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Page 1 of 2
Hecher'bleikner, Peter
From: Everson, Jeff Deverson@foster-miller.com]
Sent: ' Tuesday, Octobe'r,09, 2007 1:56 PM
To: Reading - Selectmen
Cc:. Carrie Russell
Subject: EVERSON REPSONSE TO THE ENF, AUGUST 31, 2007
Importance:;: °High
Attachments: ENF REPSONSE-EVERSON 1042D.doc; NewlVlresume11_01Vers2.doc
To the Reading Board of Selectmen:
Attached to this email is my response to the Expanded Environmental Notification Form (ENF). In summary, this
response makes the following assertions based on the Feasibility Study Final Report (i.e., issued after 4 years, 45
Task Force meetings and more than $1 M of study money) and the ENF:
(1) Problems due to congestion, rear end accidents and air quality have been transferred to connecting roadways
by the new interchange concepts.
(2) These are valid reasons to believe that computer modeling of interchange designs is incorrect.
(3) The Interchange Task Force (ITF) is incapable of recognizing, addressing and proposing solutions to issues 1-
2 because -almost all members (i.e., nearly 90%) are not technically qualified. ITF membership should have been
heavily weighted on technical qualifications. Problems 1 and 2 above could have been avoided with less time and
money.
(4) The Reading Board of Selectmen (BOS) rejected the concepts presented in the Feasibility Study Final Report.
Further, the BOS suggested that MA DOT "return to the drawing board" and re-address issues related to noise,
visual impacts and eminent domain takings. The MA DOT through the ENF has explicitly ignored BOS
recommendations.
Based on items 1-4 above. I propose the following recommendations:
(1) Expand the current Citizen's Advisory Council (CAC) to include several members with solid technical
credentials in air quality, accident and congestion analysis, as well as expertise in computer modeling of these
three areas.
(2) Invite outside environmental legal expertise to provide oversight during the Environmental Study.
Without resident expertise in the CAC, what is the point of an advisory group where most members "do not have
a clue " on technical and legal issues?
(3) Proceed immediately with my recommendations on the use of electronic countermeasures to manage
congestion along Route 95 (i.e., Reading to Waltham) during the AM peal. period. See Section 4 of the attached
document. These measures may promote a more efficient use of a redesigned interchange and avoid merely
rushing to the next point of congestion.
Regards,
Jeff
Dr. Jeffrey H. Everson
10/9/2007
Page 2 of 2
Principal Investigator, Intelligent Transportation Systems (ITS)
Member: PRESERVE, I-93/I-95 Task Force,
781-944-3632 (home); 781-684-4247 (work); cni4 a.aol.com
PS. I realize you are required by law to avoid communication outside regularly scheduled board meetings and that
there is only one 30 minute window per month to discuss matters outside the board. A fraction of 30 minutes is
not enough time to discuss complicated highway/environmental issues. So, what would you suggest?
10/9/2007
To: Ian Bowles, Secretary,
Executive Office of Energy and Environmental Affairs,
Bob Frey, Manager,
State Wide Planning, Massachusetts Highway Department
Nicholas Zavolas, Analyst,
Office, Massachusetts Environmental Policy Act (MEPA)
Cc. Luisa Paiewonsky, Commissioner
Massachusetts Highway Department
Bradley Jones, State Representative,
12`1' Middlesex District
Patrick Natale, State Representative
13'h Middlesex District
Board of Selectmen,
Reading, Massachusetts
From: Dr. Jeffrey Everson, Member: PRESERVE, I-93/I-95 Interchange Task Force'
Date: October 10, 2007
Subject: Everson Response to the Expanded Environmental Notification Form ENF,
August 31, 2007
1. Introduction
1.1 Background: The Expanded Environmental Notification Form (ENF) is part of the current
Environmental Study that follows a previous Feasibility Study for the proposed redesign of the
I-93/I-95 interchange. This four year Feasibility Study (2003-2007) was supported by nearly 3
dozen members of the Interchange Task Force (ITF) from Reading, Stoneham and Woburn.
