I have today submitted environmental comments for the Commonwealth of Massachusetts’ MEPA environmental review of the South Station expansion project. Below is my letter. Immediately below this paragraph is the synopsis from the letter.
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The plans for South Station Expansion are deficient because they do not allow any room for any expansion beyond South Coast rail. There seems to be exactly zero room after that. Alternatives are proposed by me which should be considered.
Similar problems exist at the Beacon Yard layover proposal. My suggestion for improvement should be considered in the analysis..
With the current plans, new commuter train service which should go to South Station will have NO CHOICE but to go over the Grand Junction with major environmental destruction in Cambridge, starting with commuter rail traffic generated by West Station.
Failure to include analysis this totally new passenger route which is forced by the inadequate planning at South Station constitutes segmentation, both for interference with traffic on major Cambridge arteries and for environmental harm and increase of existing heartless animal abuse on the banks of the Charles River. Cambridge and the Department of Conservation are already practicing heartless animal abuse on the banks of the Charles River targeted at long term, valuable and popular resident animals.
Analysis should include the DCR’s policy in its “Charles River Master Plan” of killing off or driving away all resident animals on the Charles River Basin.
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December 2, 2014
Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs
MEPA Office, Attn: Holly Johnson, EEA #15028
100 Cambridge Street, Suite 900
Boston, MA 02114
holly.s.johnson@state.ma.us
RE:
South Station Expanion Project, EEA No. 15028
Draft Environmental Impact Report
1.
Synopsis.
2.
Introduction.
3.
Limits of the DEIR Analysis.
a.
Introductory.
b.
Beacon Yards Layover.
c.
Project facing Dorchester Avenue.
d.
Expansion to include a lower level or levels of track space for future expansion.
4.
It is segmentation if the analysis does not include passenger traffic in East Cambridge. Highway Conflict.
5.
It is segmentation if the analysis does not include passenger traffic in East Cambridge. Increase of existing heartless animal abuse.
6.
Summary.
Madame Secretary:
1.
Synopsis.
[Printed above, at the beginning of this blog post.]
2.
Introduction.
I am writing individually and as chair of Friends of the White Geese, a Massachusetts Non Profit Organization organized in 2001 with the purpose of protecting the environment and animals of the Charles River and related matters.
I myself have two years of on the ground experience in railroad operations. I have, as part of my railroad position, observed freight and passenger railroad operations first hand from Boston almost to Washington, DC. I have major experience in working on transit planning matters in the Boston / Cambridge area over a period of nearly 40 years.
I proposed the Kenmore Crossing on the Urban Ring subway concept five years before it was officially adopted by the MBTA as a recognized alternative route in 1991.
I have major environmental experience. In the last 15 years, this has been on Charles River and related matters. I rather clearly have prevented a mass animal killing in that location.
In the last 40 years I have used my legal training for the benefit of the environment in Cambridge.
I obtained a preliminary injunction on appeal, next to impossible, in a temporarily successful effort to protect from needless destruction one of the best parks in the middle of Cambridge, including more than 20 one hundred year old trees.
I have written more successful zoning changes in Cambridge than any other person not employed by the City of Cambridge, and, in sharp contrast to many changes drafted by the Cambridge Development Department my changes do what I said they would do.
I have used zoning as a tool to force environmental protection on very major parts of the City of Cambridge. My zoning changes have required ground floor open space and more housing on about 85% of Massachusetts Avenue in the area between Harvard and Central Squares and portions of adjacent side streets. My zoning changes allowed fairly large buildings on Mass. Ave. while maintaining environmental protections and protections for neighbors.
The building at the corner of Massachusetts Avenue and Harvard Street in east Harvard Square, formerly known as the Inn at Harvard was one of my big victories. Harvard wanted that building to be 72% larger and built to the sidewalk. The City Council disagreed.
