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.
Sincerely,
Michael Pahre
76 Foster Street
Brighton, MA 02135
pahre@comcast.net
617-216-1447