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July 14, 2023


David Mohler, Chair

Boston Region Metropolitan Planning Organization

10 Park Plaza, Suite 4150

Boston, MA 02116



RE: Comments on the Draft Long Range Transportation Plan (“Destination 2050”) for FFY 2024 -27



Dear Mr. Mohler,


We, the Regional Transportation Advisory Council (RTAC) for the Boston Region Metropolitan Planning Organization (MPO), also known as the "Advisory Council," herein offer our comments on the Draft FFY2024-27 Long Range Transportation Plan (LRTP). First, we readily acknowledge that during the development of this LRTP, there was the COVID-19 pandemic with its inherent disruptive effects. Also, there were three separate managers of the LRTP this cycle with the early transition planned far in advance and the later transition occurring within the last year and with much less notice. These transitions, along with a significant and chronic shortage of staff, have understandably made the development of this LRTP more challenging. This comment letter will discuss our thoughts regarding the process of developing the LRTP as well as the observations and conclusions it contains, and when we emphasize any shortcomings, it’s with the hope that we will be partners in the process of overcoming them.



Comments on the Process


First, we commend the staff for doing an outstanding amount of outreach to develop this LRTP. The list of efforts described in Chapter #1 is impressive! Though in some respects the pandemic made outreach easier, it definitely changed the nature of the outreach, and it required nimbleness on the part of the MPO staff.


Regarding the Needs Assessment, though we appreciate that the pandemic-related disruptions and a shortage of staff have allowed for only the release of the summary of needs as presented in Chapter 2, nonetheless,  we have two concerns: (1) the originally-targeted release time is too late in the process of LRTP development to allow the Advisory Council and the MPO Board to fully review the needs and incorporate our own conclusions into the process of selecting projects; and (2) though using StoryMaps will allow for easier updating of the needs, we think it important for the MPO to take an "official" snapshot of the Needs Assessment so that it can serve as a basis of comparison as we attempt to determine the effectiveness of the MPO in meeting its goals. We suggest creating this snapshot by generating a PDF of all nine StoryMaps and compiling them into one document or collection.



Comments on the Observations and Conclusions


In this section we will comment on each chapter of the LRTP and some of the appendices. Our comments will be far from exhaustive, but they will convey a good sense of our thoughts about this iteration of the LRTP.



CHAPTER 1 (Purpose of the Plan)


CHAPTER 2 (Transportation Needs in the Boston Region)


CHAPTER 3 (Planning and Investment Framework)


CHAPTER 4 (Planning and Investment Framework)


CHAPTER FIVE (The Recommended Plan)


CHAPTER SIX (Next Steps: Implementing Destination 2050)



APPENDIX C (Public Engagement and Public Comment)


APPENDIX D (Universe of Projects and Project Evaluations)


APPENDIX G (System Performance Report)


APPENDIX H (Transportation Equity Performance Report)


APPENDIX I (Disparate Impact and Disproportionate Burden Policy)





The conditions caused by the pandemic have presented major difficulties to the region and to all of us as individuals. Nonetheless, a lot of great effort has gone into creating this LRTP. As the Advisory Council to the MPO and a member of the Board, we are heavily involved with making decisions; so, the comments we make are directed at ourselves as much as they are everyone else. We feel that this LRTP would have benefitted from more deliberation by the Advisory Council and the Board on the Needs Assessment before projects were selected. We also would like to have seen more than one build scenario. Therefore, given the shortfalls of the current LTRP as indicated by the DI/DB analysis  and with the clock running out for us to meet the submission deadline, let's commit to reviewing and possibly amending this LTRP by the end of the next FFY in order to make it better plan.




The Advisory Council