About a block away, I saved the 19th Century building at 10 Mt. Auburn Street, on the corner of Banks and Mt. Auburn Streets from destruction by Harvard. I used fine print in the Cambridge Rent Control Ordinance, and the Cambridge Rent Control Board agreed with me. Saving that building probably was key in the retention of the historical character in this, the Kerry Corner neighborhood with Harvard’s expansion in this area since 2000.
The first two blocks north of Harvard Law School were downzoned as a result of the very first petition written by me.
There is a former parking lot between Alewife Station and Route 2 which is being returned to nature as a result of another zoning change I wrote. This is the only meaningful environmental victory in the Alewife area in spite of a Cambridge related group which claims to be protecting Alewife.
And this does not include the non explosive changes.
3.
Limits of the DEIR Analysis.
a.
Introductory.
I was fully in favor of the South Station Expansion Project until it sunk in that there is no thought whatsoever as to what flexibility exists for future expansion.
In fact, my understanding is that there is no thought of any capability of future expansion of South Station or its holding facilities whatsoever after this project.
It looks to me like the proposal traps our Commonwealth in the same sort of shortsighted thinking which brought railroad transportation into the fifty to sixty year mess which we are now attempting to undo. But after this go round, there may not be an opportunity to undo this mess.
b.
Beacon Yards Layover.
My analysis at South Station is another approach to my analysis in EEA #15278, the I90 Allston Interchange Project. The most serious problem in both plans is failure to allow for future expansion.
We do not have the luxury of being unconcerned about future expansion. We have the possibility now to leave room to allow our railroad system to thrive. If we do not take needed action now, we are boxing ourselves into a death of strangulation.
Correction of the artificially created limits on the layovers at Beacon Park can NOW be readily corrected by building layover tracks on both sides of the relocated Mass. Pike, not just on the side away from Cambridge Street, as is proposed in the I90 Allston Interchange Plan and blessed in the South Station Expansion Plan.
This shortsightedness can easily be corrected by inserting a switch in the access track from South Station to the proposed layover yard as that track approaches the proposed layover yard. The track approaches the layover yard under the reconstructed Mass. Pike Viaduct before the Mass. Pike returns to ground level. A switch can readily be inserted before the Mass. Pike returns to ground level so that the switch would give the option that layover trains can go on either side of the relocated ground level Mass. Pike. There is no plan for any public transportation use between the relocated Mass. Pike and Cambridge Street. There is plenty of room to set aside adequate area to allow for future transportation needs.
Please note that my analysis of the I90 Mass. Pike Allston project also proposes a layover yard between this added commuter rail layover area and Cambridge Street. This layover yard would be for a street car Green Line A spur from the existing Green Line B to Harvard Square as described in greater detail in my I90 analysis.
c.
Project facing Dorchester Avenue.
The same problem of total lack of future expansion applies to the main project.
I repeatedly hear reasons why greater expansion cannot be done, but it is clear that the limits being artificially imposed on the expansion project are the greatest problem for future South Station expansion.
Part of the unthinking limits problem, as it was 50 or 60 years ago, is the application of non railroad priorities ahead of railroad priorities in spite of the very great reality that the places where railroad expansion can be placed is under very severe limits, whereas the alternate uses do not have that very real limit.
This defective thinking applies strongly to that portion of the project facing Dorchester Avenue.
Certainly Boston needs housing, and certainly it is a lovely location for housing, BUT there are other locations for housing. There are pretty much no other locations to expand South Station capacity.
Addition of one or more tracks in the area facing Dorchester Avenue should be seriously considered. Perhaps the housing could be placed above the added tracks. A higher location for housing certainly would be inferior for housing, but this is a matter of life or death for future South Station expansion.
I am told there is a choke point problem in the entrance to South Station with regard to adding tracks next to Dorchester Avenue. I not aware of any meaningful analysis of the choke point. Have I missed something? At minimum, such an analysis should be presented.
d.
Expansion to include a lower level or levels of track space for future expansion.
A lower level or levels of track space is being proposed by the North-South rail people. Their idea could be a solution to the limits being imposed on South Station Expansion, with or without North-South rail.
