Public comment letters and responses
Massachusetts Port Authority · from Massport · 216 pages · 30.3 MB
open the file ↗ · original at the source ↗
Boston Logan International Airport 2023/2024 EDR B
B. Comment Letters and
Responses to Comments
The Secretary received comment letters on the 2022 ESPR from the following agencies, organizations,
and public commenters. Massport has provided responses to the comments raised, following each
comment letter.
1. Massachusetts Department of Energy Resources ....................................................................... B-2
2. City of Boston ........................................................................................................................................ B-14
3. Town of Milton ..................................................................................................................................... B-54
4. Airport Impact Relief, Inc. (AIR, Inc.) ............................................................................................B-105
5. BlueSkies Advocates ......................................................................................................................... B-203
6. Conservation Law Foundation (CLF) ........................................................................................... B-207
7. Massport Community Advisory Committee .............................................................................. B-231
8. Mothers Out Front ............................................................................................................................ B-240
9. Christopher Eliot, PhD ..................................................................................................................... B-243
10. Aubrey Harnett .................................................................................................................................. B-250
11. Regina Marchi .................................................................................................................................... B-253
12. Amy McCoy ......................................................................................................................................... B-257
13. Gail Miller ............................................................................................................................................. B-266
14. Donna Reilly ........................................................................................................................................ B-269
15. Fred Salvucci ....................................................................................................................................... B-274
16. Nancy Timmerman ........................................................................................................................... B-286
Comment Letters and Responses to Comments B- 1
B Boston Logan International Airport 2023/2024 EDR
1. Massachusetts Department of Energy Resources Comment Letters and Responses to Comments B-2
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF
ENERGY AND ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENERGY RESOURCES
100 CAMBRIDGE ST., SUITE 1020
BOSTON, MA 02114
Telephone: 617-626-7300
Facsimile: 617-727-0030
Maura Healey
Governor
Kim Driscoll
Lt. Governor
Rebecca Tepper
Secretary
Elizabeth Mahony
Commissioner
17 October 2024
Rebecca Tepper, Secretary
Executive Office of Energy & Environmental Affairs
100 Cambridge Street
Boston, Massachusetts 02114
Attn: MEPA Unit
RE: 2022 Environmental Status and Planning Report, Boston Logan International Airport,
Boston EEA #3247
cc: Jo Ann Bodemer, Director of Energy Efficiency, Department of Energy Resources
Elizabeth Mahony, Commissioner, Department of Energy Resources
Dear Secretary Tepper:
We’ve reviewed the Environmental Status and Planning Report (ESPR) for 2022 (published May
2024) for Boston Logan International Airport. Environmental Status and Planning Reports
(ESPRs), filed periodically, complement Environmental Data Reports (EDRs), filed annually.
Many of the recommendations presented below were also contained in our 31 January 2023
comments on the most recent EDR.
The scope of our review and recommendation is limited to decarbonization and emissions
reduction of Logan ’ s buildings and power plant.
Executive Summary
It ’ s recommended that Logan upgrade its new building standards to mandate the Specialized Code
with electrification. For existing building renovations, mandate low air infiltration and ventilation
energy recovery when renovating. Finally, reassess central plant heating utilization based on fossil
fuel elimination strategy described herein.
2022 Environmental Status and Planning Report, Logan International Airport, EEA #3247
Boston, Massachusetts
Recommendations
x New building design standards should be updated to mandate conformance with the all-
electric pathway of the Massachusetts Specialized Opt-in Code. The ESPR states that both
electrification and meeting the Opt-in are only “ encouraged ” . This is out of step with
current decarbonization state of practice now routinely being delivered across the
Commonwealth. Committing to this standard would greatly advance the building
component of Massport ’ s stated goal of net zero. The Specialized Opt-in Code, which
results in unprecedented building decarbonization, is already mandatory in Boston and
in more than 40 other communities . In almost all cases, building projects choose the all-
electric pathway of this code. New buildings are now routinely built to this standard across
Massachusetts. Massport should elevate the all-electric pathway of the Opt-in from being
just “ encouraged ” to mandatory.
x For existing building renovations, Massport should mandate the following as part of the
renovation:
o Air infiltration and ventilation energy recovery standards of the Massachusetts
Stretch Code.
o If the scope of the project includes replacement of punched windows, conformance
to Stretch Code fenestration standards and thermal bridge mitigation of the
fenestration/exterior wall intersection.
o Or, alternatively to above two sub-bullets, meet the Enerphit standard.
x Commit to no new fossil fuel boilers (or furnaces) for space heating and create a
decommissioning plan for existing fossil fuel boilers and furnaces, if any.
x Commit to no new fossil fuel water heating and create a decommissioning plan for existing
fossil fuel water heating, if any.
x Develop and commit to a decarbonization plan for the central heating and power plant to
transition off fossil fuels based on the following approach:
o Minimize electric power production to lowest possible level (preferably eliminating
power production) and reassess amount of recovered heat using the following
process:
Assess whether ongoing power production is necessary;
Assess whether power equipment can be reduced to emergency backup
only, with no regular production;
Reduce regular electric power production to zero, if possible;
If regular power production is necessary, assess the quantity of recoverable
heat than can be captured based on the lowest possible level of power
production (e.g. “ recovered heat ” );
Ideally, recovered heat will be zero based on being able to eliminate power
production, and thus fossil fuels.
1-2
1-1
1-3
1-4
1-5
1-6
1-10
1-11
1-12
1-9 Comment Letters and Responses to Comments B-3
2022 Environmental Status and Planning Report, Logan International Airport, EEA #3247
Boston, Massachusetts
o Assess the maximum heating output feasible using new central heating plant based
on electric heat pumps sourced from air, ground, and/or Boston Harbor (e.g. “ heat
pump heat ” ). This value will be based on available space and, in the case of Boston
Harbor source, environmental and water access constraints.
Heat production should be from electric heat pumps and no electric
resistance should be used.
o Estimate total available for building space heating as: recovered heat + heat pump
heat
In the likely circumstance that this total is less than the heat currently
recovered from the heating plant, quantify the difference and undertake a
program to reduce central plant heating use to meet this total by swapping
central plant heating with in-building heat pump retrofits.
In the circumstance that this total is more, downsize air- water- Boston
Harbor- source heat pump plant to meet the need.
o Assess option of eliminating central plant heating by converting all building heating
to in-building heat pumps.
Sincerely,
Paul F. Ormond, P.E.
Energy Efficiency Engineer
Massachusetts Department of Energy Resources
1-8
1-13
1-7 Comment Letters and Responses to Comments B-4
Boston Logan International Airport 2023/2024 EDR B
Massachusetts Department of Energy Resources Comment Responses
1-1: Air Quality/Emissions Reduction (GHG)
New building design standards should be updated to mandate conformance with the all-electric
pathway of the Massachusetts Specialized Opt-in Code.
As discussed above and in Comment A-69 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has established a new benchmark for sustainable development as part of its
Roadmap Net Zero by 2031 program in response to Department of Energy Resources (DOER)’s
comment letter. While the adoption of the Massachusetts Specialized Opt-in Code with the All-Electric
Pathway is still optional for municipalities, Massport will meet the same standards and achieve the
same outcomes as this will be integral to achieving the Roadmap Net Zero by 2031 Program’s goals.
Additionally, the recently updated Massport Sustainable Design Guidelines (SDGs) are based on the
latest and most stringent building energy codes in the Commonwealth of Massachusetts along with
reputable third-party sustainability rating systems. Depending on the project type and construction
cost, the SDGs also require projects to pursue or achieve Gold level certification under the U.S. Green
Building Council™ Leadership in Energy and Environmental Design (LEED®) rating system, Green
Business Certification Inc.™ ParkSmart® rating system, and the Institute for Sustainable Infrastructure™
Envision® rating system. Given Massport's internal directives and the mandated SDGs, projects built on
Massport property are already required, when feasible, to meet more stringent standards than the
state's baseline codes, including the Massachusetts Specialized Opt-in Code with the All-Electric
Pathway option.
For more information on Massport’s on-going initiatives and investments to achieve Net Zero GHG
emissions for its Scope 1 and Scope 2 sources by 2031 refer to Chapter 11, Sustainability and
Climate Resilience . The SDG requirements are summarized in Section 11.1.2.1 of Chapter 11 and the
full publication is available at https://www.massport.com/environment/sustainability/sustainable-
design-and-construction .
1-2: Air Quality/Emissions Reduction (GHG)
Massport should elevate the all-electric pathway of the Opt-in from being just encouraged to
mandatory.
As discussed above in Comment 1-1 and in Comment A-69 in Appendix A, MEPA Certificate and
Responses to Comments , Massport has established a new benchmark for sustainable development as
part of its Roadmap Net Zero by 2031 program in response to DOER’s comment letter. This standard is
based on the latest and most stringent building energy codes in the Commonwealth of Massachusetts,
along with reputable third-party sustainability rating systems. Given Massport's internal directives and
the mandated SDGs, projects built on Massport property are already required, when feasible, to meet
more stringent standards than the state's baseline codes, including the Massachusetts Specialized Opt- Comment Letters and Response to Comments B-5
B Boston Logan International Airport 2023/2024 EDR
in Code with the All-Electric Pathway option. However, Massport will still encourage projects with
vertical components to follow the current version of the Massachusetts Stretch Energy and Municipal
Opt-In Specialized Building Code. Of the three compliance pathways available, projects are encouraged
to follow the "All Electric" pathway.
