Sierra Club on South Station ENF

Secretary Richard K. Sullivan

Executive Office of Energy & Environmental Affairs

MEPA Office

Attention:  Holly Johnson – MEPA Analyst

EEA# 15028

100 Cambridge Street, Suite 900

Boston, MA 02114

Dear Secretary Sullivan:

        I am writing on behalf of the Massachusetts Chapter of the Sierra Club in response to the South Station Expansion Project Environmental Notification Form.  While there are some aspects of the pro­posal that we find of merit—most notably, the reopening of the Dorchester Avenue bridge to the public to better link Downtown with South Boston, and the associated rebuilding of the adjacent streetscape and the extension of the Harborwalk along Fort Point Channel—we believe the overall project to be funda­mentally flawed by its basic design assumptions, rendering it incapable of providing a permanent solution to the problem of the Sta­tion’s congestion so long as it remains a stub-end terminal.

        South Station was last expanded in the mid 1990s with the addition of sev­eral tracks and platforms to accommodate new commuter rail services to the South Shore and Worcester.  Nearly two decades later, the Commonwealth is planning to increase yet again the capacity of this busy terminal by taking the South Postal Annex and putting at least seven more tracks on its site (“An $850m plan to return South Station to bygone glory,” 2/23/13 Boston Globe).  At its Public Scoping Session on April 1, MassDOT described the project as “[a] rare chance to remove a major chokepoint and unlock greater regional mobility and growth.”

        Almost completely absent from these plans, however, is any recognition that building yet more dead-end tracks into South Station is a temporary solution, at best, and will likely be eclipsed again in a couple more decades by the anticipated growth in passenger traffic.  Instead, MassDOT should revisit its long-shelved plans for a direct rail connection between South and North Stations—a DEIS for the Rail Link was completed in June 2003 and immediately dropped by the Romney administration—that would al­low for the through running of Amtrak and commuter trains without the wasteful backup moves that are now a major cause of congestion at both terminals.  A first step would be to put the new South Station plat­forms underground, allowing the tracks to be extended north at a later date.

        One of the more disturbing aspects of this project is the plan to build a layover yard to hold and ser­vice the MBTA’s commuter train sets, a location where idling diesel locomotives would spew pollution into the adjacent neighborhoods. After examining 28 sites for this facility, the ENF has narrowed the options to three locations:  the Boston Transportation Department Tow Lot in the city’s Newmarket neighbor­hood, Beacon Park Yard in Allston, and Readville-Yard 2 atBoston’s southernmost point.  Of these, only the Tow Lot location is anywhere close to downtown, meaning that trains may be deadheading back and forth for a distance of up to nine miles each way, showering yet more fumes and particulates on the city’s residents.  At the very least, the MBTA should reconsider its decision several years ago not to electrify its commuter rail lines, which would reduce air pollution along its lines—most particularly around the pro­posed layover facility.

        Additionally, the current plan would fail to provide benefits two other key constituencies: travelers coming from the north via both the commuter rail system and the Downeaster from Maine, and riders on the MBTA’s central subway system.  Running through commuter and Amtrak trains would provide better distribution of passengers coming intoBoston and relieve pressure on our overstressed subway lines, es­pecially on the Orange Line.

        Construction of the North-South Rail Link would serve as a more lasting solution to the capacity con­straints to the addition of more traffic to South (and North) Stations, unifying the city’s two passenger rail systems into a more coherent whole and providing for the more efficient distribution of riders throughout the downtown core—espe­cially if an intermediate station is also built close to the State Street financial district and the adjacent tourist attractions of Faneuil Hall Marketplace and the Freedom Trail.  While state officials have publicly stated that the South Station expansion plan would do nothing to pre­clude the eventual construction of the Rail Link, its $850 million price tag is a most costly temporary “so­lution” that might prevent the underground connection from ever being built.  We can do better than that!


                                                                                                John Kyper, Transportation Chair

                                                                                                Sierra Club, Massachusetts Chapter