Definitely, building 7 tracks at the same level as the current facility, plus building room under the 7 tracks for an additional expansion in the future sounds like an excellent way to get around the crunch point problem, if the crunch point at the entrance to the current South Station facility is a true and absolute limit on expansion at the current level.
Of course, the construction for access to the lower level IN THE FUTURE would be a lot more expensive than the current access cost for new tracks into the 7 proposed tracks.
But we are talking about a station which currently has 13 tracks being expanded to 20 tracks with no future expansion, as opposed to expanding to 20 or 22 tracks now with the possibility of 27 to 31 tracks in the future.
Creating a lower level could include expansion under Dorchester Avenue for the lower level. 2 tracks under Dorchester Avenue could combine with such larger lower and main levels as can be constructed at this time.
With the mail facility moved and Dorchester Avenue not yet reconnected to South Boston / Dorchester, construction under Dorchester Avenue would be readily feasible. Could that bring a possible lower level to 11 tracks with 9 tracks on the current level?
Can the expansion project build under tracks 11, 12 and 13 and others for future expansion? Why not include that in the analysis as well? Perhaps doing it in phases. Build toward Dorchester Avenue first, and let those new tracks temporarily replace 11, 12, and 13. Could a lower level be created under all the existing tracks, working in stages? There is no such analysis in the submittal.
An excellent example in the South Station complex of such planning for the future is the parking garage on top of the bus facility. That is obviously intended as a location of future expansion of bus service.
Why not use underground expansion in the future for parking in the short run as in the bus facility?
Why restrict underground expansion possibilities to one level, with parking until need and money exists? Can more underground levels be constructed with corresponding future track expansion, and interim use for parking..
This is not being studied and it should be.
Is it necessary or even sensible to create an artificial limit on future expansion of South Station?
4.
It is segmentation if the analysis does not include passenger traffic in East Cambridge. Highway Conflict.
Below is MassDOT’s map of the Grand Junction railroad in Cambridge taken from an MIT submittal. I have added thick markings of intersection conflict with existing road traffic.
As stated in my I90 Allston analysis, where will West Station trains go? Why guarantee an environmental nightmare in the eastern part of Cambridge for trains which sensibly should go to South Station?
And the reality is that, given the obvious forcing of use of East Cambridge for future expansion, it looks like failure to include impact of future expansion on East Cambridge would not only be segmentation, but would be dishonest.
There was great hostility to expanding commuter rail to East Cambridge the last time it was proposed. MassDOT’s analysis indicated that Grand Junction commuter rail use would have no value except for Kendall Square. There has been no communication of what looks like a certain proposal to put West Station commuter trains on the Grand Junction. Such lack of communication is dishonest.
Especially since creating underground facilities at South Station are obvious alternatives now, and there is no mention that the South Station expansion project as proposed will prevent future expansion and mandate use of the Grand Junction for West Station and other future expansion.
5.
It is segmentation if the analysis does not include passenger traffic in East Cambridge. Increase of existing heartless animal abuse.
In addition to the highway conflicts, there would be very real environmental conflicts and the ramping up of existing deliberate heartless animal abuse on the Charles River:
The portion of the banks of the Charles River abutting the Grand Junction on both sides of the Grand Junction is animal habitat. It includes animals of long term residence on the Charles River. In spite of a decade of outrageous misbehavior by Cambridge, the DCR and their friends, many resident animals continue to exist.
Of particular importance is the valuable popular gaggle of the Charles River White Geese who have resided on the Charles River for 34 years and have established a strong community readily admired by all familiar with them. The vibrancy of this free community is an ideal subject for scholastic study.
Their biggest problem of the Charles River White Geese is vile treatment and abuse by Cambridge and the DCR. The Charles River White Geese are, once again without mentioning it, being heartlessly and deliberately starved by Cambridge and the DCR taking their long term food at the Magazine Beach playing fields from them.
Cambridge’s map of the area is attached. This is yet another environmental attack on the animal habitat. Cambridge is considering building in the Destroyed Nesting Area of the Charles River White Geese and placing a fence following the railroad tracks blocking access between the two animal habitat areas.
