June 25, 2014
Clinton Bench, Chair
Boston Region Metropolitan Planning Organization
10 Park Plaza, Suite 2150
Boston, MA 02116
RE: Draft Federal Fiscal Years 2015-18 Transportation
Improvement Program and Draft Federal Fiscal Year 2015 Unified
Planning Work Program
Dear Mr. Bench:
The
Regional Transportation Advisory Council (Advisory Council) is an independent
group of citizen and regional advocacy groups, municipal representatives, and
agencies charged with advising the Boston Region Metropolitan Planning
Organization (MPO) on issues arising out of the federally mandated 3-C transportation
planning process and with serving as a primary mechanism for public input to
the MPO within that process. We have
collectively reviewed and discussed the FFYs 2015-18 Transportation Improvement
Program (TIP) and the FFY15 Unified Planning Work Program (UPWP) currently in
circulation for public review and comment and now offer the following input for
consideration by the members of the MPO and its staff.
The
Advisory Council believes the MPO should take steps each federal fiscal year to
allocate sufficient funding for small and medium sized, local projects. We urge the MPO to make every effort not to
let a very few large projects tie up all available target funding in the TIP
program. The TIP process was set up to allow
for smaller projects that can make highly needed repairs and improvements throughout
the MPO region; we believe this should continue. Allowing just a few large projects to consume all
available target funding (thereby decreasing funding
for local projects) would change the nature of the program significantly and
could discourage widespread interest in the planning process. We accordingly urge the MPO to commit to an
equitable balance between small and large projects.
The
Advisory Council appreciates that MassDOT occasionally fully funds projects
from the Boston Regions TIP program with non-federal aid (NFA). We encourage the MPO to urge MassDOT - when
considering funding projects using NFA - to select projects that have already scored
highly on the MPOs project evaluation list.
Advisory
Council members are concerned about the impact of project cost increases that
routinely occur as projects move through the design process and closer to construction.
Such cost increases significantly disrupt
TIP scheduling, cause delays for other projects and prevent yet others from
being programmed. We urge MassDOT to prioritize
containing such cost increases. We urge the
MPO and MassDOT to better estimate 100% design costs when projects are
initially programmed (even if they may only be at 25% design at the time of their
programming) and whenever scope changes are considered for approval to give
serious consideration to the rippling effects that associated cost increases
could have on TIP funding and scheduling.
More
specifically, the Advisory Council is concerned that the Green Line Extension
Phase 2 project could well have cost increases that could ultimately make the
project unaffordable for the MPO. We
urge all applicable state planners to consider immediately how to fund any cost
increases (over the level currently programmed in the TIP) for this project and
not leave the responsibility for covering any such increases solely within the
MPOs purview. We further suggest that
any savings from the hoped for FTA Full Funding Agreement for the Green Line
Extension Phase 1 could be applied to Phase 2 expenses.
Keeping
projects on schedule will minimize the inflation-related cost increases that
occur when projects are delayed. Accordingly, we encourage the MPO, MassDOT and
affected municipalities to work cooperatively during the design process to
avoid these delays. As a helpful
example, the Accelerated Bridge Program yielded significant cost savings by
moving up reconstruction of important bridges (rather than spreading out to later
years when the same project would have been more costly). We believe more attention to staying on
schedule could similarly save the MPO significant money in the coming years.
The
Advisory Council would like to see more projects programmed that improve freight
mobility within and through the region.
We encourage the MPO to consider how such criteria could be sensibly
added to existing TIP project evaluation ratings.
Members
of the Advisory Council have shared concerns that the cost of police details
for construction projects in our region may be substantially higher than in
other parts of the country which in turn may significantly affect the scope and
number of projects that can be programmed using Target funding. We respectfully request the MPO initiate a
discussion about such costs including if and how such costs might be reduced
over time.
The
Advisory Council is aware that the MPO is currently facing some uncertainty
concerning federal target funding due to widely known concerns about the
solvency of the Highway Trust Fund.
Should reprioritizations regrettably prove necessary as a result of
shortfalls in federal funding, the Advisory Council will
look forward to participating collaboratively in such further deliberations by
the MPO.
The
Advisory Council is pleased with the scope of projects recommended for the FFY2015
UPWP. We especially support studies that
identify project improvements with high likelihood of implementation and those
that actively generate positive interest from the private sector in bringing
such projects to fruition. We are
especially encouraged by the progress of the current Beacham Street Corridor
study and see it as a potential model for further studies in the years ahead.
The
Advisory Council is particularly grateful to the MPO for its continuing support
of Freight Planning Support and for increasing its funding in the current UPWP.
We believe that implementation of the
MPO Freight Action Plan represents both a vital opportunity for economic
development in and throughout the region and an effective approach toward the MPOs
current freight planning needs and accordingly urge additional annual funding
increases in the years ahead.
We
appreciate the opportunity to express our concerns to the MPO and look forward to
working collaboratively with the MPO in the months and years ahead on these and
related issues.
Very truly yours,
David P. Montgomery
Chair
cc: Members of the Boston Region MPO