Thursday, January 17, 2008

Letter to BC Task Force: Traffic, Transportation, and Parking

At Wednesday night's meeting of the BC Task Force on the topic of traffic/transportation/parking in Boston College's Institutional Master Plan Notification Form, I presented the following letter to the task force for their consideration.

Much of the information in the letter grew out of a series of community meetings of the BC Neighbors Forum during 2007 which I facilitated. It is not a "position paper" (nor a public comment for the scoping determination) per se, but instead my attempt at summarizing the various concerns that were raised at those meetings -- and add a few more.

TO: Jeanne Woods, Chair, BC Task Force
DATE: January 16, 2008
RE: Traffic, Transportation, and Parking in Boston College's IMPNF

Dear Ms. Woods,

In this letter, I outline a series of issues needing discussion in the traffic, transportation, and parking proposals in Boston College's Institutional Master Plan Notification Form of December 5, 2007. Most of these issues have been raised by Brighton residents in previous meetings of the BC Neighbors Forum.

1. Need for Independent Peer Review of Traffic, Transportation, and Parking Studies (and Their Assumptions). Members of the public and the BC Task Force are neither experts nor engineers in the field of traffic and transportation. BC's traffic, transportation, and parking studies should therefore be subjected to an independent peer review in order to examine their assumptions, data, models, analysis, and conclusions.

Such peer review is standard practice in the field of traffic engineering. Allowing municipalities to charge for it is provided in state law (MGL 44, section 53G). Many neighboring municipalities charge developers for independent, third-party review (e.g., Somerville, Plymouth, Hopkinton, Salem, Winchester, Stoneham, etc.).

a)BC should pay the costs of the independent peer review (Harvard is already doing so through as part of their review with the Massachusetts Environmental Protection Act Office);
b)The BC Task Force, or another suitable community organization (such as the ABCDC), should act as both the fiscal agent and client for the peer review (this is already being done by the Citizens Advisory Committee in the Special Review Procedure for the Harvard case);
c)The peer review should examine the assumptions [see #6 below], data, models, analysis, and conclusions of BC's consultant's traffic study, including breaking down the traffic analysis by individual element [see #2 below];
d)The peer review should also examine errors in BC's 2000 traffic study, and certify that those errors have been corrected [see #5 below];
e)BC's consultants should share data in electronic format with the peer reviewer(s); and
f)The peer review should be conducted, and its results shared with the community, well in advance of BC submitting their next filing to the BRA (e.g., DPIR) so that the results can be studied and any remaining problems identified.

2. Traffic Analysis Should be Done for Individual Elements of Their Proposals. BC's traffic and transportation proposals for the intersection of Lake St and Comm Ave are:

a)Moving MBTA station. BC has proposed to move the MBTA station from its current location northwest of the intersection of Lake Street and Commonwealth Avenue to the center of Commonwealth Avenue east of Lake Street.
b)Creating new intersection east of Lake Street. BC has proposed to create a new intersection that crosses Commonwealth Avenue and the MBTA B line tracks at a location east of Lake Street (and east of the proposed new MBTA station).
c)Re-routing St. Thomas More Road. BC has proposed to re-route St. Thomas More Road, a city street on state-owned land, further to the east (to link up with the intersection in b) above).

The traffic and transportation impacts of these three elements must be analyzed both individually and in every possible combination in order to determine which elements improve the traffic flow – and which do not. Elements not contributing to traffic improvement should be removed from the IMP. For example, if moving the MBTA station all by itself creates all the improvement in the level-of-service (LOS) for the intersection of Lake Street and Commonwealth Avenue, then there is no public need to re-route St. Thomas More Road.

3. Stone Walls Along Commonwealth Avenue Should Not Be Removed to Provide Space for MBTA Center Platforms. If it is built, in order to provide for a wider center-platform MBTA station, the stone walls located along both the north and south sides of Commonwealth Avenue should not be modified from their current state. This may entail the trade-off of loss of a small number of on-street parking spaces along Commonwealth Avenue. Since BC is strongly advocating the new MBTA station, they should provide substitute parking spaces nearby.

4. MBTA Car Barn Land and/or Air Rights. BC and the MBTA should communicate to the neighborhood immediately if any kind of discussions have occurred regarding purchase and/or lease of land and/or air rights for the MBTA car barn parcel northeast of Lake St and Comm Ave.