For more information on Massport’s on-going initiatives and investments to achieve Net Zero GHG
emissions for its Scope 1 and Scope 2 sources by 2031 refer to Chapter 11, Sustainability and
Climate Resilience . The SDG requirements are summarized in Section 11.1.2.1 of Chapter 11 and the
full publication is available at https://www.massport.com/environment/sustainability/sustainable-
design-and-construction .
1-3: Air Quality/Emissions Reduction (GHG)
For existing building renovations, Massport should mandate the following as part of the renovation:
• Air infiltration and ventilation energy recovery standards of the Massachusetts Stretch Code.
• If the scope of the project includes replacement of punched windows, conformance to
Stretch Code fenestration standards and thermal bridge mitigation of the
fenestration/exterior wall intersection.
As discussed above in Comment 1-1, Massport has recently updated Massport Sustainable Design
Guidelines (SDGs), which are based on the latest and most stringent building energy codes in the
Commonwealth of Massachusetts along with reputable third-party sustainability rating systems. Section
C: Technology and Structure Design Guidelines, Measure 4, Heating, Ventilation, And Air Conditioning
(HVAC) Systems – Occupied requires “one or more of the following energy-efficient mechanical systems
has been installed in equipment serving the occupied spaces: geothermal heat pumps (GHP), air source
heat pumps (ASHP), variable-frequency drive (VFD), variable refrigerant flow (VRF), heat recovery
ventilation/energy recovery ventilation (HRV/ERV).”
The SDGs further stipulate that, “In alignment with the Massachusetts State Building Code and Stretch
Energy Code, achieve enhanced insulation levels across all building components and include high-
performance windows with low U-values and appropriate solar heat gain coefficient (SHGC) values to
maximize energy efficiency and comfort. Mitigate thermal bridging by implementing a continuous
thermal insulation barrier and by using thermal break materials at window and door frames, structural
framing that crosses the thermal envelope, and slab edges. Apply air sealing to all joints, seams, and
penetrations. Conduct building leakage testing to ensure results are less than 0.35 cfm/sf @75 Pa.
Install reflective roofing materials to deflect heat and reduce cooling loads.”
The SDG requirements are summarized in Section 11.1.2.1 of Chapter 11 and the full publication is
available at https://www.massport.com/environment/sustainability/sustainable-design-and-
construction . Comment Letters and Response to Comments B-6
Boston Logan International Airport 2023/2024 EDR B
1-4: Air Quality/Emissions Reduction (GHG)
Commit to no new fossil fuel boilers (or furnaces) for space heating, and create a decommissioning
plan for existing fossil fuel boilers and furnaces, if any.
Massport has recently updated the SDGs, as discussed above in Comment 1-1, which are based on the
latest and most stringent building energy codes in the Commonwealth of Massachusetts along with
reputable third-party sustainability rating systems. The SDG requirements are summarized in Section
11.1.2.1 of Chapter 11 and the full publication is available at
https://www.massport.com/environment/sustainability/sustainable-design-and-construction .
In Section 5.2, Additional Vertical Project Guidelines , the SDGs state that, “On a project-by-project basis,
Project Teams shall evaluate the available power capacity needed to provide new, fully electric systems
and equipment. All existing systems and equipment running on fossil fuels should be evaluated to
determine the end of their useful service life. If fossil fuel equipment is identified within the project
boundary and has less than three years of service life remaining, this equipment should consider
replacement with electric-powered or clean fuel alternatives.”
In addition, the SDGs’ Attachment B, Sustainability Guidelines Compliance Checklist provides direction
on completing an inventory of such equipment and documenting remaining service life estimates, and
stipulates that fossil fuel systems and equipment with less than three years remaining service life must
be replaced with electric-powered alternatives.
1-5: Air Quality/Emissions Reduction (GHG)
Commit to no new fossil fuel water heating, and create a decommissioning plan for existing fossil
fuel water heating, if any.
The recently updated SDGs, as discussed above in Comment 1-4, require project teams to evaluate the
feasibility of installing new, fully electric systems and equipment in new buildings and renovations.
Existing systems and equipment running on fossil fuels identified as having less than three years of
service life remaining will be considered for replacement with electric-powered or clean fuel
alternatives. This would include water heating equipment. In addition, the SDGs’ Attachment B,
Sustainability Guidelines Compliance Checklist provides direction on completing an inventory of such
equipment and documenting remaining service life estimates. Attachment A in the SDGs further
mandates that project design considerations must also include options for low-temperature hot water
for building hydronic systems and hydronic heat recovery. For more information, refer to Section
11.1.2.1 of Chapter 11, and the full SDG publication available at:
https://www.massport.com/environment/sustainability/sustainable-design-and-construction .
1-6: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: minimize electric power production to lowest Comment Letters and Response to Comments B-7
B Boston Logan International Airport 2023/2024 EDR
possible level (preferably eliminating power production), and reassess amount of recovered heat
using the following process:
• assess whether ongoing power production is necessary;
• assess whether power equipment are reduced to emergency backup only, with no regular
production;
• reduce regular electric power production to zero, if possible;
• if regular power production is necessary, assess the quantity of recoverable heat than are
captured based on the lowest possible level of power production (e.g. “recovered heat”);
• ideally, recovered heat will be zero based on being able to eliminate power production, and
thus fossil fuels.
Massport appreciates the suggestion regarding a recommended approach for decarbonizing Logan
Airport’s Central Heating and Power (CHP) Plant. Massport will consider how to integrate this approach
into its planning and assessments regarding the feasibility of possible CHP alternatives or retrofits as
part of implementing the Roadmap Net Zero by 203 1 Program.
Massport remains dedicated to achieving its Net Zero goals and will continue to explore innovative
approaches to decarbonization. This includes assessing the feasibility of minimizing electric power
production and transitioning to alternative energy sources. Additionally, Massport will evaluate the
necessity of on-going power production and explore the potential to reduce operations to emergency
backup only. However, these evaluations will also consider operational continuity, current aviation
safety regulations, and facility energy requirements before making a final determination on the
feasibility of this approach.
1-7: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: assess the maximum heating output feasible using
new central heating plant based on electric heat pumps sourced from air, ground, and/or Boston
Harbor (e.g. “heat pump heat”). This value will be based on available space and, in the case of a
Boston Harbor source, environmental and water access constraints. Heat production should be from
electric heat pumps, and no electric resistance should be used.
Massport acknowledges the importance of transitioning to sustainable heating solutions as part of
achieving its Net Zero goals and appreciates this suggestion regarding the use of electric heat pumps
that employ diverse technologies and heat sources. Massport is committed to exploring innovative
technologies and will consider the feasibility of implementing electric heat pumps sourced from air,
ground, or Boston Harbor, taking into account available space, environmental constraints, operational
continuity, current aviation safety regulations, and facility energy requirements. Comment Letters and Response to Comments B-8
Boston Logan International Airport 2023/2024 EDR B
1-8: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: estimate total available for building space heating
as: recovered heat + heat pump heat. In the likely circumstance that this total is less than the heat
currently recovered from the heating plant, quantify the difference and undertake a program to
reduce central plant heating use to meet this total by swapping central plant heating with in-
building heat pump retrofits. In the circumstance that this total is more, downsize air- water- Boston
Harbor- source heat pump plant to meet the need.
Massport acknowledges the importance of transitioning to sustainable heating solutions as part of
achieving its Net Zero goals and appreciates this suggestion regarding the use of electric heat pumps
employing diverse technologies and heat sources. Massport is committed to exploring innovative
technologies and will consider the feasibility of implementing electric heat pumps sourced from air,
ground, or Boston Harbor, taking into account available space, environmental constraints, operational
continuity, current aviation safety regulations, and facility energy requirements.
Massport is governed by a Board of Directors, which periodically receives updates from the Office of
the CEO regarding the Roadmap to Net Zero by 2031 (Roadmap to Net Zero) and approves related
funding allocations. As discussed in Section 11.2.1 of Chapter 11 , Sustainability and Climate
Resilience , in 2023, the Board of Directors voted to approve $500 million in investments to Net Zero
projects, laying the groundwork for future reductions. This funding supplements routine funding
requests that incorporate the Roadmap to Net Zero. Massport has committed to achieving Net Zero
GHG emissions for its Scope 1 and Scope 2 sources by 2031 and absolute Net Zero GHG emissions
across these scopes, without relying on renewable energy credits (RECs) or carbon offsets, by 2040.
1-9: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: minimize electric power production to lowest
possible level (preferably eliminating power production), and reassess amount of recovered heat
using the following process: assess whether ongoing power production is necessary.
