SAND has responded to a Notice of Project Change (NPC) filed by the MBTA affecting plans for the the Piers Transitway now in construction. SAND continues to register concerns regarding the MBTA's underestimation of future demand for public transportation in the Seaport District, the types of vehicles used in the Transitway, and the limitations in design of an above-ground wired system from D Street through Massport's Parcel F.

Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
Attention: MEPA Office
100 Cambridge Street, 20th Floor
Boston, MA 02202

re: Comment on South Boston Piers/Fort Point Channel Transit Project, Boston
............Initial Vehicle Technology and New Connector Road

EOEA # 6826, Mr. William Gage

Dear Secretary Durand,

The Seaport Alliance for a Neighborhood Design (SAND) supports and endorses the proposed construction of this vital transitway link, but would like to take this opportunity to raise certain issues. We believe the course of action outlined in the NPC will compromise the operation of the Transitway, contravene prior agreements, and will further inhibit and delay proper development of the Seaport District. This NPC should therefore not be approved in this form.

Development in the Seaport is currently limited by issues of access, and the pace of future development will also be guided by the ability to efficiently convey workers to jobs, 24 hours a day. The previous plan was insufficient to permit the currently anticipated level of development. This reduction in service will make the Seaport less desirable and more difficult to access.

The NPC does not adequately address issues of the service life of the proposed vehicle and methodology for timely replacement, it does not prove that the newly proposed vehicle will be any more likely to be available than the prior design vehicle, and it provides no strategy or methodology for provision of additional service when additional demand arises.

The NPC does not address previously anticipated actions such as servicing of anticipated conventioneers, provision of an additional stop at the new Convention Center, extention of the line to serve Logan Airport, or linkage to a spur of the Urban Ring. Other planning efforts are relying upon these elements and will be significantly compromised by their lack, possibly leading to failure of the roadway system.

The crossing of D Street should be made below grade so that there is no interface with surface traffic. D Street should not be degraded with catenary lines and masts. Should the vehicles' connection be broken, a common occurrence with electric coaches, it would paralyse trafffic in this critical location.

We currently see a worrisome pattern of MBTA projects which are falling years behind on their commitments. Does the absence of a schedule for transition to rail vehicles indicate an abandoning of previous commitments? Serving the full ridership spectrum would generate sufficient patronage to justify this mode. It seems likely that stations will now be constructed that will not permit vehicles other than Green-Line types, further limiting the success of this publicly funded project and requiring still greater reliance on private automobiles.


Jon Seward, on behalf of
Seaport Alliance for a Neighborhood Design

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