5. Failures of the Traffic Assumptions, Models, and Analysis in BC's 2000 IMP Must be Fully Documented and Corrected. The traffic models in BC's approved IMP from the year 2000 contain the following information for the intersection of Lake Street and Commonwealth Avenue:

a)The intersection's actual "Level-of-Service" (LOS) in 2000 was rated a “C” overall (2000 IMP, App. B, Table 12);
b)The LOS no-build prediction for 2005 was a “D” (Table 14);
c)The LOS build prediction for 2005 was a a “D” (Table 24);
d)The LOS no-build prediction for 2010 was a “D” (Table 16); and
e)The LOS build prediction for 2010 was a “D” (Table 26).

As we know from BC's March 2007 presentation to the BC Task Force, the actual LOS for 2007 is “F” for this intersection. Note that the shrinkage of the Archdiocese of Boston, unanticipated in 2000, should have, if anything, decreased the traffic in that intersection; the opposite appears to have occurred.

The traffic assumptions, models, and/or analysis in BC's IMP of 2000 were therefore demonstrably flawed. These flaws must be identified, explained to the community, and corrected in their current traffic analysis. Their current traffic model must be capable of using the traffic data of 2000 in order to correctly predict the actual traffic data of 2007. I note that these glaring and systematic errors in their 2000 traffic study points to the need for independent peer review.

6. Assumptions for Traffic, Transportation, and Parking Must be Justified and/or Corrected. BC's 10-year master plan calls for an increase in their faculty of 100. Such an increase in the number of faculty usually bring an associated increase in the number of professional research staff, post-doctoral researchers and fellows, technicians, graduate students, secretaries, grant administrators, and the support staff (custodial, food service, stock rooms, etc.).

BC claims in their IMPNF that their increase of 100 faculty members would be accompanied by 342 new graduate students – but only an increase of 12 in all other categories of employees combined!!! (Table 6-3) Their 2000 IMP estimated an increase of 11 new faculty and 93 staff (2000 IMP, App. B, p.55). The ratio of increased faculty-to-staff has changed by a factor of 70 between 2000 and 2007!!! The 2007 numbers are highly suspect.
Jeanne Levesque, BC Director of Government Relations, has noted (private communication) that 23 of the 100 new faculty members will be in the natural sciences. These science faculty members will bring in a substantial number of new post-doctoral researchers, technicians, scientific staff, and so on.

Full disclosure of the ratio of faculty to all employees in BC's natural sciences departments (physics, biology, chemistry, etc.) should be required (it was requested verbally from BC), and the increase in total faculty, staff, and students should be independently reviewed.

Anecdotal evidence can be found at the website for some individual faculty members' labs, which indicate that there are often around eight employees per faculty member's lab group. Inspection of Harvard University's Department of Molecular and Cell Biology, and Harvard Medical School's Department of Cell Biology, indicates that there are 12.6 employees in addition to each member of the faculty. Whether we adopt a ratio of eight (BC anecdotal evidence) or 12.6 (Harvard examples), just the 23 new natural sciences faculty members will bring with them an additional 184 to 290 employees in the other (staff) categories.

These additional employees must be accounted for transparently and included in BC's traffic, transportation, and parking plans. In so doing, BC will likely have to increase the number of parking spaces to be built on-campus as part of their IMP. For example, an increase in 290 staff employees (compared to an increase of 12 in the IMPNF) would require an additional 222 parking spaces (using 80% auto mode share for faculty and staff).

7. Inadequate Parking Spaces in Master Plan. Even with BC's estimated increase of only 100 faculty, 12 staff, and 342 graduate students (Table 6-3), the master plan does not construct enough new parking spaces to accommodate those new employees.

Faculty and staff currently have a 80% auto mode share (Table 6-4), while students have an auto mode share of 26% (Table 6-4). [Note: BC needs to separate students into undergraduate and graduate students for tabulating mode share and other statistical data.] Using these mode share numbers, BC's estimated increase in employees requires an increase in 179 new parking spaces, but their master plan only increases parking spaces by 36.

The needed increase in the number of parking spaces should be scoped and included in the IMP. Furthermore, the location of these parking spaces is highly problematical: effectively, BC is moving 150 spaces from the main Chestnut Hill Campus to the Newton Campus, while their faculty and staff increase (80% of whom drive!) are likely to be concentrated in the Chestnut Hill Campus. The location of new parking spaces should follow the location of the new BC students and faculty. Modified locations for the new and/or substitute parking spaces should be scoped.