As discussed above and in Comment A-69 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has established a new benchmark for sustainable development as part of its
Roadmap Net Zero by 203 1 program in response to DOER’s comment letter. This standard is based on
the latest and most stringent building energy codes in the Commonwealth of Massachusetts, along
with reputable third-party sustainability rating systems. For more information on Massport’s on-going
initiatives and investments to achieve Net Zero GHG emissions for its Scope 1 and Scope 2 sources by
2031 refer to Section 11.2 of Chapter 11, Sustainability and Climate Resilience . Comment Letters and Response to Comments B-9
B Boston Logan International Airport 2023/2024 EDR
1-10: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: minimize electric power production to lowest
possible level (preferably eliminating power production), and reassess amount of recovered heat
using the following process: assess whether power equipment are reduced to emergency backup
only, with no regular production.
As discussed above and in Comment A-69 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has established a new benchmark for sustainable development as part of its
Roadmap Net Zero by 203 1 program in response to DOER’s comment letter. This standard is based on
the latest and most stringent building energy codes in the Commonwealth of Massachusetts, along
with reputable third-party sustainability rating systems. For more information on Massport’s on-going
initiatives and investments to achieve Net Zero GHG emissions for its Scope 1 and Scope 2 sources by
2031 refer to Section 11.2 of Chapter 11, Sustainability and Climate Resilience .
1-11: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: minimize electric power production to lowest
possible level (preferably eliminating power production), and reassess amount of recovered heat
using the following process: reduce regular electric power production to zero, if possible.
As discussed above and in Comment A-69 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has established a new benchmark for sustainable development as part of its
Roadmap Net Zero by 203 1 program in response to DOER’s comment letter. This standard is based on
the latest and most stringent building energy codes in the Commonwealth of Massachusetts, along
with reputable third-party sustainability rating systems. For more information on Massport’s on-going
initiatives and investments to achieve Net Zero GHG emissions for its Scope 1 and Scope 2 sources by
2031 refer to Section 11.2 of Chapter 11, Sustainability and Climate Resilience .
1-12: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: minimize electric power production to lowest
possible level (preferably eliminating power production), and reassess amount of recovered heat
using the following process: if regular power production is necessary, assess the quantity of
recoverable heat than are captured based on the lowest possible level of power production (e.g.
“recovered heat”).
As discussed above and in Comment A-69 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has established a new benchmark for sustainable development as part of its
Roadmap Net Zero by 203 1 program in response to DOER’s comment letter. This standard is based on
the latest and most stringent building energy codes in the Commonwealth of Massachusetts, along Comment Letters and Response to Comments B-10
Boston Logan International Airport 2023/2024 EDR B
with reputable third-party sustainability rating systems. For more information on Massport’s on-going
initiatives and investments to achieve Net Zero GHG emissions for its Scope 1 and Scope 2 sources by
2031 refer to Section 11.2 of Chapter 11, Sustainability and Climate Resilience .
1-13: Air Quality/Emissions Reduction (GHG)
Develop and commit to a decarbonization plan for the central heating and power plant to transition
off fossil fuels based on the following approach: assess option of eliminating central plant heating
by converting all building heating to in-building heat pumps.
As discussed above in Comment 1-8, Massport appreciates the suggestion to transition building
heating systems to in-building heat pumps as part of its decarbonization efforts. The organization is
committed to exploring all viable options to reduce reliance on fossil fuels and enhance energy
efficiency. Massport will assess the feasibility of eliminating central plant heating and converting to in-
building heat pumps, considering factors such as infrastructure requirements, energy efficiency,
aviation operations and safety, and environmental impact. For more information on Massport’s on-
going initiatives and investments to achieve Net Zero GHG emissions for its Scope 1 and Scope 2
sources by 2031 refer to the 2023/2024 EDR Section 11.2 of Chapter 11, Sustainability and Climate
Resilience. Comment Letters and Response to Comments B-11
B Boston Logan International Airport 2023/2024 EDR
2. City of Boston Comment Letters and Response to Comments B-12
October 11, 2024
Rebecca Tepper. Secretary
Executive Of fi ce of Energy and Environmental Affairs
I00 Cambridge Street, Suite 900
Boston, MA 02114
Attn: Jennifer Hughes, Deputy Director, MEPA Of fi ce
Re: 2022 Environmental Status and Planning Report,
Boston Logan International Airport, EEA# 3247
Dear Secretary Tepper:
The City of Boston Environment, Energy and Open Space Cabinet welcomes this
opportunity to comment on the Logan International Airport 2022 Environmental Status and
Planning Report (2022 ESPR). We thank MEPA Of fi ce Director Tori Kim for coordinating
multiple meetings over the past year to facilitate discussions about how the stakeholders
can take the best advantage of this process.
After a thorough review of the 2022 ESPR, the City of Boston respectfully submits the
following comments in response to both what is contained in the report as fi led and the
data that we feel is missing or insuf fi ciently speci fi c. We recognize the economic value and
other bene fi ts of having an international airport within the city while also aspiring to
ensure that the negative impacts are reduced or mitigated wherever possible in explicitly
trackable ways. Our comments focus on the structure of the report, general air quality
issues, differentiating and improving climate actions, and a range of transportation issues.
DOCUMENT TIMING, FORMAT AND CONTENT
Massport continues to reference its fi ling of annual documents and then, once again, asks
to fi le a two-year Environmental Data Report (EDR) in 2025 rather than one for 2023. It also
continues to intersperse in this 2022 ESPR references to 2023 accomplishments: four new
gates opening in Terminal E, Piers Park II completed in December 2023, Bayswater
Embankment Airport Edge Buffer EENF fi led with MEPA in December 2023, etc. We believe
annual EDR fi lings and timely ESPR fi lings are important, and should be limited to
conforming data and references, by a date certain, so that year-to-year comparisons are
meaningful.
2-1
ESPRs with unsupported expectations about the future and the extensive and repeated use
of generalities are challenging to evaluate. Massport has standardized this framework with
the use of the conceptual 10- to 15-year Future Planning Horizon. The phrase ”in the Future
Planning Horizon,” is too general a reference that serves to obviate fi rm commitments. It is
used 21 times in the text of the main document. For example, estimated Greenhouse Gas
(GHG) Emissions are identi fi ed as “in the future planning horizon.” Firmer time horizons are
needed. The current format runs counter to a goal to tighten the link and process between
future expectations, goals, and mitigation.
The Secretary has shown via the thorough and incisive Draft Environmental Impact Report
(DEIR) Certi fi cate for the L.G. Hanscom Field North Air fi eld Development (EEA#16654)
[Certi fi cate], her willingness to require that Massport substantiate, in some cases justify,
assertions made in project-related documents. In a signi fi cant stipulation, the Certi fi cate
requires that the Supplemental DEIR propose mitigation measures that are commensurate
with the level of impacts of the project by quantifying those impacts and by presenting a
SC-C (social cost of carbon) analysis. These two requirements are noteworthy and, as
standards, will serve environmental justice communities particularly well. The GHG
bene fi ts associated with mitigation measures already proposed are also to be included in
the SDEIR. The Certi fi cate speci fi cally notes that credit should not be taken for any
measures for which actual implementation is not yet de fi nitive. We believe that this
well-balanced perspective should also be applied to the planning, impact expectations, and
mitigation base for EDR/ESPR discussions.That said, we recognize the differences between
project review and the EDR/ESPR process.
ESPRs from Logan often read as a listing of Massport’s accomplishments rather than as 1)
detailed chronicles of sometimes opaque information valuable to the people affected by
and evaluating the operation of Logan and 2) as a way to suggest what Massport may
realistically expect to change or accomplish in the future in order to plan to appropriately
mitigate, unforeseen circumstances and uncontrollable factors notwithstanding.
Representatives from the community have suggested that a mitigation framework with
metrics based on threshold triggers such as passenger numbers and fl ight activity is
preferable to the currently accepted format by which Massport generates forecasts in
ESPRs that are not looked at again until the next ESPR. This suggestion is based on the
recognition that there is a need for more timely attention to forecasts that are not
accurate, to a broader range of impacts, to impacts that exceed expectations, and to the
responses required to address them.
We agree that the current process does not result in accurate forecasts with mitigation
plans that get to the heart of impacts and we appreciate the added certainty that the
communities are seeking. But, we are not sure if, as described, impact-triggered mitigation
2 Comment Letters and Response to Comments B-13
might actually work to provide that predictability. And, despite discussion, we are unclear
about a reliable trigger-to-mitigation path. Our suggestion is that a reasonably sized,
multi-party working group be convened to address what are seen as the multiple existing
de fi ciencies in the ESPR planning, impact identi fi cation and mitigation process so that it be
made more effective in preventing or addressing damage to health and the environment.
Some detailed information in the ESPR is historical with little current value. For example,
Massport has indicated in numerous EDRs/ESPRs that it is committed to multi-modal
regional transportation options and cites its participation in the New England Regional
Aviation System Plan (NERASP) and other regional planning efforts. However, Massport’s
role in furthering multi-modal regional transportation is never discussed. What is the
function of this section in these fi lings unless there is something that demonstrates
concrete contributions to regional efforts and the potential effects on the environment,
demand and/or capacity? In general, what is the function of decades of historical data
without a relevant tie to the very recent past, the present and future?
Some information in the ESPR is relegated to the Technical Appendices and summarized
rather than spelled out (see Dwell and Persistence - meaningful if you live under a fl ight
path; see 2022 DNL Values at U.S. Census 202 Block Groups with no indication as to how to
make the Block Group IDs meaningful). Setting parameters for when data is relegated to
the appendices and how it should be made accessible is important, and presently missing.
