June 11,
2015
David Mohler, Chair
Boston Region Metropolitan Planning
Organization
10 Park Plaza,
Suite 2150
Boston, MA 02116
RE: Draft Charting Progress
to 2040: Long Range Transportation Plan
Draft Federal Fiscal Years
2016-20 Transportation Improvement Program and Draft Federal Fiscal
Year 2016 Unified Planning Work Program
Dear Mr. Mohler:
The Regional Transportation Advisory Council (Advisory
Council) is pleased to offer comments on the draft long-range transportation
plan, Charting Progress to 2040 (LRTP);
the Federal Fiscal Year (FFY) 2016-2020 Transportation Improvement Program
(TIP); and the FFY 2016 Unified Planning Work Program (UPWP). First, the
Advisory Council recognizes the effort that went into changing focus through
scenario planning. The refocus of the MPO’s efforts which have been dramatic
this year: The TIP changed to a five-year view (to match the LRTP years); the
focus changed from large infrastructure projects to smaller, local projects. It has been a unique year of change.
Long-Range
Transportation Plan
The MPO’s analysis of alternative LRTP scenarios illustrating
different investment emphases was a valuable exercise. The Advisory Council supports adoption of the
MPO’s proposed Operations and Management (O&M) scenario, rather than the
alternative High-Capital Investment Congestion Management Scenario or the
Current-LRTP Scenario. Under the Current
LRTP and High-Cap scenarios, the majority of MPO funding over the next 25 years
would have been programmed to a small number of capital-intensive major
infrastructure projects. Unfortunately,
the funding available to the MPO is insufficient to do justice to the latter. The O&M scenario will instead benefit a
much larger number of projects, and with them, a much larger number of
communities. The emphasis on
intersection improvements, “complete streets” enhancements in combination with
road reconstruction, pedestrian and bicycle infrastructure, and community
transportation programs will provide cost-effective safety, congestion relief,
and mobility benefits throughout the region. It will also help facilitate important goals
for the region and state such as mode shift, greenhouse gas reduction, sustainability,
traffic safety and public health.
The Advisory Council also agrees with designating funding for
general types of these smaller projects, with the specific projects (beyond the
current TIP period) to be selected at a later date. The MPO’s TIP project prioritization process
provides a robust approach to selecting top projects that are ready to go and
have a wide array of benefits. This
process will evolve over time, with the needs and priorities of the
region. Smaller projects need less lead
time for planning and project development. Flexibility in the plan’s funding
direction will accommodate changing factors such as project readiness, funding
sources, and local needs.
While supporting the direction of the LRTP (within the
constraints of available funding and policy), the Advisory Council offers the
following additional points for MPO consideration:
·
With major infrastructure projects no longer funded
through the LRTP (and inadequately funded before), and overall funding limited,
we should all ask where funding for important regional projects – such as
transit expansion and highway safety improvements – will come from? Once the LRTP work is complete, the Advisory
Council urges the MPO to conduct further analysis of scenario(s) with
additional funding beyond the projected LRTP levels, to illustrate the regional
benefits that could be achieved through expanded investment in transportation.
·
Planning for funds under the control of the MPO,
State, and MBTA is currently conducted through separate silos. We believe that the current state of affairs
does not constitute comprehensive or integrated regional planning. We urge the MPO to collaborate more closely with
MassDOT and the contiguous MPOs (including MBTA & RTAS) to develop a
process where priorities for major investments in the Boston region can be
jointly determined.
·
The Advisory Council would like to continue to provide
input as the MPO develops and implements guidelines for directing funding in
the categories identified in the 2021 and beyond timeframes.
Transportation Improvement Program
The proposed FFY 2016-2020 TIP implements the first five
years of the LRTP with specific projects selected based on the MPO’s point
system for regional goals and for project readiness. The Advisory Council believes that the MPO’s
process is sound and that the recommended set of projects is reasonable. We appreciate the emphasis on prioritizing
and selecting projects as objectively as possible using clearly defined
criteria that relate to regional goals.
The Advisory Council observes that the number of deserving
projects far outweighs the available funding. A small number of rating points
separated many of them. The Advisory
Council suggests that the MPO may want to undertake a sensitivity analysis of
its criteria rating point systems, to see how much changes in the weighting and
scoring system (e.g., emphasizing cost-effectiveness vs. total benefits) might
change the outcome of project selection.
The Advisory Council would also like to see the MPO continue to improve
its data and analytical methods to assign ratings based on quantitative
measures of impact and benefit as much as possible – realizing that it is as
much art as science.
Unified
Planning Work Program
We believe the proposed FFY 2016 UPWP includes a good
cross-section of projects that should provide useful planning support to the
region. We welcome including noise
pollution in corridor and environmental justice studies. We suggest that over
time, it may be useful for the MPO to document outcomes of past UPWP projects
to ensure that the studies selected for funding through the UPWP are having a
meaningful impact on transportation outcomes in the Boston region.
Once again, the Advisory Council appreciates the opportunity
to comment on these important planning and programming documents.
Sincerely,
Mike Gowing,
Chairman
Regional Transportation Advisory Council