SAND has submitted the following comment letter to the Executive Office of Environmental Affairs regarding recently proposed changes to the the South Boston Piers Transitway. Transit and public transportation systems are viewed by many within SAND to be the Achilles heel of the South Boston waterfront planning process.

SAND continues to make suggestions to the MBTA, the BRA and BTD in an attempt to isolate and correct potential problem areas. To this degree, we continue to stress a plan that discourages private vehicular traffic, stimulates early development of a high-capacity public transportation system, accommodates alternate transit modes (rail, bike, ferry) and provides unfettered access for trucks entering and exiting the Marine Industrial Park.

June 14, 1999

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

Attn: Mr. William Gage

re: Comment on South Boston Piers/Fort Point Channel Transit Project, Boston
Initial Vehicle Technology and New Connector Road
EOEA # 6826

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.

We appreciate the changes which are incorporated into the responses to earlier NPC comments. Larger capacity vehicles, running with minimal headway will be necessary to provide adequate levels of service. Direct connection to Logan Airport is also a critical link.

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. This plan is insufficient to permit the currently anticipated level of development of 18 million square feet of office space, 4,000 to 8,000 residences, 3,500 hotel rooms, and the demands of the Convention Center, among others. Without sufficient levels of transit service these goals cannot be met. It is true that development has lagged behind the prior timeline. But the Convention Center and its hotels are now a certainty, Massport has one office building in construction and three more in advanced planning stages. Fan Pier development is moving forward, with a proposal for 3.3 million square feet of mixed use construction. And the Central Artery is maintaining its schedule for completion.

Vehicle capacity of 90 passengers, moving on a 2.5 minute headway during rush hour, will deliver 2,160 passengers per hour and under 5,000 total during morning and evening peak demand times. Massport alone, in its Parcel F EENF covers two buildings with 440,000 sf of office space, 416 hotel rooms, 88 residences, and 32,250 sf of retail and restaurant space, and asserts public transportation shares up to 62% for 14,055 daily person trips. Total transit trips are expected to be 6,620 per day. If this pattern holds typically throughout the South Boston Seaport District over one-quarter million transit trips would be desired daily. Only a very small fraction of that anticipated transit demand will be able to be met by the Silver Line. In the absence of other plans for upgrading other lines of service, greatly increased vehicle congestion will result from this lack of coordination.

It is concerning that responses to questions vary as to whether it will ever be possible to have a single seat trip from Dudley Square to Logan Airport. This should be clarified as to timetable, procurement, budget and physical constraints. It is also problematic that at least one existing bus line will be incorporated into future Silver Line service. We had assumed that ridership projections would represent new seats for new demand, not incorporation of existing riders. That number, for the #7 bus, will need to be deducted from the new service numbers to have an accurate sense of what the new capacity will actually be. The MBTA has not stated what the ultimate capacity of this line will be, how additional rolling stock will both be provided in a timely manner if demand for service outstrips supply, what criteria will be used when contemplating expansion of service, and what the minimum headway time will be and how it will be managed for efficiency and safety. We are not aware of MBTA lines which currently maintain headways of under two minutes.

The NPC does not adequately address issues of the service life of the proposed vehicle and methodology for timely replacement, particularly at a unit cost of $830,000. It does not inform us why the newly proposed vehicle will be more likely to be available than the prior design vehicle.

The NPC does not address previously anticipated actions such as servicing of anticipated conventioneers, or provision of an additional stop at the new Convention Center, beyond asserting that there will be one and that the route is feasible, if round about. The BCEC does not seem to have the same view towards provision of a Transitway stop, and yet is expecting to rely heavily on public transport to be able to meet demand. Other planning efforts are based 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, particularly interfering with pedestrian movement. The interface at the surface should be made so that there is adequate warning and safety when a trolley will be on the sidewalks. The MBTA responses do not address issues of the viability of a grade separated crossing of D Street, leading to the conclusion that it is possible. They make no response to the amount of delay and congestion that a surface crossing would contribute, or its effect on maintaining Transitway schedules if there were to be traffic jams. Estimates of potential additional costs have not been offered, precluding informed discussion of the relative merits of the two options.

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? What will our neighborhood be like should development proceed rapidly and transit be delayed? It seems likely that stations are now be constructed that will not permit vehicles other than lower capacity Green-Line types, precluding eventual transition to rail vehicles, 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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