Other information is repeated in various formats in the same section (see Air Quality and
Greenhouse Gas Emissions) and/or discussed in multiple locations in the document
making it time-consuming and dif fi cult to grasp the full picture of an issue. As only one
example, Environment Department staff found it necessary to take copious notes and go
back and forth in the document, Appendices and prior documents, in order to seek a
coherent and complete understanding of existing ground transportation conditions,
mitigation history, planned mitigation going forward, and the claimed bene fi ts of
mitigation. Despite that, we do not consider the effort completely successful. Both the City
and Massport lose under this scenario. We likely do not have a complete picture and,
equally likely, are not able to credit Massport for all of its efforts.
We join with the Massport Community Advisory Committee (MCAC) in requesting that the
data included in several of the technical appendices to the 2022 ESPR regarding operations
and impacts be made available to the public in a format that is accessible, and which allows
impacted community members to ask questions of the data. The charts and graphs in these
appendices provide a wealth of useful operational information. If these data were presented
in an electronic format which is searchable and allows interested users to query the data
regarding area-speci fi c impacts and compare them over time, this would allow for
meaningful, data-driven conversations about impacts and mitigation.It would be a bene fi t
3
2-2
2-3
2-4
to both community members and Massport. In its current analog format, it is nearly
impossible to answer basic operational questions that are important in ensuring a shared
understanding of impacts.
We suggest a process designed to revamp the format of these documents to reduce the
non-relevant information; condense information into smaller discrete subject sections; and
make them more readable.
ADDITIONAL TRANSPARENCY
In the past, Massport was required to fi le with MEPA an Environmental Noti fi cation Form
(ENF) to report all new routes proposed for Logan. The practice was eliminated, leaving the
public, environmental agencies, and other interested parties uninformed about these
additions. While both Massport and the FAA emphasize their lack of control over service
entrants, Massport has an active marketing team that seeks new entrants and new routes.
International routes, which seem to have dominated the increases over the past several
years, have created new capacity at Logan by extending the departure and arrival hours of
fl ights to meet the needs of arrival and origin locations in signi fi cantly different time zones.
This capacity increase results in increased noise disturbance time-frames for those under
fl ight paths. We strongly recommend that an ENF be required for all new or renewed
routes so that very basic information, including mandatory identi fi cation of fl ight
schedules and the aircraft to be fl own, is provided to a full range of stakeholders.
AIR QUALITY AND EMISSIONS
Massport identi fi es itself as a national leader in studying, tracking, and reporting on the air
quality environment of Logan Airport and in implementing measures to reduce emissions.
It is clear that Massport has made strides on any number of fronts to address air
quality—providing pre-conditioned air (PCA) and 400-Hertz (Hz) power at all aircraft
contact gates to reduce emissions associated with aircraft idling and APU use, replacing
older Massport fl eet vehicles with alternative fuel vehicles (AFVs) or EVs, replacing
diesel-powered GSE with eGSE where commercially available, installing charging stations
for eGSE equipment, the use of CNG buses. The concerns we have are the extent of claims
about activities not in Massport’s control and technologies such as alternative aviation fuel
not proven to have an air quality bene fi t for the end user (so therefore not bene fi tting
those harmed by Logan activities).
In general, Chapter 8, Air Quality and Greenhouse Gas Emissions , suggests Massport’s belief
that it can continue to grow from 2022’s 22,678,000 annual air passengers to 53.3 million
and from 266,034 aircraft operations to 495,000 “over the Future Planning Horizon of the
next 10 to 15 years.” During the same time-frame, operations sources of VOCs, NOx,
PM10/PM2.5, and CO are expected to remain at “similar” (well below 1990 benchmark)
levels due to:
4
2-5
2-6 Comment Letters and Response to Comments B-14
- converting ground service equipment (GSE) to viable electric alternatives (not
entirely under Massport’s control);
- lower motor vehicle emissions due to greater ef fi ciency and cleaner technologies
(dependent on manufacturers and the purchasers of vehicles);
- changes in the aircraft fl eet mix (also dependent on manufacturers and the
purchasers of aircraft); and
- emission reduction due to the Net Zero by 2031 program efforts.
There follows a list of strategies that include:
- “facilitating” the replacement of gas and diesel GSE;
- “encouraging” single engine taxiing;
- installing EV charging stations available for public use (while the Massport Board is
contemplating charging for their use);
- committing to LEED green building standards (which are dependent upon the
credits chosen); and
- investing in renewable energy installations.
None of these actions are quanti fi ed, and there is a lack of detail about plans for
‘facilitating’ and ‘encouraging.’ It is clear, for example, in other areas of the document, that
single engine taxiing is not pursued by Massport diligently as it is a practice that pilots do
not choose to use at Logan for a variety of reasons. We suggest that more detail is
necessary about how these goals are to be attained, particularly for strategies that are not
under Massport’s direct control. As written, we fi nd them to be unsubstantiated.
We also note that the ESPR refers the reader for more information to Chapter 8, Section
8.6, which doesn’t exist. There is a Table 8-12 which itemizes Air Quality Emissions
Reduction Goals, but there are no actual performance goals. This would suggest that much
of the reductions expected by individual contributors are not accurately quanti fi able.
Transportation accounts for 37% of the total greenhouse gas emissions in Massachusetts.
While off-airport parking with shuttle services for construction workers is identi fi ed as
construction mitigation and employee parking in Chelsea with shuttles to Logan is
identi fi ed as an employee transportation management measure, these strategies shift the
air quality burden. They do nothing to address close-in issues in the case of Chelsea or
Revere or regional emission issues that contribute to local burdens. Providing free or
subsidized parking for employees who have other travel options encourages driving and
has an impact on the roadways they use in addition to the areas in which they park. A
creative and active mitigation plan would work with airport employers to incentivize local
hires and promote strategies for getting as many employees as possible out of
single-occupant vehicles and into high occupancy or no- or low-emission vehicles for
commuting.
5
2-7
NOISE
When the FAA’s TRACON software was updated it no longer worked with the software that
Massport had used for the Preferential Runway Assignment System (PRAS). Massport
continues to provide data it identi fi es as PRAS but there is no longer a functioning
assignment system. We suggest that it be eliminated from future EDRs & ESPRs.
It is noted that reduced-engine taxiing is encouraged but little additional detail is provided.
How often and by what means? How is success measured? If it’s not presently successful, is
there a better strategy? Do other windy airports have more successful strategies? This is
identi fi ed as an air quality mitigation measure but it is not practiced regularly by airlines
and no air quality bene fi t is quanti fi ed.
Answers to additional questions would be useful. How successful have the efforts to
maximize late-night over water operations been? What percentage of eligible fl ights make
use of the option? How could the number be improved? Has the ban on nighttime engine
run-ups and use of APUs been successful? How is success measured?
BUILDING SOUND INSULATION
Massport identi fi es itself as having one of the longest-standing and most extensive
Residential Sound Insulation Programs (RSIP) of any airport in the nation, having insulated
5,467 residences and 36 schools. We ask that the number of insulations be broken down by
the years in which they were completed for both the residences and schools.
We note that soundproo fi ng is proceeding in Revere and Winthrop and that new noise
contours have been established for 2024 that will include East Boston.
CATEGORIZING AND REPORTING ON CLIMATE ACTION
Chapter 2 of the ESPR is titled Sustainability, Outreach, and Environmental Justice with a
sub-section titled Sustainability, Climate Adaption (sic), and Resiliency . While sustainability
and resilience actions are both appropriate responses to climate change, they are not the
same. Given the importance of each, we would recommend distinct chapters on
sustainability and climate resilience going forward.
The ESPR does not speci fi cally provide the climate resilience measure information
requested by the Secretary. Given the scale and nature of Massport’s footprint, we would
encourage a future chapter on resilience to focus explicitly on the plans and projects that
actively address the risks of extreme heat, intense precipitation, and coastal fl ooding,
including efforts focused on employees, guests, operations, assets and adjacent properties.
On the BERDO Covered Buildings List alone, Massport is listed as the owner of 59 buildings,
many of which are in the Logan vicinity, many in the fl oodplain. Numerous tenanted
6
2-8
2-9
2-10
2-11
2-12
2-13 Comment Letters and Response to Comments B-15
buildings would bene fi t from guidance and a clear course of action detailed in future
ESPRs.
The ESPR does mention that Massport published a 2020/2021 Massport Sustainability and
Resiliency Report. No details are provided; it is not included in the 2020/2021 EDR; we did
not fi nd a report on the website; and, a link to Sustainability and Resiliency in that EDR
lands at a page of Sustainability goals. That EDR also mentions an annual Sustainability and
Resiliency Report but there are no links in the ESPR and mentions of it focus on the
sustainability agenda.
We request that EDRs and ESPRS include the annual Sustainability and Resiliency Report
and that it be prominently posted in the Environmental section of Massport’s website. At
present, only regulatory documents are posted.
COMMUNITY AND ENVIRONMENTAL JUSTICE OUTREACH
Massport indicates that its commitment to engaging with nearby communities and
enhancing the quality of life of its neighbors is carried out by its Community Relations &
Government Affairs Department and the Massport CAC [Community Advisory Committee].
