At its last board meeting in March, the MBTA released its first five-year Capital Investment Plan (CIP) since the COVID-19 pandemic sent the agency scrambling. This marks a significant change from prior CIP cycles, in which the MBTA’s and MassDOT’s projects have been combined together in a single state CIP for all transportation investments. The old CIPs, done by MassDOT on MassDOT’s schedule, made public comment pointless, since the plan had to be approved by the end of June, only a few weeks after it was published in late May, and staff responses to comments would not be published until late summer, when it was too late to have any effect.

What follows is my submission, lightly edited for formatting, to save you the effort of using the public records law to find out what I said (since the MBTA will only publish comments in aggregated form).

I will begin my comments with some general remarks. The timing, structure, and presentation of this CIP are a significant improvement over recent years, and the introduction of information about project phasing in particular is a welcome addition. On the content, however, it is still quite disappointing that the staff evidently decided to “wait the old board out” and make no progress whatever on the electrification of the commuter rail system that was directed by the FMCB. We should, had the Authority not decided to drag its feet, now be seeing significant capital programs for new vehicles, platform upgrades on the Providence and Fairmount lines, and design contracts for electrification on the Fairmount Line and the Eastern Route. None of these are anywhere to be found in this document.

In particular, the Authority was directed to proceed without delay to a pilot of electric multiple unit service on the Providence Line — a line which has six low-platform stations that all must be upgraded to high platforms in order for to support modern rolling stock. In one of the FMCB’s last actions before its termination, the board also published a document describing ways to improve worker productivity and safety, which highlighted, among other issues, the problem of “traps” on the Authority’s existing, obsolete commuter-rail equipment. Nonetheless, senior management has allowed the staff to continue to treat low-level platforms as solely an accessibility issue and not a sine qua non for modernization of the service (and a necessity for purchasing modern off-the-shelf multiple-unit rolling stock).

It is still somewhat difficult to figure out exactly what some of these projects actually are. I would suggest that every project over some threshold dollar value (say, $25 million?) should have a project page on mbta.com and the CIP document should link to project pages whenever they exist so that the public may provide more informed comment.

My comments on individual projects and groups of projects follow, indexed by project ID.

P1108

erroneously categorized as commuter rail. What is the division of responsibility between the MBTA and municipalities for these street improvements? How does this differ from P1113?

P1005a, P1005b

Strongly support these bus priority projects. Center-running bus lanes with dedicated stations are among the most effective investments the MBTA can make for bus passengers.

P0940

Please clarify the locations and time scale involved. The budget seems quite low, based on recent MBTA commuter rail construction projects, so assuming this is a design-only project, there should be other projects within this CIP that would fund the construction — otherwise it’s anything but “early action”.

P0906

You told us in February that you were going to destroy the trolleybus infrastructure. I support the modernization of the North Cambridge trolleybus network as this project proposes, and the replacement of the existing fleet (and expansion of emissions-free service) using extended-range battery trolleybuses similar to those deployed in Dayton, San Francisco, and Seattle. But there’s nothing else in this CIP to suggest that you have even considered that (unsurprising given the lies told by staff at the last public meeting).

P0889

Obviously this project is in progress, but “South Station Expansion” is unnecessary and a waste of money given the significant inefficiencies of the current South Station terminal operation. Fix the operational problems (such as slow clearance of platforms, unreliable diesel locomotives, and low-speed turnouts) before pouring more concrete. (And obviously the North-South Rail Link tunnel should be built and would completely obviate any need for more surface platform capacity at South Station.)

P0869

This was approved by the board more than a year ago. What is holding up the final conveyance?

P0752

Blandin Ave. does not cross the Worcester Line. Is this project actually on the Framingham Secondary, a freight line connecting Framingham and Mansfield?

P0705c

If you’re going to destroy the trolleybus infrastructure, why do you still need a duct bank in front of Mt. Auburn Cemetery? What purpose would it serve?

P0692

One hopes that “capital improvements” includes upgrades to Sharon substation to support electrification of Providence and Fairmount commuter rail.

P0261

Strongly support reconstruction of stations on this line to reduce dwell times and improve passenger safety and accessibility. Unclear to me that restoring a third track for the full length offers significant benefits, because no operational model is specified and it’s not clear how it relates to rail transformation. (A three-track line is not especially useful for frequent, all-day bidirectional service as called for by the previous board — you would need to restore all four tracks for that; Amtrak or FRA grants should pay for it if the only benefit is to infrequent intercity trains.) Support proceeding with the design process so that some of these constraints can be fleshed out in public.

P0214

Support completing this project. The existing project page on mbta.com has not been updated since 2020 and needs to explain where the project is at and what the revised timeline is.