8. Substantial Improvement Is Needed to BC's Transportation Demand Management Program. Boston College's TDM program appears to have shown only limited success, in that 80% of their faculty and staff drive to work everyday (2007 IMPNF Table 6-4). In 2000, however, BC reported that 70% of their faculty and staff drove to work alone (2000 IMP, Appendix B, Table 9).

In the absence of an effective Transportation Demand Management Program, Boston College regressed in getting their faculty and staff to use alternate transportation methods. A vastly improved and aggressive TDM program, with clear targets and penalties, should be a requirement of their IMP.

Example: BC Should Subsidized MBTA Passes. It is astonishing that BC does not subsidize public transportation passes for their faculty or staff. One easy and effective way to reduce the auto mode share is to subsidize monthly T passes, for example, by 50% – and by allowing them to be purchased before payroll taxes are deducted.

9. New Cut-Through Route Will Divert Traffic Onto Foster Street. Currently, traffic from northbound St. Thomas More Road or eastbound Commonwealth Avenue cannot easily access Foster Street northbound without taking a U-turn on Commonwealth Avenue. (The intersection of Foster Street and Commonwealth Avenue does not extend across the MBTA B line tracks.) Opening up the new intersection at the entrance to the Brighton Campus will provide for a new cut-through route to Foster Street. Such additional traffic diverted onto Foster Street will overburden a narrow street already the subject of regular vehicle damage and speeding. The recent effects of the street closure next to the Brooks Pharmacy on Market Street created a 1 km backup along Foster Street, indicating how the street is critically burdened already.

The methods to prevent this cut-through route are: (1) locked gate [near Clements Hall] blocking through traffic, or (2) closed entrances to Brighton Campus [fully manned 24/7] requiring permit access for parking. Without either of these solutions, BC's proposal will create a new traffic route that would defeat the original layout of the streets emphasizing, e.g., Chestnut Hill Avenue for through traffic. BC should scope both options in their master plan and justify the final option.

10. Street Parking Study Should Be Performed to Determine Impact of Illegal Parking by BC Community on City Streets. BC does not provide on-campus parking for most of its undergraduates, leading to many parking off-campus illegally on city streets without resident parking stickers. Other commuters to campus avoid on-campus parking fees – or because they do not qualify for on-campus parking – by parking illegally on city streets.

BC should be required to to a thorough, wide-ranging, and complete street parking survey of the entire surrounding neighborhood within, say, 0.25 mile of any BC property. This survey should be done at a series of times at each location – e.g., midday; late-night on weeknights; and late-night on week-ends. The results should be compared to known locations for BC off-campus student rentals and on-campus buildings (e.g., academic, administrative, athletics, and housing). Cars should be identified by visible, legal parking stickers, any BC identification characteristics, state of license plate registration, etc. The availability of street parking throughout the impacted neighborhoods should also be fully documented.

All impacts of BC community using street parking must be addressed in the DPIR with a clear path towards resolution (and penalties for failing to meet targets) for all of those impacts. BC needs to be proactive to prevent such illegal parking by members of their community, rather than simply saying that it is the city's job to enforce those laws.


Michael Pahre
76 Foster Street
Brighton, MA 02135


Eagle in Brighton said...


Why do you feel the need to pick apart practically every facet of BC's 10 year plan?

I'll even concede you have some legitimate concerns in regards to the proximity of the baseball field to residences, but you need a dose of reality here. A few genuine issues have spawned a laundry list of absurdly contentious points.

Does the placement of dormitories on Shea Field really bother you? Does the omission of some TA’s from the proposed faculty addition figure truly get your goat? Does it really matter if the baseball field has a turf, rather than grass, field?

The answer is no.

At the end of the day, activists like you and Eva, just simply like to hear the sound of your own voices.

I understand you’re trying to meet (BC) force with your own form of stonewalling. But Brighton campus will not remain a park for your leisure. Nor will the only buildings erected be erudite museums or quiet offices.

Work for a compromise, not some absurd ideal.

(And no, placing all new dormitories and athletic facilities all on the current campus is not a practical stance)


Michael Pahre said...