We note that the Massport CAC is a legislatively created body and that it is funded by
Massport. It does not, however, function as an agent of Massport and is not charged with
responsibility for Massport’s community and environmental justice activities. Section
2.3.2.2 should be edited to re fl ect that the Massport CAC was established by the
Massachusetts General Court in 2014.
Consigning what is described as EJ supporting documentation to the Appendices seems
inappropriate given the signi fi cance of these issues. It is of note, however, that the
documentation does not actually provide detail on how Massport might be working
speci fi cally to address airport impacts in EJ communities. Providing census tract data
without instructions for how to identify where those census tracts are located is not useful.
IMPROVING REPORTING ON EMPLOYEE TDM MEASURES
The Secretary’s Certi fi cate on the Boston Logan International Airport 2020/2021 EDR,
dated January 2023, requires that the 2022 ESPR address, “Strategies for enhancing
services and increasing employee membership in the Logan Airport TMA.”
These are the references to the TMA in the main text of the ESPR:
1. West Garage, Table 10-1, Mitigation Measures - Massport will form a
Transportation Management Association (Logan TMA) for Logan Airport
employees in order to provide new opportunities for the development of targeted
Transportation Demand Management (TDM) strategies for Massport and airport
tenant employees.
7
2-14
2-15
Implemented . Massport continues to support the TDM strategies by funding the
Logan Sunrise Shuttle at a cost in 2022 of approximately $161,000. Massport
continues to conduct outreach through new hire orientation materials and other
communication methods to raise awareness of employee commute options with a
focus on high-occupancy vehicle (HOV) modes of transportation.
We have the following questions: Is there a TMA? Has this been implemented? If so, how
does the TMA operate? What does it do? How many members does it have? What
percentage of employees does that represent? How does it measure success?
2. West Garage, Table 10-1, Mitigation Measures - Massport will develop, coordinate,
and implement effective TDM strategies to reduce the number of single-occupant
trips made by all Logan Airport employees, including outreach to employees about
transportation options
Implemented . Massport supports TDM strategies by providing services to Logan
Airport employees and by periodically conducting the Massport Employee Survey.
Findings from the 2022 Logan International Airport Air Passenger Ground Access
Survey are summarized in Chapter 6, Section 6.5.2. Massport surveys its
employees as part of its Massachusetts Department of Environmental Protection
(MassDEP) Rideshare reporting requirements.
We note that this response is not speci fi c to the requirements of the mitigation measure.
What is its status? Massport’s Air Passenger Ground Access Survey is not relevant here. We
have never seen the Mass DEP Rideshare survey results and there is no reason to expect
that it would address the issues of an urban airport comprehensively. Detailed information
about outreach strategies and their relative success should be provided in EDRs and ESPRs.
3. West Garage, Table 10-1, Mitigation Measures - Massport will report on the
formation and activities of the Logan TMA in the next Generic Environmental
Impact Report (GEIR). [Now ESPR].
Implemented . Massport continues to support TDM strategies by funding the
Logan Sunrise Shuttle at a cost in 2022 of approximately $161,000. Massport
conducts outreach through new hire orientation materials and other
communication and engagement methods to raise awareness of employee
commute options with a focus on HOV modes of transportation.
In addition to the comments above, we have the following questions: What information do
new hire materials provide to employees? Are they the same for all employers? How often
are they updated and sent to employers? Does the TMA provide advice and assistance to
employers? If so, what is that advice and assistance?
8
2-16 Comment Letters and Response to Comments B-16
4. Replacement Terminal A, Table 10-4, Mitigation Measures - Delta Air Lines, Inc. to
join Massport’s Logan TMA and designate an Employee Transportation Advisor.
Implemented.
Additionally, Delta Air Lines will provide the following services as part of their
Transportation Demand Management Program (DMP) through the Logan TMA:
Transportation subsidy for full-time Delta Air Lines employees at Logan Airport;
ride matching/carpooling; vanpooling; guaranteed ride home; preferential parking
for high-occupancy vehicles (HOVs); shuttle to and from employee parking.
Implemented .
It would seem that these are not one-time measures, but should be ongoing. What is the
current status? Do some employers provide parking for their employees off-site? How
many employers offer parking as a bene fi t and how many employee spaces are occupied by
these employees? How many shuttles are operated by entities other than Massport and
what are their characteristics?
5. Table 10-5 Logan Airside Improvements Planning Project (EEA #10458) Details of
Ongoing Section 61 Mitigation Measures (as of December 31, 2022) Report on
Progress of Logan Transportation Management Association (TMA).
Implemented .
We have been unable to fi nd this report.
6. Table 10-6 Southwest Service Area (SWSA) Redevelopment Program- Requires
rental car companies to participate in the Logan Transportation Management
Association (TMA).
Implemented .
It would seem that this is not a one-time measure, but should be ongoing. What is the
current status of rental car companies vis a vis the TMA?
7. EEA# 3247 2020/2021 EDR Certi fi cate, January 30, 2023 - The 2022 ESPR should
report on 2022 ground access conditions at the airport and provide a comparison
to 2019, 2020, and 2021 for the following (includes):
- Logan Airport Employee Transportation Management Association services
This does not appear to be included in the 2022 ESPR in a comprehensive way.
Massport identi fi es the following as TDM measures:
- Encourage employees to use alternative transportation to commute.
9
- Encourage employees to utilize public transit through a comprehensive employee
transportation system that includes includes a 24/7 free shuttle bus service to the
Terminals with off-Airport employee parking in Chelsea; shuttle buses connecting
Airport Station to Southwest Service Area, South Cargo Area locations, and
Terminals; early morning and late-night Logan Express bus trips that provide
nearly 24 service to several locations with signi fi cant discounts for Airport-wide
and Massport employees; the Sunrise Shuttle that offers early morning services
from East Boston, Winthrop, and Revere before the commencement of MBTA
operations.
- Subsidies for water transportation, transit use.
- Financial support for the Sunrise Shuttle.
- Discounted HOV and transit fare options.
- Bike racks or posts for securing bikes at all new facilities and at appropriate
existing facilities to promote employees biking to work. Bicycle racks or posts for
securing bikes are currently provided at the RCC, Terminal A, Terminal E, Logan
Of fi ce Center, MBTA’s Airport Station, Economy Parking Garage, Signature general
aviation facility, and the Green Bus Depot (Bus Maintenance Facility, for authorized
personnel).
We believe Massport should detail the current status of the TMA beginning with the
following information:
- the number of employers on the airport;
- the number of employees who commute to a job at the airport;
- the number of employers that were members of the TMA in 2019, 2020, 2021 and
2022;
- the range of services offered/sponsored by the TMA in 2019, 2020, 2021 and 2022,
utilizing a checklist, with at least the following categories;
- subsidized transit pass,
- subsidized fares for HOV use (enumerate - ex. Logan Express,
commuter bus, ferry/water shuttles),
- free shuttle services-identify all,
- subsidized shuttle services (identify all and specify subsidy),
- secure bicycle parking protected from the elements,
- showers and changing rooms,
- ride matching service (explain process),
- number of three-person (or more) car/vanpools, and
- guaranteed ride home for commuters who qualify as walkers, transit-,
HOV-, or bicycle-users (we do not see Logan Express as a blanket
guaranteed ride home).
10
2-17 Comment Letters and Response to Comments B-17
In addition, Massport should provide information about TDM and Massport employees as
outlined in the following questions:
- Does Massport provide free and/or subsidized parking to its employees? If there
are charges to riders, please explain. If, for example, carpool or vanpool vehicles
are offered incentives, please identify them.
- How many parking spaces does Massport provide off of the airport for its
employees and where are the off-airport spaces located? Is 2,448 the correct
number of on-airport spaces available to Massport employees?
- How do employees access the airport from those parking locations? If they are
served by shuttles, please indicate the hours and frequency of operation. If this
does not include Park N Ride locations, please identify the Park N Ride locations
served by shuttles.
- How many employee showers and employee changing areas serve employees on
the airport, where are they located and how are employees made aware of them?
Are they available 24-hours/day?
- How often are free employee shuttles run from Airport Station to employment
areas in SWSA and South Cargo Area?
- What are the transit & water shuttle subsidy rates for Massport employees?
- Is the ‘new’ employee Park N Ride in Quincy for employees who use the Braintree
Logan Express? If so, how do they get to the Logan Express?
8. EEA# 3247 2020/2021 EDR Certi fi cate, January 30, 2023 - The 2022 ESPR should
address the following topics (includes):
- Strategies for enhancing services and increasing employee membership in the
Logan Airport TMA.
We note that this does not appear to be in the 2022 ESPR.
We appreciate that as a 24-hour operation with many, many independent employers in the
mix, implementing TDM is a challenge. That said, there are attractive TDM options available
or potentially available to all employees, many created speci fi cally by Massport, throughout
most working hours of the day and night. This population can be in fl uenced to give up the
single-occupant vehicle (SOV) trip if there is a broad menu with incentives that incorporate
various ways of commuting.
