MBTA ROC CIF Subcommittee Submits Commentary on the Boston MPO’s Draft 2017 Triennial Title VI Report

The MBTA ROC Capital Investment & Finance Subcommittee submitted comments to the Boston Region MPO regarding their Draft 2017 Triennial Title VI Report. The commentary is provided in the letter below:

MBTA ROC Subcommittee Submits Commentary on the Boston MPO’s Draft UPWP

The MBTA ROC Capital Investment & Finance Subcommittee submitted comments to the Boston Region MPO regarding their FY 2018 Draft Unified Planning Work Program (UPWP). The commentary is provided in the letter below:

MBTA ROC Subcommittee Submits Comments Regarding the FY 2017-21 CIP

The MBTA ROC Capital Investment & Finance Subcommittee submitted comments to the MBTA regarding the CIP for FY 2017-21. The text is available below, and a pdf of this letter is available here: MBTA ROC CIP Commentary

May 13, 2016

RE: FY2017-21 Capital Investment Plan


To Whom It May Concern,

Below are comments from the Capital Investment & Finance Subcommittee of the MBTA Rider Oversight Committee:

1. The Project Universe spreadsheet is very helpful and very informative. Perhaps another sheet could be added to provide descriptions for some of the columns and programs. Some lines seem to be duplicated, and that is confusing.

2. We would like more transparency into the scores that were given to projects by the Project Selection Advisory Committee

3. Where applicable, we would like to see not only the State of Good Repair scores for selected and unselected projects, but we would like to see the projected changes to those scores as a result of the proposed spending.

4. On page 96, there is a line for “SUB” with a FY17-21 cost of $5M, but there is no associated program

5. Of the selected MBTA projects, they all seem worthy of being chosen. In particular, we are pleased to see that the expansion of GLX from College Station to Rt. 16 remains on the table.


With respect to the projects that were not selected, here are our concerns:

1. Overall, we feel that the lack of spending on the Asset Management Plan will make it difficult, if not impossible, to create and maintain an accurate and effective State of Good Repair database.

2. Though IT has its own section that is separate from the MBTA section, there still seems to be lack of spending on IT projects that would allow the MBTA to effectively mine and analyze the large amounts of data it collects. The MBTA dashboard is a nice addition, but so much more could be done with the data that could create tools that would be helpful to MBTA staff. It would also be good if the MBTA could develop the IT resources that would allow it to more frequently and more effectively survey its riders and the non-riding public in order to assess the MBTA’s effectiveness in providing what the public wants. Related to this notion, we also support the following: (1) Expansion of CTPS Travel Demand Model Territory, (2) Financial System Integration & Upgrade, (3) Digital Scanning Project, (4) MBTA Fuel, Fluids, and Maintenance Management Systems, (5) Next Generation AFC Study, (6) Operations and Maintenance Facilities Needs Evaluation, (7) Parking enforcement payment and technology, (8) Wayfinding, (9) Service Delivery Mgt System, (10) Bus Systems Upgrades

3. Climate Change Adaptation Strategy: Given the close call posed by Superstorm Sandy and the ongoing concerns about rising temperatures and water levels, it is prudent to study how we can make the more susceptible elements of the transit system flood-proof. Those of us who remember the flooding of Kenmore Station by the Muddy River in 1996 remember how severely the Green Line was crippled at that time.

4. Emergency Repair Services, Equipment Resiliency, and Fire Prevention/Sprinkler Repairs seem to be programs that should be funded immediately.

Thanks for your attention to our concerns,
The Capital Investment & Finance Subcommittee of the MBTA Rider Oversight Committee

MBTA ROC Submits Letter Reiterating Late Night Service Mitigation Advice

The MBTA ROC voted to submit a letter to the MBTA reiterating the ROC’s stance regarding late night service mitigation. This letter was submitted within the MBTA’s official late night service mitigation comment period.

The ROC’s stance has not changed, but this letter accepts the reality that late-night service was cancelled. As a result, our focus has turned to promoting a new 24/7 bus-only lifeline network in lieu of late-night service as we previously knew it. Our letter to the MBTA is provided below:

MBTA ROC Submits Letter Asking for Late Night Service Mitigation

The MBTA ROC submitted a letter asking the MBTA to keep the current late-night service running; however, the ROC is also asking the MBTA to consider a new 24/7 bus-only lifeline network if late-night service is terminated. We are deeply concerned for those with limited resources whose daily lives and work patterns require travel during overnight periods, especially those who have inadequate or no other transit options. A 24/7 bus-only lifeline network would ensure that overnight travel remains possible for those who need it. Late-night service should not end until the MBTA finds a way to minimize the impact on these populations.

Our letter to the MBTA is provided below:

MBTA ROC Finds Possible Title VI Violations in Late Night Service Cuts

A few weeks ago it came to our attention that the MBTA is looking to cut late-night service entirely. When the ROC heard about this, we began looking through FTA documentation and discovered that the MBTA would possibly violate FTA Title VI regulations if they cut the service entirely. According to FTA Circular 4702.1B, late-night service was considered a permanent service addition as of March 2015, twelve months after being launched in March of 2014. The ROC believes that, due to these regulations, the MBTA cannot eliminate late-night service without conducting separate disparate impact analyses for each of the affected routes. Also, in eliminating late-night service on certain routes at the end of June 2015, the MBTA may have violated these same FTA regulations.

The MBTA ROC submitted these concerns to the MBTA, MassDOT, the FMCB, and the FTA. We have asked the MBTA to provide a response regarding these concerns by the end of this month. A copy of our letter is provided below:

MBTA ROC Reiterates Support for Five-percent Fare Hikes Every Two Years

It has come to light that the MBTA is considering a 10% fare increase in the coming fiscal year. As a result, the MBTA ROC released a letter reiterating our support for 5% fare hikes every 2 years. During our public outreach prior to the last fare increase, we discovered that a majority of the public was in favor of predictable, moderate fare increases. Also, in our discussions with administrators regarding the 2013 Transportation Finance bill, the 5%-every-2-years rate was agreed to be a reasonable rate.

We are disappointed that the administration would use a technicality to create a situation that violates the trust that the public has with the MBTA regarding fare increases. Government works best when there is a trust between our elected officials, as represented by their appointees, and us, their constituents. There is the letter of the law, and then there is the spirit of the law. We ask that everyone involved in the decisions regarding the 2016 fare increase honor the spirit of the 2013 Transportation Finance legislation and limit fare increases to 5% every 2 years.

Our letter is provided below: