The following is a letter dated September 22, 2023 from Milton Select Board chair Michael Zullas to Chris Kluchman, deputy director of the Executive Office of Housing and Livable Communities. To read Kluchman’s response to Zullas, click here.
We write to seek clarification of the Town Miltonâs status under M.G.L. Chapter 40A, Section 3A – Multi-family Zoning As-Of-Right in MBTA Communities (the âActâ) – and its classification as a âRapid transit communityâ under the Compliance Guidelines for the Act (the âGuidelinesâ) issued by the Executive Office of Housing and Livable Communities (the âEOHLCâ).
It is clear that the Town of Milton is an âMBTA Communityâ under the Act. However, while Milton is listed as âRapid transit communityâ in Appendix 1 to the Guidelines, Milton is not a âRapid transit communityâ according to the definitions found in the Guidelines (the âDefinitionsâ).
According to the Definitions, ââRapid transit communityâ means an MBTA community that has within its borders at least 100 acres of developable station area associated with one or more subway stations, or MBTA Silver Line bus rapid transit stations.â
Also according to the Definitions, ââSubway stationâ means any of the stops along the MBTA Red Line, Green Line, Orange Line, or Blue Line, including any extensions to such lines now under construction and scheduled to begin service before the end of 2023.â
Because the Mattapan Trolley Line stops in Milton are not âalong the MBTA Red Line, Green Line, Orange Line, or Blue Line,â Milton is not a âRapid transit communityâ according to the Guidelines.
It is clear beyond peradventure that the Mattapan Trolley Line is not part of the MBTA Red Line, Green Line, Orange Line, or Blue Line. For example, MBTAâs Service Delivery Policy, upon which the MBTAâs classifications
are based, includes in its rapid transit designation five separate Lines, which are
comprised of heavy rail (Blue, Orange, and Red Lines) and light rail (Green Line and Mattapan Trolley Line).
The MBTAâs literature clearly refers to the Mattapan Trolley Line as a separate Line. See Copy of https://www.mbta.com/schedules/subway attached as Exhibit A (Listing subways as âRed Line,â âOrange Line,â âGreen Line,â âBlue Line,â and âMattapan Trolleyâ); see also Copy of https://www.mbta.com/projects/mattapan-line-transformation attached as
Exhibit B (âThe historic 1940s Mattapan Line trolley runs on 2.6 miles of track between Ashmont, on the Red Line, and Mattapan Stationâ); see also MBTA State of the System Report, dated December 2015, attached as Exhibit C, at page 5 (âthe term ârapid transitâ comprises the MBTAâs heavy rail system (Red, Orange, and Blue Lines), the entire Green Line, and the Mattapan high-speed trolley serviceâ), page 7 (Service Map), page 17 (Rapid Transit Stations), page 22 (Rapid Transit Bridges), page 23 (Track and Traction Power), page 30 (Scheduled Service Frequency), and page 37 (Rapid Transit Fleet).
Recently, in response to our letter seeking clarification of the Mattapan Trolley Lineâs classification, the MBTA reiterated that the Mattapan Trolley Line is a separate Line and not part of the MBTA Red Line, Green Line, Orange Line, or Blue Line. See Letter from Lynsey M. Heffernan, Assistant General Manager for Policy and Transit Planning, Massachusetts Bay Transportation Authority, dated September 8, 2023, attached as Exhibit D (âthe Mattapan line is one of two light rail lines that the MBTA operatesâ;
âWhile quality and frequency of service are certainly an important part of the ridersâ experience and are areas in which the MBTA is seeking to improve, they are not material to the designation of the Mattapan Line as a light railâ). See also Letter from the Milton Select Board to MBTA Board of Directors, dated August 10, 2023, attached as Exhibit E.
The Mattapan Trolley Line is a unicorn that is separate from the MBTA Red Line, Green Line, Orange Line, or Blue Line, is treated as such by the MBTA, and is not addressed in the Guidelines.
In much the same way, Milton is a unicorn for the purposes of, and not addressed in, the Guidelines. As such, we seek clarification of Miltonâs status given the inconsistency in the Guidelines between the Definitions and Appendix 1.
CommonWealth Voices is sponsored by The Boston Foundation.
The Boston Foundation is deeply committed to civic leadership, and essential to our work is the exchange of informed opinions.  We are proud to partner on a platform that engages such a broad range of demographic and ideological viewpoints.