Each EDR and ESPR should provide some basic information about TDM measures that are
available to employees with speci fi c information from employees sought through a periodic
(we suggest annual) survey. We believe that a commitment to doing a survey on a
scheduled basis is necessary to ensure attention to this issue and are requesting that each
EDR/ESPR provide detail about the most recent employee survey to include: date, a copy
of the survey tool, method of administration, number of respondents, and a table of
11
2-24
2-23
2-22
2-21
2-20
2-19
2-18
2-25
answers. The survey should not be limited to asking about current transportation habits
but should also be used to assess what additional methods might encourage employees not
to drive, particularly in SOVs.To start, we suggest a check-list of existing
amenities/measures and employees should be asked if they are aware of them and if they
are made available to them so that the survey tool can also serve as an educational
opportunity.
We ask that the following TDM measures be considered as part of a standard,
comprehensive plan by all employers if they are not already offered:
- Free or subsidized transit pass
- Reduced-fee Logan Express-needs to indicate charges for employee parking and
bus ticket
- Guaranteed Ride Home program - needs not to be Logan Express (see notes
below)
- A ride-matching service for employees who may want/need to commute by car
and are looking to carpool/vanpool
- Advantageous (on-airport) parking for carpoolers (3 or more
employees)/vanpoolers
- Free shuttle from off-site car/vanpool parking locations in addition to Chelsea
- Bicycle amenities/programming (see notes below)
- Showers and changing rooms in various areas of the airport; some available
24-hours, with safe transportation to work locations
Guaranteed Ride Home (GRH): Logan Express will not get all employees home or close to
home and should not be considered a GRH program in and of itself. GRH programs provide
employees with an occasional free or partially subsidized ride home in cases such as
unscheduled overtime or other unanticipated change in schedule, a family illness or
emergency, the sudden illness of the employee or their family members. They address a
common objection to the use of alternative modes of transportation. Employees who walk,
bike, take transit, or carpool/vanpool to work are reimbursed for the cost of their ride
home. Reimbursements from these programs typically cover taxis, transportation network
companies (e.g. Lyft or Uber), transit costs, and rental cars. Employers may cap
reimbursements for each employee at a mile or dollar amount (e.g., $30 per month). The
cost of offering this service tends to be low because it is rarely used.
Bicycle Program:The ESPR indicates that bicycle racks or posts are located throughout the
airport with sheltered parking racks at the Rental Car Center (RCC) and covered bike
parking at Terminal A. A comprehensive bicycle support program would include multiple
bicycle storage rooms in various locations with at least one of them including a repair
station that offers a tire pump, chain lube, a few allen keys and maybe the Big Blue Book of
12
2-25
2-26 Comment Letters and Response to Comments B-18
Bicycle Repair. It is our experience that protection from the elements is a signi fi cant factor
in the successful promotion of a bicycle-commuting program.
Ensuring and publicizing safe bicycle access and pathways is also essential. Describe the
ways and provide graphics that show the routes into and out of the airport that are being
made safe and obviously available to bike riders. Offering to sponsor or subsidize training in
safe riding skills for cyclists can be a valuable and welcomed service for employees.
We suggest that a bicycle storage room (perhaps with a repair station), showers and
changing rooms be part of the 4,300-space parking garage to be built in front of Terminal
E. In addition, we suggest consideration of employee parking spaces for veri fi ed three- or
more person carpools and vanpools in easy on- and off- locations in the new garage.
IMPROVING PASSENGER GROUND TRANSPORTATION
Logan Express
The ESPR indicates that bus customer facilities and secure parking are provided at the four
Logan Express suburban locations with no customer parking provided for the urban Back
Bay route. The cost of an adult bus trip is $12 each way for a standard fare and $9 each way
with advanced online ticket purchases (identi fi ed on the Massport Logan Express Website
as a time-limited price). Although a discount for Seniors is indicated, there is no way to
take advantage of such a discount. Back Bay Logan Express tickets are $3 to Logan, and free
from Logan to Back Bay. Parking at suburban lots is $7 per day.
A site in Danvers to be opened in 2024 has opened; however, it is identi fi ed as a new
suburban location. As it is replacing the Peabody location, just under a mile away, it is a new
facility but not one that expands the number of Logan Express offerings.
Limited parking disclaimers, though honest, deter the users of these services. This is
always posted on LoganExpress.com: “Parking at all Logan Express locations is limited. We
cannot guarantee parking and are strongly recommending getting picked up and dropped
off at Logan Express. Please visit our website for alternative options for getting to and from
Logan Airport.” This is not reassuring and encourages four vehicle trips rather than two in
local areas. It also means that an unexpected late arrival back at Logan resulting in a late
arrival back at the Express parking lot, may result in pick-up problems. It is not unusual for
there to be more speci fi c alerts on the Website indicating that a Logan Express lot is full,
particularly at Braintree and Framingham, or that it is making use of off-site over fl ow
parking, potentially creating a timing problem. It would seem that there is value in the
limited amount of self-control that Logan Express offers. It is important that the service
function to maintain that level.
13
2-27
We note that there are plans to expand the garage in Framingham by about 1,000 spaces
and to increase the frequency of service from every 30 minutes to every 20 minutes at an
unidenti fi ed time in the future.
There is no easy way for passengers to compare Logan Express sites in terms of schedules
and it appears that they do not operate on a universal time-table. If a passenger wanted to
drive to one location and saw online that the lot was full, there should be a convenient way
to see whether another location had a scheduled trip that they could get to readily. We
suggest that the Website post a one-page Master Schedule that would allow for passengers
to quickly assess potential options. It’s also not clear if the very early and very late trips are
exclusively for employees and serve limited sites or if they serve all sites and are open to
anyone who has a ticket. Clari fi cation on the nature of these trips would be helpful.
Potential new sites for Logan Express include North Station and somewhere in Metro West.
We support Massport’s proposal for a North Station location and suggestion of a Metro
West-area site and we agree with Air Inc.’s recommendation for a total of three new
locations. There have been suggestions to utilize one of the former I-90 toll plaza sites.
Given the popularity of the Framingham Logan Express, a location west of that might well
capture the greater-Worcester area population that doesn’t want to use the Turnpike or
deal with the Commuter Rail and then the MBTA. We would also suggest a site in the area
of JFK/UMass.
While there are inherent bene fi ts to taking a bus to the airport, the Airport Security Line
Priority is an additional incentive. It is identi fi ed in some materials as a bene fi t of using
Logan Express, but we would like clarity on the current status of the program.
In the longer term, we suggest planning for certain remote sites to become TSA security
screening locations so that passengers can clear security and check baggage which will be
transported separately and securely to Logan. Perhaps these locations can start with
passengers who have cleared TSA pre-check or who are not checking bags. They will then
use a dedicated Logan Express to take them as close to the gates as possible. The more
convenient this makes the commute and accessing the terminals, the more likely families
will be inclined to use the service. We suggest asking on the next air passenger survey if
this level of convenience would entice passengers to use this kind of service.
The comfort and convenience of passengers is foremost at Logan but not at the Logan
Express sites. We would like Massport to address the following questions about these sites.
Are there safe, indoor waiting areas available for the earliest passengers and for those
whose fl ights may arrive late and may, therefore, delay ultimate passenger pick up? How
does Logan Express work for the suburban sites when fl ights are delayed and arrive after
the last bus is scheduled to leave Logan? Given that passengers don’t have reservations on
Logan Express, are they then left on their own to get from Logan to Framingham at 2 am,
14
2-31
2-31
2-30
2-29
2-28
2-32 Comment Letters and Response to Comments B-19
for example? Is this tracked somehow? Do we know why Peabody wasn’t more popular?
Does Danvers address de fi ciencies that were present in Peabody?
Other High Occupancy Vehicles
In most contexts, a High Occupancy Vehicle (HOV) refers to vehicles with two or or more
passengers, including the driver, but the high number of vehicles arriving and departing at
Logan with a driver who is not an air passenger blurs the accuracy of the reporting. In the
event that a taxi, black car limousine, and RideApp driver drops off and picks up passengers
on the same trip, such service may be seen as reducing overall traf fi c volumes compared
with a passenger who is being dropped off or picked up by someone who would not
otherwise make the trip.
The 2020/2021 Environmental Data Report (EDR November 2022) indicates that, “Starting
with the 2019 Logan International Airport Air Passenger Ground-Access Survey, Massport
has used this updated de fi nition of HOV that considers vehicle occupancy among taxi,
black car limousine, and RideApp modes. Previously, Massport counted taxis and RideApp
services as non-HOV and black car limousines as HOV, regardless of the number of
passengers transported. Under the updated de fi nition, taxis, black car limousines, and
RideApp services that carry two or more air passengers per vehicle are de fi ned as HOV.
With this new de fi nition, Massport has a goal of reaching 35.5 percent HOV by 2022, and 40
percent HOV by 2027.” This seems reasonable to us so long as an accurate count of air
passengers can be assured. What remains unclear is, how does Massport document the
number of air passengers in any vehicle? We understand that they can count taxis that use
the taxi pool to wait for a fare leaving Logan, for example, because the driver must buy a
ticket to park in the taxi pool. Is there a way to count taxis that drop off but don’t go to the
taxi pool? How are the number of passengers in an arriving taxi counted? We have the same
question for RideApp vehicles, identi fi ed as the predominant mode of travel to Logan. In
general, how are RideApp operations tracked? Is someone in the parking garages counting
the number of people who get out of RideApp vehicles that enter the drop-off parking
garages? How do things work for black car limousines so that Massport has an accurate
count?
