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 Milton’s status under M.G.L. Chapter 40A, Section 3A – Multi-family Zoning As-Of-Right in MBTA Communities (the “Act”) – and its classification as a “Rapid transit community” under the Compliance Guidelines for the Act (the “Guidelines”) issued by the Executive Office of Housing and Livable Communities (the “EOHLC”).

It is clear that the Town of Milton is an “MBTA Community” under the Act. However, while Milton is listed as “Rapid transit community” in Appendix 1 to the Guidelines, Milton is not a “Rapid transit community” according to the definitions found in the Guidelines (the “Definitions”).

According to the Definitions, “’Rapid transit community’ 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.”

Also according to the Definitions, “’Subway station’ 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.”

Because the Mattapan Trolley Line stops in Milton are not “along the MBTA Red Line, Green Line, Orange Line, or Blue Line,” Milton is not a “Rapid transit community” 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, MBTA’s Service Delivery Policy, upon which the MBTA’s 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 MBTA’s 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 “Red Line,” “Orange Line,” “Green Line,” “Blue Line,” and “Mattapan Trolley”); see also Copy of https://www.mbta.com/projects/mattapan-line-transformation attached as
Exhibit B (“The historic 1940s Mattapan Line trolley runs on 2.6 miles of track between Ashmont, on the Red Line, and Mattapan Station”); see also MBTA State of the System Report, dated December 2015, attached as Exhibit C, at page 5 (“the term ‘rapid transit’ comprises the MBTA’s heavy rail system (Red, Orange, and Blue Lines), the entire Green Line, and the Mattapan high-speed trolley service”), 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 Line’s 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 (“the Mattapan line is one of two light rail lines that the MBTA operates”;

“While quality and frequency of service are certainly an important part of the riders’ 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 rail”). 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 Milton’s status given the inconsistency in the Guidelines between the Definitions and Appendix 1.