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December 4, 2020

Secretary Stephanie M. Pollack Department of Transportation 10 Park Plaza
Boston, MA 02116

RE: Forging Ahead Legislative Comments

Joseph Aiello, Chair
MBTA Fiscal and Management Control Board 10 Park Plaza
Boston, MA 02116

Dear Sec. Pollack, Chair Aiello, and members of the MBTA Fiscal and Management Control Board:

We write today to offer comment on MBTA Commuter Rail service changes that have been proposed as part of Forging Ahead. These comments are offered with a recognition that the COVID- 19 pandemic has had unprecedented impacts on ridership and revenues, and that thoughtful policy discussions about how to respond to revenue shortfalls are required. We appreciate the Board’s efforts to center these discussions around the needs of the riding public and applaud the numerous efforts to engage the public for feedback. Prior to the pandemic, constituents from MetroWest communities relied heavily on multiple Commuter Rail lines, including the Framingham/Worcester line, the Franklin line, the Needham line, and the Fitchburg line, and retaining this essential service in both the short and long term is essential.

The following comments are provided with three goals in mind: 1) to fully understand the financial picture and assumptions underlying these discussions and better assess the cost/benefit of proposed service changes; 2) to understand how a rapid return to full service can occur under the proposed scenarios; and 3) to urge the Board to delay any action until these proposals are better understood.

Clarify cost/benefit of proposed changes in both the short- and long-term

The financial and service implications of the various scenarios under consideration, in both the short and long term, remain unclear. Knowing that many costs associated with the Commuter Rail system are fixed in nature, more clarity is needed around where savings will be found, in addition to how these savings might impact fare revenue and other interdependent aspects of the rail system. It would be particularly concerning if workforce reductions factor significantly into expected savings, as this would hinder rapid return to service once ridership resumes. We know that experienced and highly trained staff are essential to rail safety, and training and onboarding new staff would be a lengthy process with the potential to greatly impede return of service. A clearer cost/benefit calculation and associated impacts to service levels must be understood before voting on any changes to ensure we are not pursing a plan that may generate short-term savings, but greatly compromise the future of the system.

Detail return-to-service expectations and assumptions

The proposed service changes have been described as temporary, but there has been little information presented on when service is expected to return and what assumptions have been made in the planning process. Before any service reductions are decided upon, there needs to be a clear presentation of how, and how quickly service can be restored once ridership returns under the scenarios. This presentation needs to include detail on the data and information which serve as the basis for return to service assumptions, particularly information gained directly from the Commonwealth’s employers relative to return to work expectations. A proposal to implement service cuts at a time when a vaccine is imminent raises questions that must be more directly addressed.

Find opportunities to innovate during this time of low ridership

Temporary decreases in ridership related to the pandemic do not diminish the longstanding challenges faced by MetroWest customers and Commuter Rail systemwide. Many of these needs were clearly defined in the Rail Vision process, including ideas for more consumer-friendly approaches to both scheduling and fares. During this time of low ridership, we should take the opportunity to experiment with and measure innovative ridership and fare approaches that could pay dividends in ridership and revenue post-pandemic. We all know that Commuter Rail will continue to play a crucial role in the Massachusetts economy and climate response. While we face short-term funding challenges, this doesn’t preclude opportunities to pilot test limited-cost service delivery innovations and make progress toward the 21st-century transit system envisioned in the Rail Vision process.

Prioritize previously scheduled capital projects for possible federal funding

It is becoming increasingly likely that Congress may approve an infrastructure package that would provide funding to states for transit-related capital improvements. This funding should be used to restore essential projects that will dramatically improve service once ridership returns, including these priorities on the Framingham/Worcester Line:

  • Third Track project: The proposed Third Track project, which is currently in the design stage, should be accelerated to minimize disruption to commuters during this low-ridership period and to increase mitigation options for upcoming major construction projects. This project, which would install an express track between Framingham and I-95, will increase availability of express rush hour trains that will be needed under normal conditions and especially during construction of the Allston Multimodal Project.
  • Increased parking capacity: Parking-related capacity improvements are urgently needed on the Framingham/Worcester line.
  • Improvements to stations: It should be the goal of the MBTA to make all Commuter Rail stations ADA-compliant with high platforms, particularly those already scheduled in Newton and improvements to Worcester Union Station which will allow for more robust and responsive future service.

Account for mitigation of Allston Multimodal Project impacts

As you are aware, planning and engagement is continuing for the upcoming Allston Multimodal Project which is expected to begin construction in 2022. The administration has recognized that mitigation planning for the Allston Multimodal Project is essential, and the Framingham/Worcester line will serve as an important alternative to I-90 during periods of construction-related lane closures. This project must be considered when estimating service requirements and return of ridership on the Framingham/Worcester line specifically. Delay binding FMCB votes until financial needs and short- and long-term impacts are better understood
Given the significant number of questions still outstanding including a recent finding by the MBTA Advisory Board that cuts are unnecessary, and the clear opposition to service reductions shown in the recent MassINC poll, it is premature for the FMCB to take any binding votes on specific service changes at this time. With a vaccine on the immediate horizon, and the likelihood of federal funding increasing, any votes on service changes should be delayed, at a minimum, until 2021.

Thank you for your consideration of these comments. We welcome your ongoing engagement and any questions that you may have and look forward to receiving additional information about this initiative.


Carolyn C. Dykema
State Representative 8th Middlesex District

Denise C. Garlick
State Representative 13th Norfolk District

Carmine L. Gentile
State Representative 13th Middlesex District

Danielle W. Gregoire
State Representative 4th Middlesex District

Kate Hogan
State Representative 3rd Middlesex District

Hannah E. Kane
State Representative 11th Worcester District

Kay Khan
State Representative 11th Middlesex District

Jack P. Lewis
State Representative 7th Middlesex District

David P. Linsky
State Representative 5th Middlesex District

Brian W. Murray
State Representative 10th Worcester District

Alice H. Peisch
State Representative 14th Norfolk District

Maria D. Robinson
State Representative 6th Middlesex District

Jeffrey N. Roy
State Representative 10th Norfolk District

Danillo Sena
State Representative 37th Middlesex District

Michael J. Barrett
State Senator 3rd Middlesex District

Jamie B. Eldridge
State Senator Middlesex & Worcester District

Becca L. Rausch
State Senator Norfolk, Bristol, & Middlesex District

MBTA Fiscal and Management Control Board
Steven Poftak, MBTA General Manager
David Scorey, CEO, Keolis Commuter Services
Rep. William Straus, House Chair, Joint Committee on Transportation Sen. Joseph Boncore, Senate Chair, Joint Committee on Transportation Jonathan Lenicheck, MassDOT
Owen Kane, FMCB
Michael Muller, MBTA
Robert DiAdamo, MBTA

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