There are numerous references in the EDR to the contributions of RideApp Management to
congestion and emissions reduction but the actual strategies or how strategies are
implemented are nebulous. These are our questions:
- What speci fi c strategies have been identi fi ed to meet the goals of the RideApp
Management Plan (2020/2021 EDR)? We have gleaned that the dedicated
drop-off/pick-up in the Central Garage and reduced fees for shared rides are
being relied upon to increase RideApp shared rides, reduce deadhead trips and
reduce congestion. How are potential riders made aware that sharing a trip would
15
2-33
2-34
2-35
2-36
save them money? How does Massport quantify the improvement it makes in
congestion and in a related drop in GHG emissions?
- Please identify other RideApp strategies and describe what success looks like, how
is it quanti fi ed?
We are also curious to learn more about the following:
- What does exploring RideApp Last Mile connections mean?
- How many parking spaces are in the co-located RideApp Pool Lot/Cell Phone
Waiting Lot on Porter Street? How is it monitored for idling and the fi ve-minute
idle law enforced?
- How does Ride Rematch work, how has it been advertised and facilitated and how
has success been measured? What are the numbers?
- What percentage of RideApp drivers who drop off a passenger or passengers stay
on-airport to wait for a passenger to leave Logan?
- How have passenger-shared rides been advertised and facilitated and how
successful have the efforts been? How has success been measured?
- How are numbers obtained in order to calculate the 38.4% HOV mode share?
Congestion Pricing and Other Potential Pricing Strategies
Massport had agreed in 2017 to conduct a Congestion Pricing Study to determine if the
strategy would reduce auto emissions at Logan. It was expected to be completed by July
2019. In April 2018, the Boston Globe reported that Massport had decided against
congestion pricing but it did not reference the study. The then-CEO stated that many
people who drive to Logan pay a toll at the harbor tunnels and that an added fee for the
airport could seem unfair. We believe it could seem equally unfair to people living near
Logan that they bear the associated air quality and health impacts, including those caused
by airport traf fi c.The best way to determine if a strategy can help to minimize impacts is an
unbiased, well-designed study (or perhaps a real-time test) to determine if a fee would
result in a quanti fi ed level of traf fi c reduction.
Other strategies that might bear study are a combination of roadway access or curb access
pricing and multiple pricing scales for Logan Express to determine potential effect on
demand.
EVs/AFVs/APVs
In the discussion of Air Quality and Greenhouse Gas Emissions, the ESPR identi fi es
encouraging the conversion to AFVs/APVs - Alternative Fuel Vehicles/Alternative Power
Vehicles - as an air quality emission reduction goal. (Confusingly, the Acronyms section
identi fi es “APV” as Approach Procedure with Vertical Guidance.)
Policies such as a 50 percent discount in ground access fees to limousines, vans, and buses;
and preferred parking for hybrid and AFVs/APVs at Logan Airport parking facilities, and
16
2-37
2-38
2-39
2-40
2-41
2-42
2-43
2-44 Comment Letters and Response to Comments B-20
free “high-speed” EV charging to RideApp companies and taxis serving Logan Airport are
speci fi ed as strategies. We would like de fi nitions for preferred parking and descriptions of
how limousines, van services and buses are noti fi ed of the incentives and how quali fi ed
vehicles are recognized. A summary of the marketing and use of these incentives should be
provided annually.
The ESPR indicates that by the end of 2022, there were over 70 EV charging ports across
Logan Airport available for use by shared-ride companies (i.e., RideApp companies, rental
cars, taxis, and limousine vehicles) and the general public, with additional ports owned and
proposed by rental car companies at the Rental Car Center (RCC). We request that
Massport identify the locations of all chargers and any limits, if any, on who may access and
use them.
Massport identi fi es the installation of EV charging stations available for public use,
including RideApp vehicles, black car limousines, and taxis as an air quality management
strategy to reduce criteria air pollutant and GHG emissions. Massport currently provides
free “high-speed” EV charging to RideApp companies and taxis serving the airport and is
working with the Massachusetts Clean Energy Center (MassCEC) to study opportunities to
enable the conversion of ride-for-hire fl eets serving Logan Airport to EVs.
We understand that the Massport Board has recently discussed charging a fee for the use
of EV charging portals. We understand that having a vehicle parked at a charging portal for
an extended period of time may be part of the problem. If a passenger leaves a car in that
spot during a three-day trip, the charger is not available to anyone else so Massport does
not get the most out of their investment. At the same time, the goal to reduce GHG
emissions is important enough to merit additional charging portals. We suggest that at
least 15% of spaces in the new parking garage have a charging portal.
Air Passenger Ground Access Survey
The surveying methodologies and results were not fully described in the ESPR. What was
the 2022 Air Passenger Ground Access Survey protocol? What was the sample target? How
many passengers participated in the survey? For HOV users, ask about how many in their
traveling party used and HOV to get to Logan.
The way in which respondents are asked about the number of people in a vehicle is phrased
by asking about “occupants,” not about “passengers” or “air passengers.” This may well
result in some respondents including the driver as an occupant when they are not also an
air passenger. A distinction that indicates that the question is looking for the number of air
passengers or does not want to count someone who is just a driver may result in different
information.
17
2-45
2-46
2-47
2-48
In the past, community comments have noted that the surveys have not sought information
about what might make Logan Express more attractive to passengers. Although the 2022
survey is not replicated in the ESPR, the results seem to suggest that it is very limited in
scope. We suggest that Massport make the most of this one opportunity to get information
from passengers and ask if their HOV trip was satisfactory and if there are improvements to
HOV options in general that would make them more attractive. Focusing on Logan Express
should be predominant.
There are also no questions about the use of EV chargers at Logan and the survey would be
an opportunity to learn more about EV users. We suggest the following questions:
- Did you drive an electric vehicle (EV) to Logan and park it here during your trip?
- Did you park it and leave it at a charging station?
- How many kWh does your car need to charge?
- If you needed to charge your car when you left it, how much charging time did it
need?
- If there had been a cost to charge your car and then move it to a preferred parking
space without a charger for your pick-up, would you still drive your EV to Logan?
City of Boston staff is available to meet with you, your staff, or with Massport on any of the
issues raised in this letter. We look forward to your Certi fi cate and to Massport’s response
to our comments.
Sincerely,
Chief Brian Swett
City of Boston, Environment, Energy & Open Space Cabinet
Of fi ce of Mayor Michelle Wu
Cc:
Roberto Gomez, Of fi ce of Neighborhood Services
Aaron Tof fl er, Executive Director, MCAC
John Nucci, MCAC, Massport Board of Directors
Chris Marchi, AIR, Inc
Gail Miller, AIR, Inc.
18
2-49
2-50 Comment Letters and Response to Comments B-21
B Boston Logan International Airport 2023/2024 EDR
City of Boston Comment Response
2-1: Logan Airport Environmental Review and Planning
Annual EDR filings and timely ESPR filings are important, and should be limited to conforming data
and references, by a date certain, so that year-to-year comparisons are meaningful.
As discussed in Comments A-3 and A-4 in Appendix A, MEPA Certificate and Responses to
Comments , Massport has employed multiple strategies to improve the timing of document and annual
data publication. These strategies include an in-depth review of prior report development procedures,
creating a new User’s Guide reference document, limiting data reported in EDRs and ESPRs to
applicable reporting years, and developing an EDR and ESPR website. Section 1.2.2 of Chapter 1,
Introduction and Executive Summary, also has an overview of document changes in the 2023/2024
Environmental Data Report (2023/2024 EDR) . Before filing the 2023/2024 EDR , Massport developed a
new webpage specifically for EDR and ESPR filings (https://www.massport.com/environment/boston-
logan-edr-espr-data-portal). For more on the EDR and ESPR website, refer to Section 1.2.2.2 of
Chapter 1 .
2-2: Logan Airport Environmental Review and Planning
Our suggestion is that a reasonably sized, multi-party working group be convened to address what
are seen as the multiple existing deficiencies in the ESPR planning, impact identification, and
mitigation process so that it can be made more effective in preventing or addressing damage to
health and the environment.
As discussed in Comments A-1 and A-5 in Appendix A, MEPA Certificate and Responses to
Comments , Massport is committed to active participation in the Work Group established in
collaboration with the Massachusetts Environmental Policy Act (MEPA) Office and the Office of
Environmental Justice & Equity (OEJE). MEPA’s Logan Airport Work Group, launched in February 2025,
includes representatives from state agencies, local officials, and community stakeholders and is co-
moderated by MEPA and OEJE to promote an inclusive and transparent process.
The Work Group’s primary objective is to assess and discuss potential supplemental mitigation
measures that could address environmental concerns associated with Logan Airport operations among
environmental justice (EJ) communities in East Boston, Winthrop, and Chelsea. The Work Group may
also serve as the proper forum to discuss the ESPR planning process as suggested.
