure makes curious the MassDOT estimate that the cost of final design of the 

Red/Blue Connector has somehow ballooned to $52 million from the previous estimate 

of $29 million, a figure that in earlier comment letters I had termed incomprehensibly 

high for the design of a half-mile tunnel and one underground station. 

MassDOT's major reason for asking to be relieved of its SIP Red/Blue requirement -

that it has been unable to identify funding to construct the Red/Blue Connector "at any 

point in the next 20 years" - is not a sound one, in my view. Few projects in that time 

horizon have a fully identified funding source, yet planning wisely continues on the 

projects deemed most valuable (which I submit the Red/Blue Connector is one) so they 

are shovel-ready when funding is secured for them. 

Curiously, MassDOT continues to aggressively pursue the South Coast Rail project -

with Governor Patrick as recently as last week meeting with EPA officials and others in 

Washington to try to advance this project past regulatory hurdles - despite the fact that 

it is neither a SIP Transit Commitment project, nor does it have any construction money 

appropriated at this time. 

My opinion is that the Red/Blue Connector is an immensely valuable project that is 

integral to the efficiency of the MBTA system and its ability to meet increasing ridership 

demands, and therefore should not be removed as a SIP requirement. 

However, should MassDEP agree with MassDOT's request to cease work on the 

Red/Blue Connector, it must require MassDOT to identify substitution projects and 

commit to building them via inclusion in the SIP. The most logical, practical and 

environmentally beneficial substitution project to add is construction of the permanent 

terminus for the Green Line Extension at Mystic Valley Parkway (Route 16) on the 

Somerville/Medford line. 

Not only is this location MassDOT's Preferred Full Build Alternative for the Green Line 

Extension and has unanimous support from all major stakeholders, but it is a project -

unlike Red/Blue - for which the state has identified a funding source, and not over a 

20-year horizon, but in the next eight years! This spring, the Boston Region MPO 

continued to make the Route 16 station a priority in its Long Range Transportation Plan, 

designating $190 million for the design and construction of this important last segment 

of the extension for federal fiscal years 2016 through 2020. 

Kenneth J. Krause - 2012 SIP Amendment 
It is imperative that the state align its planning and funding resources so that they are 

focusing on the same goals (and the same projects). The addition of construction of the 

Green Line Extension to Route 16 to the SIP would be the perfect substitution project 

for the elimination of the Red/Blue Connector design (which already had been scaled 

back from the original SIP commitment, which was to design and construct the 

Connector). 

My final suggestion regarding MassDOT's amendment request is for MassDEP to also 

require MassDOT to appropriate $26 million - the difference between the original $29 

million estimate for the Red/Blue Connector design and the $3 million already spent on 

it - toward the Interim Offset Projects that the state is required to implement as a 

penalty for missing the deadlines to complete two other SIP projects: the Fairmount 

Commuter Rail enhancements, and the Green Line Extension to Somerville and 

Medford. 

Specifically, a large portion of this money should be designated to be spent on two 

Interim Offset Projects in the Green Line Extension corridor: 

+ Construction of the multi-use pathway from Harvard Avenue at the West 

Medford/Arlington line to the Maiden Bridge between Somerville and Everett, as 

described and mapped in the Mystic River Reservation Master Plan of November 2009. 

+ Construction of the extension of the Somerville Community Path in all applicable 

geographic areas contained in Phase I of the Green Line Extension construction, which 

has a completion timetable concurrent with the deadline for implementation of the 

Interim Offset Projects (December 31, 2014). 

Both of these projects will provide significant regional mobility and air quality benefits by 

providing safe, accessible and inviting routes for bicycling and walking (including 

improved access to transit) that will make these modes an attractive and viable 

alternative to driving in this badly congested and polluted corridor. 

Thank you for your consideration. 

Ken/Krau^ 

Ken Krause 

50 Mystic St. 

Medford, MA 02155 

781-396-0920 

cc: David Mohler, Boston Region MPO 

Richard Davey, Secretary of Transportation 

Kenneth J. Krause - 2012 SIP Amendment