Members provided input on impacts related to noise, visual affects and eminent domain takings.
Information on this Feasibility Study and the ENF can be found at www.9395info.com.
My response was prepared based on my professional experience in the field of highway
transportation safety systems. (See attached resume). I am prepared to defend my assertions in
whatever venue is deemed appropriate (i.e., technical or legal). I request a review process that
includes a timely written rebuttal from the Executive Office of Energy and Environmental Affairs
related to this response, followed by a public hearing.
1.2 Major Failure of the Feasibility Study: A major failure of the previous feasibility study was
to confine the study area to a relatively small region in the vicinity of the interchange and to
ignore exacerbating effects created by a redesigned interchange on connecting roadways beyond
the study area. Based on the ENF and the Feasibility Study that preceded it, the current
embodiment of the redesigned I-93/I-95 interchange is expected to have the following frequent
negative impacts on the segments leading away from the interchange along Route 93 to Boston
and along Route 95 to Waltham during the weekday AM peals commuting period:
1. Increased congestion
2. Added stop and go driving (due to #1)
3. More exhaust emissions from stop and go driving (resulting from #2)
1 781-944-3632 (home); 781-684-4247 (work)
5)
4. Degraded air quality along these routes due to increased stop and go driving (caused by
#2)
5. Increased likelihood of rear end accidents (due to #2)
6. More rear end accidents will lead to additional stop and go driving with added exhaust
emissions and degraded air quality.
7. No improvement in overall commuting time from home to office. An alleged "spot
improvement" merely shifts interchange issues (items 1-6 above) to connecting segments.
8. Incidents (i.e., "fender benders") cause additional congestion that could lead to more
exhaust emissions and poor air quality. The relationship between these effects and
incidents due to rear end and run-off-road accidents occurring in the interchange or on
connecting segments were never explicitly addressed by the Feasibility Study
9. Computer modeling of the interchange is incorrect because items 1, 2, 5, and 6 were
ignored. Therefore, the proposed interchange concepts are flawed and should be rejected.
These same issues are likely to plague the return trip through the interchange during the weekday
PM peals period. However, my response will focus on the AM peals period for purposes of
illustration. Sections 2 and 3 provide referenced justification in support of issues 1-9.
1.3 Major Failure of the Feasibility Study and the Interchange Task Force: In the course of
four years of Task Force meetings, members of the Task Force showed that they were incapable
of grasping the significance of the nine issues cited above for the following reasons. Most
members have absolutely no technical background in general,' and only one (i.e., me) has
expertise derived from US DOT contracts in both transportation accident analysis and congestion
mitigation. Further ITF members have no background in air quality and absolutely no civil
engineering qualifications to be assisting the MA DOT in the redesign of anything, not to mention
a major interchange. The ITF did make recommendations regarding impacts due to noise, visual
effects and eminent domain for candidate interchange redesigns. However, the ITF is not
technically qualified to make the connection between such recommendations and impacts on
accidents, congestion and air quality. The MA DOT never provided justification with accessible
references on the use of a "committee of amateurs" to redesign highway infrastructure. It is not
clear that the trivialization of highway design by amateur talent would be legally defensible if the
MA DOT were confionted with a class action suit related to an accident-causing design flaw of a
redesigned interchange, for example.
1.4 Major Failure of the Feasibility Study and the Reading Board of Selectmen (BOS):
During the four years of the Feasibility Study, there were two members of the Reading Board of
Selectmen in attendance at most Task Force meetings. It should be noted that the Reading BOS
rejected the proposed interchange redesign concepts due to insufficient noise reduction,
unmitigated visual disturbances, and a failure by the Executive Office of Transportation (EOT) to
reduce eminent domain takings to zero. The ENF has ignored the BOS decision. One may
justifiably conclude that the BOS wasted their time over the course of 45 Task Force meetings. I
am not aware that the BOS ever publicized their decision on the Feasibility Study. One might ask
why...