P0206

The “Foxboro Pilot” seems to be dead and probably not coming back, but I guess you’ve already spent most of the money….

P0164

Needs complete description.

P1101, P1010, P1011, P0920, P0921

Strong support.

P1002

Arborway is being replaced by 2027. Why build permanent buildings at the old location now?

P0952

Layover facilities should be located at the ends of the lines; rolling stock should not be stored in Boston.

P0863

Planning for maintenance and layover facilities should ensure that they are capable of handling articulated (non-separable) multiple-unit sets of at least 330 feet in length, to unconstrain choices of future rolling stock. Construction at Readville must accommodate electrification.

P0671, P0671a, P0671b

While recognizing the need for swift action to replace Quincy garage, the cost of $3.35 million per bus is unacceptable, and designs for subsequent bus facility replacements like Arborway must be constrained to a more reasonable amount.

P0671c

Do not support destruction of trolleybus infrastructure — at a time when all major builders can supply extended-range battery trolleybuses — merely to satisfy Vehicle Engineering’s unjustified desire for all buses to be identical. Safety and accessibility in the Harvard bus tunnel require left-hand doors.

P0609

Sorry, what does GLX have to do with something 20 miles away in Billerica?

P0515

Support. This is only item in the CIP that demonstrates recognition of the requirement to electrify commuter rail service.

P1150

Where? For only $10 million, at MBTA costs that’s like one station’s worth of high platform.

P1025

Support. When I visited in 2021, the garage was both nearly empty and visibly in very poor condition. Lynn would do much better with transit-oriented development on this site to take advantage of more frequent regional rail service. In the mean time, the garage needs either to be properly maintained or to be taken down.

P1009

Where?

P0970

Attleboro station requires high-level platforms. $1.2m really ought to be enough, but on the basis of recent projects that’s low by about an order of magnitude.

P0890

Support.

P0761, P0689c

I recall numerous presentations to the previous board about bus stop amenities, and discussions of a new contract for modern shelters. Is this all that’s become of that extensive discussion? Another priority that management has just dropped the ball on?

P0395

Strongly support the completion of this project, which will relieve a significant bottleneck on the Worcester Line.

P0179, P0178, P0174

Support.

P0173

You’re just going to have to go back and put in full-length platforms, which FTA should never have allowed you to leave off this project.

P0170

Strongly support the revised scope of this project with platforms serving both tracks.

P0168, P0129, P0117

Support.

P1152, P0652

No no no no no. Unpowered coaches are generations-obsolete technology and the MBTA should not be planning to still be operating them in 2050, regardless of motive power. To the extent new diesel-hauled equipment is necessary as a result of management’s foot-dragging on electrification, the Authority should be purchaing dual-mode (diesel/electric), single-level, articulated multiple-unit vehicles with a passenger capacity between 250 and 400, with a manufacturer option to remove the diesel prime mover at mid-life overhaul. Such vehicles could be deployed immediately on the Old Colony lines (including South Coast Rail), allowing the 67 obsolete coaches (81 including the SCR order) to be moved to other lines until high-platform and electrification construction has progressed sufficiently. This is sufficient to retire all currently active BTC-1C, BTC-1A, and BTC-3 coaches.

This style and passenger capacity “right-sizes” vehicles for the future all-day bidirectional service, optimizing the use of equipment and personnel by eliminating separate compartments on most trains, improving acceleration, and reducing dwell times, thereby allowing equipment to cycle faster. All major domestic builders offer families of multiple-unit equipment with a variety of power sources, allowing for parts and training commonality and reducing maintenance expense.

I cannot emphasize this enough: there is no “leapfrog” move available here. The MBTA must electrify its commuter rail network, it must do so using standard 25 kV overhead catenary, and it must purchase modern rolling stock and construct uniform high platforms. Additional investment in the current operating model, inherited from the freight railroads 50 years ago, is unacceptable.

The IIJA includes funding programs to support mainline rail electrification, grade crossing elimination, and station accessibility; the MBTA must aggressively pursue these opportunities as they are opened for applications.

P0893

I understand that this contract has already been executed; otherwise the same comments apply as for P1152.

P0653

See my comments above with respect to buses and bus facilities.

P0369

Strong support for the type 10 program and related capital improvements to bring the Green Line closer to industry standard for light rail facilities. This will improve service reliability and reduce operating costs over the lifetime of these vehicles.

P0362

The public deserves more frequent status updates regarding this procurement, quarterly at a minimum.

P0866

Strong support for Red-Blue Connector; continued design should be funded to support applications for discretionary FTA grants.