The following letter, collaboratively drafted by EMFRC constituents was sent to MassDOT providing comments on the (Draft) Massachusetts Rail Plan.
Mr. Ned Codd, P.E.
Manager of Plan Development
Massachusetts Department of Transportation
10 Park Plaza, Room 4150
Boston, MA 02116
(on line at www.mass.gov/massdot/freightandrailplan.) Public review period September 9th to
a: Facsimile and 1st Class Mail
The MassDOT Massachusetts Freight Plan projects Massachusetts freight volumes to increase 70 percent by 2030 and that “construction of all investment rail projects would increase future [rail] mode share from 6.1% to 7.1% by 2035”. Only a one percent change in share. This is an astounding statistic.
If MassDOT’s assessment is correct, this translates to significantly more truck trips, with uneven distribution of these trips throughout the State. As the largest consuming area, one has to assume that Metro-Boston will see the largest increase in truck trips, further fueled by the current retreat of logistics and distribution centers to mid-state locations.
The Eastern Massachusetts Freight Rail Coalition (EMFRC) is an independent body representing freight transportation interests including shippers, carriers, terminal operators, freight forwarders, municipalities and nonprofit groups in Eastern Massachusetts. Our constituents understand the connection between freight rail and economic development and have been awaiting the release of the Rail Plan for some time. As active participants in the Boston MPO’s Regional Transportation Advisory Council, we provide specific input on approaches to develop balanced transportation systems that would put freight rail on equal footing with other transportation projects.
Our comments herein are largely focused on the freight elements of the Rail Plan. We see untapped opportunity for MassDOT to establish programs and foster policies to unleash the full potential of Commonwealth-owned and privately owned rail assets for both passenger and freight purposes. As a return for their investment as taxpayers, the citizens of the commonwealth deserve continuing benefits of reduced traffic congestion, less pollutants, economic development, job growth and quality of life possible through focused passenger and freight rail initiatives. We believe we can do better than a one percent modal shift in freight to rail.
At the outset, we are concerned about the abbreviated public comment period. Our constituents personally attended the Massachusetts Rail Plan Public Hearing held in Worcester on September 16th. It was not particularly well attended and was the only such public forum. The average citizen will not understand the Plan and likely will never see the Plan. They ultimately will, however, be affected.
More concerning, we did not see an executive summary, implementation plan, implications or conclusions. These sections are necessary to allow planners, legislators, municipalities, business entities and others to quickly understand what the Plan means to them, to the Commonwealth and understand MassDOT’s recommendations. This Plan is purported to lay out a 20 year perspective. With the Commonwealth making significant financial commitments to rail, $100 million for the purchase of CSX lines alone, more outreach is required and clearly more distillation of the material is a necessity for inclusion in the final document.
We commend MassDOT for the depth of the statistical and factual material that describes the current state of the rail infrastructure. Much of this we understand to be mandated by USDOT. However, the Plan, as presented, lacks an overarching transportation vision for the Commonwealth and the steps to achieve that vision. We hoped that reform efforts and creation of the new MassDOT would provide that vision. Unfortunately, we don’t see it at this stage.
Specifically, we were disappointed that the plan overlooked key strategic issues, including:
- Strategies and related infrastructure to promote and integrate freight rail with maritime freight at key ports, particularly Boston and New Bedford.
- Short-sea shipping and rail synergies so as to allow Massachusetts to participate in programs actively being promoted by the USDOT.
- Plans demonstrating how rail assets can accelerate economic development programs. (Other states invest directly in rail for the purpose of attracting jobs.)
- Discussion and 20 year implications of diminished freight rail capacity and related operations into the Boston metropolitan area and its impact on quality of life and cost of goods.
- Strategies to expanded use of state-owned commuter rail lines for both passenger and freight purposes. Historically in the Commonwealth, commuter rail discourages and effectively displaces freight.
- A corridor-specific assessment of expected highway congestion and capacity within I-495, particularly as the national rail carriers rely more heavily on truck drayage for “the last mile” from their centralized intermodal rail terminals in Worcester and Ayer.
- The strategic role of the Commonwealth’s 12 short line railroads as an alternative to extensive truck drays from centralized rail terminals to the urban centers of highest consumption.