My recommendation: either forthrightly address these issues or abandon any major change to
the I-93/I-95 interchange. See my recommendation in Section 4 on addressing issues 1-9.
2 Exceptions to this general observation are Jay Corey, Woburn City Engineer and Jim Gallagher, Senior
Transportation Planner, Metropolitan Area Planning Council. There are 35 Task Force members, 3
qualified technical members and 11 elected officials. Thus, Task Force technical membership = 8.6
political membership = 31.4 technically unqualified membership = 92.4 %
2
Section 2 summarizes certain claims made by the ENF. My rebuttal to these claims is provided in
Section 3. The failings of the proposed interchange design might be mitigated by means of
electronic countermeasures to regulate the flow of vehicles onto Route 95 from Routes 3 and 2
during the AM peak period. This subject is discussed in Section 4. The Appendix poses clarifying
questions on air quality issues.
2. ENF Claims
This section summarizes certain claims asserted by the ENF. These are alleged interchange
efficiency and air quality. My rebuttal does not address issues related to land or water,
2.1 Claim No. 1: "...Analvsis with a CORSIM micro simulation model of the area indicates
that traffic operations would be substantially improved and delays would be reduced. With
reduced delays, the interchange would process more vehicles, which would have travel time
benefits for many drivers, and would shorten the period of maximum congestion in the area. With
fewer drivers seeking alternate routes to avoid the original congestion, traffic on local streets used
as "cut-throughs" (cited as a significant problem by the local communities) would be reduced as
well. Although Route 128 and I-93 would continue to operate near capacity downstream from the
interchange, svstem-wide travel and mobility are improved throughout the region."'
2.2 Claim No. 2: The ENF claims that project will not meet or exceed any review thresholds
related to air quality (see 301 CMR 11.03). It is further claiined that the project will not require
any state permits related to air quality, a
3. Rebuttal to ENF Claims
My rebuttal to the above claims is given below.
3.1 Rebuttal to Claim No. 1
3.1.1 "...Analysis with a CORSIM micro simulation model of the area indicates that traffic,
operations would be substantially improved and delays would be reduced:"
The program CORSIM is based on the Highway Capacity Manual (HCM), 2000 edition. "The
HCM does not take into account or apply to the influence of downstream blockages or queuing on
a segment without modification by the analyst." 3 Further, the HCM does not address demand
conditions in excess of capacity (op. cit. 3). There is nothing in the I-93/I-95 Interchange
Feasibility Study to indicate that the down stream blockage due to peals period bottlenecks, or
downstream demands in excess of capacity in the same time period, were ever explicitly
considered in the use of the traffic simulation, CORSIM. 4 . The EOT has made every effort to
ignore downstream affects during the past four years. Therefore, one may justifiably conclude
that the results of CORSIM are incorrect.
Conclusion: There is no reason to believe that claim 3. 1.1 is true and should be rejected
until credible, verifiable evidence is made available.
3.1.2 "...systemwide travel and mobilitv are improved throughout the region."
"A freeway bottleneck is the critical point of congestion with queues upstream and freely
flowing traffic downstream. Recurring bottlenecks (those not caused by atypical conditions such
as incidents) can occur for manv reasons. including high volumes of entering and merging traffic.
lane drops between ramps or at off ramps, heavy weaving sections, horizontal or vertical curves,
and long upgrades. Proper identification of freeway bottlenecks and their causes is the key to
formulating plans for reducing congestion.i5
Thousands of commuters know that Routes 95 to Waltham and 93 to Boston from the interchange
suffer from constant recurring bottlenecks during the AM peals period. An interchange with
improved flow properties would only add more vehicles to these routes that are already at or near
capacity. The ENF admitted that these routes have limited capacity, if any.
• Conclusion: There is no reason to believe that claim 3.1.2 is true and should be rejected
until credible, verifiable evidence is made available.