Dear Eagle in Brighton,

You appear to be unaware that BC's institutional master plan is currently in a public comment period leading to the Boston Redevelopment Authority's scoping determination.

These comments, no matter how broad or narrow, guide the BRA in how BC's thin proposal should be fleshed out and studied in detail. These kind of comments are what the BRA requests under the Article 80 process of the zoning code.

If you are unaware of how zoning works in the City of Boston, you might do some research into the matter so that you will understand the process.

Eagle in Brighton said...

But truthfully, does it really matter to you, as a resident of Brighton, MA, whether the terrain on a proposed baseball field in your neighborhood is covered in FieldTurf or grass? Yes or No.

Michael Pahre said...

Yes, absolutely.

amartin said...

I agree with EIB in the sense that what frustrates a lot of BC people is the attempt to stonewall everything suggested by BC. sure, there are some legitimate issues, but in reality there needs to be compromise. Taking a stance against absolutely every suggestion just makes the process that much more contentious. How can the neighbors legitimtely oppose students in the neighborhoods, while also opposing dorms on Seminary and Shea field? and also oppose fields. then complain about people parking in the neighborhoods while at the same time fighting proposals to build garages.

Development happens, you can't stop it. so you should work for a compromise instead taking such a radical stance. Look, the house i grew up in was bordered on three sides by open corn fields. now, its surrounded by condos. my parents didn't like it, so they sold and moved farther out into the country. its reality.

william said...

Here's a passage from your letter that really stuck out to me:

Elements not contributing to traffic improvement should be removed from the IMP. For example, if moving the MBTA station all by itself creates all the improvement in the level-of-service (LOS) for the intersection of Lake Street and Commonwealth Avenue, then there is no public need to re-route St. Thomas More Road.

It seems to be implying that if something in the BC plan does not serve the "public need," it should not be included. What about the needs to the university? Are you trying to say that if something does not produce a net benefit for the public, BC should not be allowed to do it? What about the needs of the university, which actually purchased the land? That is why they want to reroute More Road. This process between the university and the community that you extol above is supposed to be a two-way street.

Michael Pahre said...


What you seem to have misunderstood is that St. Thomas More Road is a public way. (If I have the ownership correct, it is a city street lease of state-owned park land.)

No private developer ought to unilaterally move a public street unless there is an associated public good. I expressed a clear criterion that could be used to evaluate what constitutes a public good: improved level-of-service for the combined intersection.

That said, if BC simply wanted to add a new street on their own property, while leaving the current street in place, the threshhold for approval might be lower.

If you were involved in the process, you would realize that BC has actually discussed both options. Adding a new street while keeping the current one is option 3, while removing the current one is option 4.

This is a process by which the city tries to figure out how various aspects of BC's master plan need to be studied. Requesting detailed studies, etc., are an intrinsic part of the process -- not a statement of opposition.

A prominent traffic and transportation engineer in the state showed up at last night's meeting and said that it is impossible to evaluate the relative merits of options 1-4 without various further studies.

dave said...

eagle in brighton,

To suggest there is a need to pick apart every facet of BC's 10 year plan by those who live and represent a voice in the neighborhood is shortsighted to say the least, and to suggest that folks like Mr. Pahre simply like to hear to sound of their own voice is ignorant.

As a lifelong resident of Brighton the 10-year institutional plan is of great concern with the surrounding neighborhood. Unfortunately from past experience BC has shown no regard to the surrounding community with its current and past plans as long as it serves BC's best interest.

One of the biggest problems the surrounding neighborhoods face is the disregard or lack of respect, by many (Note: I didn’t say all) students living in the local community. Yet when the surrounding neighborhood suggests that embedding more students in the neighborhood could have a significant impact on the quality of life, it is the proponents of the 10-year BC plan that refuse to compromise. There is nothing wrong with the university creating a plan that benefits itself in a productive well though out manner, but if it has a negative impact on the surrounding neighborhood then BC cannot be allowed to do as it sees fit.

You mention compromise but time and time again BC has shown very little or lack of compromise with the community. Nobody is suggesting that the former land remain a park for leisure as you or other like to paint, but some sort of compromise (again which BC has shown lack of) needs to be addressed.

And lastly it is in fact a practical stance for BC to explore placing all dorms and athletic facilities on the main campus, and use the former St. John's land as administrative only.