- Commitment to establishing an Industrial Rail Access Program (IRAP) and state level industrial zoning overlays urgently needed to preserve and establish economic opportunities for retaining and establishing jobs/industrial and distribution businesses in Massachusetts.
- Public policy implications resulting from the plan’s analysis of the State’s transportation assets and the course of current initiatives.
- An explicit plan for distributing bulk and intermodal freight through all modes and shared assets through and within Massachusetts and New England.
We would like MassDOT to address, in the final Plan, how freight is specifically expected to flow hroughout Eastern Massachusetts. We see the need for economic analysis of the various modal alternatives. This analysis would then enable an assessment of appropriate public policy based on the resulting economics. We will need to plan for this growth or face potential highway gridlock. No meaningful percentage of current truck movements will be converted to rail deliveries without public policy involvement. Increases in rail shipments will most likely come from conversion of truck to intermodal movements – still employing truck delivery for the last mile. We did not see sufficient discussion of the potential strategic role of the Commonwealth’s 12 short line railroads. These local lines can increase localized rail freight delivery if supported by appropriate public policy. The economic tradeoffs and policy options for the “first and last mile” need to be surfaced so as to evaluate how best to reduce the length of the likely “last mile” truck delivery.
Other states have embraced short lines as a critical component in their overall transportation planning and policy making. In fact, the Massachusetts Congressional Delegation has been upportive of federal tax credit legislation to encourage private investment in rail infrastructure for these entities. It is incongruent for MassDOT not to include them more prominently in the Massachusetts State Rail Plan.
Freight rail’s small market share wasn’t caused by the lack of rail infrastructure. We believe freight moved from rail to truck primarily due to the economics and public policy of the past, which then resulted in the rail freight infrastructure being eliminated and the land repurposed.
Policies need to change. Unless the economics of small 20 acre transload facilities inside 128 can compete with large scale facility in Worcester or Ayer, we are forever wed to longer “last mile” truck drays. Class I railroad policies of scale work in other parts of the United States, but Eastern Massachusetts needs a transportation plan and supporting policies that recognize this reality.
We are concerned that the calculation of regional “benefits” for rail projects were not integrated with other elements required to foster economic development -- zoning, non-transportation infrastructure (e. g. sewer/water), workforce, etc. We do not see an approach of evaluating rail projects as an enabler of comprehensive economic development plans. Chapters 7 and 8 were viewed as too qualitative and appeared to be written to support MassDOT‘s current initiatives, rather than a quantitative approach that would objectively affirm the current initiatives or surface new needed initiatives.
We do encourage work on the IRAP program and the Freight-Intensive Land Use Development and Preservation Program. Investment decisions for these programs should not only consider direct rail access but good access to the highway network to the nearest transload location or intermodal terminal.
We see the need for increased legislative involvement on Beacon Hill in evaluating and setting overall Massachusetts’s transportation public policy to support an economic climate for business growth. Local zoning works against the health of the overall region. The impending closing of the Beacon Park rail yard in Allston as the last functional freight rail distribution point within the urban core shows clearly that no one wants infrastructure in their backyard. The reality is that it has to exist to make the region functional and competitive. Continued focus on conversion of industrial land to high end development has stagnated. Other states are broadening their economic reach through transportation and logistics policies that preserves this critical land. The opportunity (and change in distribution patterns) through the Panama Canal widening is real.
While large ships may not dock directly in our ports, short-sea shipping will require more maritime capacity and adjoining rail and logistics staging facilities. We do not see adequate protection of land and facilities for this purpose and efficient connections to the rail network.
As we said at the outset, we believe additional outreach by MassDOT on freight and rail issues is a necessity. We call on Secretary Mullan to establish a senior leadership post within in MassDOT to specifically address freight rail, intermodal and motor carrier issues. It’s too deeply buried within the “Transit” arm of MassDOT to provide sufficient visibility and influence on these critical issues.
We again complement the work you have done to date and look forward to the development of the final Plan.
Executive Director, Eastern Massachusetts Freight Rail Coalition
59 Fountain Street, Suite 301
Framingham, MA 01702
richard.flynn@emfrc.org
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