3.2 Rebuttal to Claim No. 2
3.2.1 "The hroiect will not meet or exceed anv review thresholds related to air cuality and the
nroiect will not require anv state hermits related to air aualitv."
"Studies link congested stop-and-go driving to sharp increases in emissions of carbon monoxide,
dioxide, hydrocarbons and particulates from heavy- and light- duty trucks, as well as from cars.
Cars and diesel trucks are much less fuel efficient and much worse pollution generators in
congested stop-and-go driving than in free-flowing traffic at moderate speeds." 6
Accidents that occur along roadways connecting the interchange will lead to more stop and go
driving in addition to that, which already exists. The extent of this congestion build up depends
on the length of time needed to remove vehicles involved in an incident and time for the
congestion to dissipate. Since the current interchange redesign concept will create additional stop
and go driving on connecting segments, there will be an increased likelihood of rear end accidents
on them. This increase in rear end accidents is due to the following reason. Rear end crashes
occur primarily under conditions of clear weather and on dry, straight pavements. During 77
percent of the time, they result when the lead vehicle (i.e., the driver in front of you) is stopped.
The primary causal factor is inattention to the driving task. These statements are found in the
reference given below. It is a US DOT report where I am a co-author.' Note that the key issue is
"When the driver in front of you is stopped, albeit momentarily." Therefore, increased stop and
go driving conditions will correlate with increased rear end accidents.
A redesigned interchange that promotes increased traffic flow through it will (1) contribute to the
downstream bottleneck, (2) more stop-and-go driving, (3) more rear end accidents, (4) additional
exhaust emissions and (5) additional degraded air quality beyond what would normally be present
based on the current interchange design.
• Conclusion: There is no reason to believe that claim 3.2.1 is true and should be rejected
until credible, verifiable evidence is made available.
4 ~
4. Improving Air Quality, Mitigating Bottlenecks, and Reducing Rear End
Accidents
Traffic congestion during the peals period on roadway links connecting the interchange cannot be
ignored because it will affect the interchange level of service (LOS). The redesigned interchange
concept H3 (i.e., a fully directional flyover type) and the link between the interchange along
Route 128 and Waltham during the weekday peal, AM period are used as an example (i.e. my
daily commute):
By itself, interchange redesign concept (H3) promotes an efficient flow of vehicles through the
interchange because the weaving segments are eliminated (i.e., improved level LOS). I raised this
point at a recent Task Force meeting. No one disagreed. However, concept H3 incurs a penalty
per the discussion below.
Vehicles traveling through this improved LOS facility will encounter frequent congestion [LOS
(F)] along Route 128 to Waltham during the weekday peak AM period. This weekday peak AM
congestion along Route 128 will impede the flow of vehicles from the interchange such that
congestion will flow back toward the interchange. (The same affect will occur during the
weekday AM peak period for Route 93 heading south to Boston. I've traveled this route many
times on my way to Logan airport during the peak AM period).
My recommendation: The LOS potential of concept H3 could be approached and air quality
improved by slowing congestion build up along Route 95 during the peals AM period by
regulating traffic flow onto Route 95 from Routes 3, 2 and 2A using ramp metering and/or
adaptive speed control on these three roads. There are many precedents for this approach. 8 9 to
The cost for this electronic augmentation is expected to be minor relative to the construction
expense of a redesigned interchange. The efficacy of this electronic countermeasure approach
could be computer simulated with and without a redesigned interchange. If found worthy, a pilot
test with traffic sensors, computers and controlling algorithms could be conducted at first without
a redesigned interchange to actually measure the effect of controlling traffic entering Route 95
during the AM peak period. This first step should be undertaken to improve air quality at the very
least. No eminent domain takings would be necessary. There would be no draconian flyovers
causing visual blight of the landscape. Traffic noise impacts could be measured as a function of
traffic flow (i.e., versus LOS). This approach may also lead to improved roadway safety and
reduced home-to-office commuting time.