The area which is animal habitat is bounded by the BU Boathouse on the north and the BU Bridge on the south, and by the hashed line to the left and the Charles River to the right.
This outrage has been achieved through flat out lying.
a.
The DCR manager has repeatedly promised “no harm” to the Charles River White Geese while deliberately starving them.
b.
Their food at the Magazine Beach playing fields has been taken from them with bizarre introduced bushes walling off the Magazine Beach playing fields from the Charles River. This outrage has been achieved through multiple lies and lies of omission.:
(1)
Never mentioned is the goal in the sanctified Charles River Master Plan to kill of or drive away all resident animals on the Charles River Basin. This vile goal in itself should be addressed in any environmental analysis.
(2)
The key DCR manager has spent ten years or more lying of no intent to harm them. This flat out lie was included in the Boston Globe article on the start of deliberate starvation by a quotation next to a photo of a massive earth mover next to a tiny confused resident.
(3)
The promise at the Magazine beach playing fields was a lawn to the river. So the DCR and Cambridge simply ignored the promise, and rewrote the supposedly sacrosanct Master Plan to comport to their lies of omission.
(4)
The DCR has contempt for bordering vegetation. They, twice a year, destroyed all bordering vegetation on the Charles River basin, and claim incompetence for the bizarre wall.
(5)
As many other projects as is conceivable includes heartless attacks on the residential animals supposedly incidental to the other projects.
(6)
The DCR repeatedly and loudly has proclaimed an intent to restrict the banks of the Charles River to river related activities. The starvation wall makes the Magazine Beach playing fields totally separated from the Charles River. They might as well be five miles inland.
(7)
Multiple other projects are in the works attacking resident animals while keeping the attacks secret.
(8)
Fake groups associated with the City of Cambridge function as company unions to achieve Cambridge and the DCR’s destruction by keeping concerned folk busy chasing their tails. And, in reality, too many supposedly transportation groups / protective groups are similarly influenced.
(9)
Cambridge commonly lies about supposed sainthood through loud initiatives which have no relation or minimal relation to their community which, in reality, serve no purpose other than to convince the voters that heartless animal abusers are the opposite. Excellent examples of this hypocrisy is
(a)
The repeated yelling at Circus owners for their abuse of animals while
(b)
Keeping Cambridge deliberate starving of the Charles River White Geese and other heartless abuse (Alewife in particular) as secret as they can get away with, and
( c )
Flat out lies that a government which is heavily involved in Charles River destruction and international relations has no business concerning itself with Charles River destruction.
The situation on the Charles River is an outrage. Sneaking through more destruction through secret aspects to the South Station Expansion and the I90 Allston Interchange project fits a reprehensible pattern.
MassDOT has rejected more obvious attacks on the Charles River by rejecting proposals for highway construction over the Grand Junction bridge.
MassDOT is a responsible agency. The same cannot be said for Cambridge, the DCR and their friends. These dishonest entities should not be rewarded with destruction unavoidable after their maneuvering, but very real if you realize what is really involved in the South Station Expansion and I90 Allston Interchange project.
6.
Summary.
The proposal is generally excellent.
It strikes me as silly to artificially restrict future South Station expansion when we have seen the railroads destroyed 50 to 60 years ago as a result of devaluing these excellent source of transportation.
Review should be made of allowing for further expansion using South Station after the South Coast project is in operation.
Why prevent further expansion of South Station after the currently planned expansion of trains into South Station?
And why allow unavoidable “side effects” to be rammed through in secret?
Thank you for your kind consideration.
In particular, I am strongly impressed with the professionalism of both MassDOT teams, here and in the I90 Allston Interchange project. I have seen praiseworthy examples of MassDOT standing up to environmental outrages stemming from the City of Cambridge and the DCR, especially through unidentified but very truly influenced “private” individuals.
My favorable impression of MassDOT is strikingly different from my impression of Cambridge and the DCR.
Sincerely,
Robert J. La Trémouille
