Public comment on the Urban Ring Phase 2 bus system was due February 10, 2009. Marilyn Wellons sent the following to Executive Office of Energy and Environmental Affairs Secretary Ian A. Bowles and Massachusetts Environmental Protection Agency Assistant Director Richard Bourre that day.
Dear Secretary Bowles, Mr. Bourre:
re: Urban Ring Phase 2 Revised Draft Environmental Impact Report, EOEA #12565
The revised draft acknowledges significant uncertainties regarding routes, financing, and regional and national economic futures. It nevertheless attaches numbers to critical factors affecting the realization of its goal, stated in the Executive Summary at 1.1, to reach a Locally Preferred Option (LPA). With these numbers and much less uncertainty it assesses the environmental costs and benefits of the LPA. Herewith my suggestions for further revision:
During ten year’s participation in discussions of the Urban Ring Phase 2 (UR2) for Bus Rapid Transit (BRT), my focus has been on the Charles River environment around the Grand Junction Railroad and/or Boston University bridges. It has necessarily expanded to include other proposed river crossings and the Beacon Freight Yards in Allston.
Phase 3. I very much support public transportation, mass transit, and, in principle, the Urban Ring. Like many others, I favor going directly to the 2001 Major Investment Study’s (MIS) Phase 3A2 rail in the central corridor while improving existing bus routes, such as the No. 47, for example. Given the cost of the tunnel through Longwood Medical Area (LMA), the need to keep all Phase 3 options open (Secretary’s May 20, 2005 Certificate), and the renewed understanding of mass transit’s benefits, this makes more sense to me than spending money on BRT. Consequently the RDEIR’s failure to maintain alternative UR3A2 at the northern end of the LMA tunnel raises serious doubts about the state’s commitment Phase 3 and, with it, to environmentally responsible transportation planning.
Analysis of the RDEIR’s understanding of the Charles River and other riverfront parkland and of the Beacon Freight Yards does nothing to dispel these doubts.
Open Space. Beginning with Table 5.5.B’s misidentification of Charles River parkland around the UR2 river crossing in Cambridge (Segment B, sector 6) as entirely “commercial” (p. 5-11), the RDEIR fails to see the value of this land’s current use, in addition to sports and cycling, as urban wild—home to waterfowl, songbirds, rabbits, and hawks—and passive open space. Later references to “recreation” in the inventory of parks are to active uses, with no apparent sense of open space as a place for the re-creation of the human mind and spirit. Thus at the B6 Charles River crossing, the document’s attempt at fine-grained description of parkland vanishes. It quickly pulls away from the plants, animals, and humans whose habitat this is, to a satellite-level view of the entire “17-mile linear park . . . stretching from Watertown to the Charles River Dam in Boston” and its listing on the National Register of Historic Places. It notes bicyclists, walkers, and joggers, but not the many thousands of people who need unmediated contact with the natural world and have found it here.
The RDEIR at Section 5.7 cites “common,” not rare or endangered, plants and animals in this sector, apparently to dismiss their destruction as trivial. Just this indifference to the “common” has made many species rare, endangered, or extinct. Understanding the worth of the “common”—including us city dwellers—was the foundation of the Charles River Reservation in the first place. Also, please note the Wetlands Protection Act (WPA), M.G.L. Ch. 131, is not restricted to protecting rare or endangered species. Consigning this “common” habitat to destruction, or accepting the rationalization that damage from UR2 is not permanent (Table 5-45, p. 5-146) is a travesty.
Please note that for UR2’s river crossings at the Malden and Charles Rivers Chapter 91 will apply. Not only will permanent structures replace parkland, but destruction will extend throughout the Riverfront Areas, unchecked by the WPA. Through 310 C.M.R. Sec. 10.58 (6), Chapter 91 nullifies the WPA in this land, i.e., riverfront in historically tidal rivers between the Mean Annual High Water Mark and a parallel line that is 200 feet away in Medford, 25 feet in Everett and Cambridge. As we have seen at the BU Bridge in Cambridge, Chapter 91 means that Conservation Commissions will not be able to require alternatives analysis, impose a less environmentally damaging alternative from UR2’s proponents for work within these Riverfront Areas, nor require mitigation (MADEP File #123-0215). While the RDEIR notes where in UR2 Chapter 91 applies, it fails to record the consequences.
The effect of Ch. 91 on WPA protections, themselves assumed in federal law requiring environmental review of this transportation project, would thus seem to raise serious, and unaddressed, questions about the validity of the RDEIR itself in the federal process.
Beacon Yards. The RDEIR fails to assess the environmental consequences of reducing or eliminating the Beacon Freight Yards. Harvard’s plans for this land are important to the RDEIR’s estimates of regional growth in jobs and population, hence ridership, hence the viability of UR2. However, the planned change from intermodal freight in the urban core to institutional uses will increase truck traffic in the region, with negative effects on public health. The RDEIR does not, for example, ask whether the presumed increase in public transportation ridership and assumed reduction of vehicle trips will offset these unexamined effects. It is not clear that the state’s Freight Study will consider this issue, or if it will, whether the results will be available before filing of the Final Environmental Impact Report (FEIR).
I hope for consideration of these issues. Again, they raise serious doubts about the state’s commitment to environmentally responsible transportation planning as manifest in the UR2 RDEIR. While there is no doubt all involved in UR2 have worked long and hard on it, bureaucratic momentum alone should not justify the project.
Yours sincerely,
Marilyn Wellons