Appendix:
Questions (Q) on Air Quality
The questions below are not meant to be regarded as an arbitrary "hoop jurnping" exercise. The
point of the matter is that 375,000 vehicles (EOT count) traverse the I-93/1-95 interchange daily.
That many vehicles, frequently found in stop-and-go driving, could contribute massive exhaust
emissions and substandard air quality, both for drivers, passengers and local inhabitants. For
example, "An average vehicle emits aDDroximately 3.8 tons of CO,, into the atmosphere Der vear.
COz accounts for more than 956/o of total GHG emissions from motor vehicles." 11. The process
that led to Claim No. 2 (Section 2.2) needs considerable clarification and justification in order to
be credible, and legally defensible.
5
0
Claim 2 stated that project will not meet or exceed any review thresholds related to air quality.
Q1. How was this claim determined for highways connecting the interchange (e.g., Route 93
south to Boston and Route 95 to Waltham)? Would you please send me your justification
documentation.
Q2. What are federal and state air quality requirements for these highways?
Q3. How do you measure vehicular exhaust emission pollutants, such carbon monoxide, carbon
dioxide, NO,,, SO,,, particulate matter (PM) and volatile organic compounds (VOC)?" How
accurate is your measurement instrumentation? What are the calibration requirements?
Q4. Are you able to distinguish exhaust emissions from automobiles versus trucks, as well as
spark ignition versus diesel engines? Please explain how you would proceed with this
differentiation.
Q5. Are you able to account for exhaust emissions due to seasonal variations? Please explain how
you would treat this issue.
Q6. Are you able to computer simulate variations in exhaust emissions based on different
highway geometries and different percentages of vehicles versus trucks? Please explain how..
Q7. Have you published technical reports on issues related to questions 1-6? I would appreciate
copies. For example, current and previous contracts come to mind, as well as publications that
appear in the annual Transportation Research Board (TRB) meeting.
Q8. Has the Massachusetts Department of Transportation and/or its contractors ever been
subjected to legal action on air quality issues? Please cite cases and summarize results.
References
1 ENF August 31, 2007, page 4/19, 3`a paragraph
2 ENF op. cit., page 16/19
3 Appendix A, Limitations of the Highway Capacity Manual, Table 12, Federal Highway Administration,
}httu://ops.fbwa.dot.pov/traflicanalvsistools/tat vol2/sectaup a.htm
4 I-93/I-95 Interchange Transportation Study, Final Report - June 2007
"Low-Cost Improvements for Recurring Freeway Bottlenecks," NCHRP 03-83 [Active],
http://www.trb.org/TRBNet/ProjectDisplay.asp?ProjectED=839
6 "What About Air Quality? Thoughts from WSDOT on Air Quality Concerns and Transportation,"
httD://www.wsdot.wa.Qov/Dublications/folio/AirOualitv.Ddf
7 Hendricks, D., Allen, J., Tijerina, L., Everson, J:, Knipling, R., Wilson, C., WNTSC IVHS Program
Topical Report No. 1: Rear-End Crashes," Final Report, Omni Task RA1039-Intelligent Vehicle/Highway
Systems (IVHS) Program (Contract No. DTRS-57-89-D-00086) Final Report, July 1992.
8 M25 Controlled Motorway, httD://www.hiahwavs.aov.uldlmowledae/14334.aSDX
6 I~
9 Variable Speed Limits. htto://safetv.fhwa.dot.eov/speed manaee/docs/warren vsl.nbt#1
10 Controlled Motorways,llttn:Usafetv.fhwa.dot.eov/speed manaee/docs/novntonl.odf
" Transports Quebec, Exhaust Emissions,
httD://www.mto.eouv.oc.ca/nortal/> aee/portal/ministere en/ministere/envi onnement/chaneements climati
aues/transport chaneements climatiaueshm echannement
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Reading Economic Development
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