2-3: Regional Transportation
Massport has indicated in numerous EDRs/ESPRs that it is committed to multi-modal regional
transportation options and cites its participation in the New England Regional Aviation System Plan
(NERASP) and other regional planning efforts. However, Massport’s role in furthering multi-modal
regional transportation is never discussed. Comment Letters and Response to Comments B-22
Boston Logan International Airport 2023/2024 EDR B
The New England Regional Airport System Plan (NERASP), completed in 2006, assessed long-term
aviation demand across the six New England states and explored how the regional airport network
could help manage growth at Logan Airport. The study concluded that existing regional airports, such
as Rhode Island's T. F. Green International Airport (PVD), Manchester-Boston Regional Airport (MHT),
and Worcester Regional Airport (ORH), could accommodate projected passenger demand through
2020 without the need for a new airport. NERASP identified Logan as the primary hub, drawing
passengers from surrounding markets, which resulted in high rates of passenger leakage from nearby
airports. To address this imbalance, the plan recommended improving airline service at regional
airports and encouraged coordination across the system to better distribute demand. Massport
integrated NERASP forecasts into Logan’s ESPR and delayed the 2004 ESPR publication to ensure
consistency with regional planning data.
2-4: Logan Airport Environmental Review and Planning
We join with the Massport Community Advisory Committee (MCAC) in requesting that the data
included in several of the technical appendices to the 2022 ESPR regarding operations and impacts
be made available to the public in a format that is accessible, and which allows impacted community
members to ask questions of the data.
As discussed in Comments A-1, A-5, and A-16 in Appendix A, MEPA Certificate and Responses to
Comments , Massport remains committed to enhancing data transparency and accessibility. On-going
engagement with the MEPA Office, the OEJE, and other stakeholders will continue so that data requests
are addressed and relevant information is presented in a clear and accessible manner. Massport will
collaborate with MEPA and stakeholders to refine the structure and presentation of EDRs and ESPRs,
enhancing readability and public comprehension by improving summaries, visuals, and key findings.
These efforts build upon recent improvements, including those discussed elsewhere in Appendix A ,
Appendix B, and Section 1.2.2 of Chapter 1, Introduction and Executive Summary .
2-5: Logan Airport Environmental Review and Planning
We suggest a process designed to revamp the format of these documents to reduce the non-
relevant information; condense information into smaller discrete subject sections; and make them
more readable.
As discussed above, as well as Comments, A-1, A-3, A-4, A-5, and A-16 in Appendix A, MEPA
Certificate and Responses to Comments , Massport remains committed to enhancing data
transparency, accessibility, and the clarity of ESPRs and EDRs. Massport improved the usability and
reduced the length of the 2023/2024 EDR by focusing the main chapters solely on annual data updates
and introducing a User's Guide that outlines regulatory frameworks and methodologies, enhancing
document transparency and efficiency. In addition, the 2023/2024 EDR narrowed the focus of data
analysis on reporting and benchmark years, supported by the newly developed EDR and ESPR
webpage. This webpage includes historical EDRs and ESPRs with extensive data to be posted in a Comment Letters and Response to Comments B-23
B Boston Logan International Airport 2023/2024 EDR
searchable format in the near future. In addition to the historical data, the webpage will also include
links to data sources referenced within EDRs and ESPRs that provide data in the interim before the
availability of the EDR and ESPR. These data sources are often hosted by other state agencies, federal
databases, and other reputable sources. Section 1.2.2 of Chapter 1, Introduction and Executive
Summary, also has an overview of document changes in the 2023/2024 EDR and further information
on the EDR and ESPR website.
2-6: Logan Airport Environmental Review and Planning
We strongly recommend that an ENF be required for all new or renewed [scheduled flight] routes so
that very basic information, including mandatory identification of flight schedules and the aircraft to
be flown, is provided to a full range of stakeholders.
The approval of new routes falls within the federal purview of the Federal Aviation Administration
(FAA), and Massport will comply with FAA reporting requirements associated with new or renewed
routes to the extent that these requirements apply to Massport.
In the early 2010s, airlines began consolidating flights to primary hubs such as Logan Airport, while
reducing service at secondary airports like PVD, MHT, and ORH. This shift accelerated after the 2008
financial crisis as airlines restructured networks to improve profitability and operational efficiency. As a
result, today's airline carriers prioritize high-demand markets and streamline routes to focus on hub-
and-spoke models that concentrate traffic at major airports, such as Logan Airport.
As discussed in Comment 6-13, Chapter 5, Regional Transportation of the EDR and ESPR, continues
to track new developments and the relationships between Logan Airport and other regional airports, in
addition to transportation alternatives such as rail transport modes.
2-7: Air Quality/Emissions Reduction (GHG)
We suggest that more detail is necessary about how [air quality and GHG emission] goals are to be
attained, particularly for strategies that are not under Massport’s direct control.
As discussed in Comment A-69 in Appendix A, MEPA Certificate and Responses to Comments ,
Massport aims to reach absolute Net Zero GHG emissions across all scopes, without relying on
renewable energy credits (RECs) or carbon offsets, by 2040. For more information on these efforts, see
Chapter 11, Sustainability and Climate Resilience. As discussed in Section 11.2.1 of Chapter 11 , in
2023, the Board of Directors voted to approve $500 million in investments to Net Zero projects, laying
the groundwork for future reductions over the next five years. This funding supplements routine
funding requests that incorporate the R oadmap to Net Zero by 2031 Program. For instance, at its
January 14, 2025, meeting, the Board approved the purchase of up to 50 electric shuttle buses for
Logan Airport, in collaboration with the Massachusetts Bay Transportation Authority (MBTA). Massport
has committed to achieving Net Zero GHG emissions for its Scope 1 and Scope 2 sources by 2031. Comment Letters and Response to Comments B-24
Boston Logan International Airport 2023/2024 EDR B
Additionally, Massport aims to reach absolute Net Zero GHG emissions, without relying on renewable
energy credits (RECs) or carbon offsets, by 2040, as discussed in Section 11.2 of Chapter 11.
2-8: Noise
Massport continues to provide data it identifies as PRAS, but there is no longer a functioning
assignment system. We suggest this be eliminated from future EDRs & ESPRs.
Although the Preferential Runway Advisory System (PRAS) program has been discontinued, Massport
continues to report key PRAS statistics for public information purposes, as part of its commitment to
transparency regarding the effects of Logan Airport operations on surrounding communities. However,
background information on the PRAS program and goals have been relocated to the User’s Guide,
Section U7.5.1.2 to enhance the EDR and ESPR Noise chapter’s overall readability, while Table I-16 in
Appendix I, Section I.1.2 compares the effective runway use for the current reporting years to the
prior reporting year and the benchmark year.
2-9: Noise
It is noted that reduced-engine taxiing is encouraged but little additional detail is provided. How
often and by what means? How is success measured? If it’s not presently successful, is there a better
strategy? Do other windy airports have more successful strategies?
Reduced-engine taxiing procedures at Logan Airport are encouraged as a voluntary measure to reduce
noise impacts, particularly by minimizing engine use on the side of the aircraft closest to the
community. However, its implementation is subject to airline procedures, taxiway routings, and safety
considerations. The success of reduced-engine taxiing is measured through on-going coordination with
airlines and feedback from pilots. A survey conducted by Massachusetts Institute of Technology (MIT)
in cooperation with Massport and the FAA found that single-engine taxiing was widely used on arrivals,
but less frequently on departures due to safety and feasibility concerns, such as short taxi times.
Massport continues to explore strategies to enhance the effectiveness of noise reduction measures,
including reduced-engine taxiing, and stays informed about practices at other airports. The FAA and
Massport are involved in on-going research to address aviation noise, which includes exploring
alternative metrics and strategies. For further details, please refer to the 2023/2024 EDR , Section 7.4 of
Chapter 7, Noise , and the User’s Guide, Section U7.5.6 .
2-10: Noise
How successful have the efforts to maximize late-night over water operations been? What
percentage of eligible flights make use of the option? How could the number be improved? Has the
ban on nighttime engine run-ups and use of APUs been successful? How is success measured?
Massport has continued its efforts to maximize late-night over-water operations, aiming to minimize
noise impacts on surrounding communities. The preferential use of Runway 15R for departures and
Runway 33L for arrivals has been maintained through 2023 and 2024, to keep flights over Boston Comment Letters and Response to Comments B-25
B Boston Logan International Airport 2023/2024 EDR
Harbor and away from noise-sensitive areas. While specific percentages of eligible flights utilizing this
option are not detailed in the current documents, Massport is committed to on-going collaboration
with the FAA and airlines to enhance the effectiveness of these operations. This includes exploring new
technologies and procedures that could further increase the number of flights utilizing over-water
routes.
Regarding the ban on nighttime engine run-ups and the use of Auxiliary Power Units (APUs), Massport
has continued these restrictions through 2023 and 2024 as part of its efforts to minimize nighttime
noise. Success is measured through the Noise and Operations Monitoring System (NOMS), which
tracks compliance and noise levels at various community noise monitor locations around Logan
Airport. For more detailed information, please refer to the 2023/2024 EDR , Table 7-4 in Section 7.4 of
Chapter 7, Noise , and the User’s Guide, Section U7.5 .
2-11: Noise
We ask that the number of insulations be broken down by the years in which they were completed
for both the residences and schools.
As discussed in Comment A-64 in Appendix A, MEPA Certificate and Responses to Comments , the
2023/2024 EDR summarizes the RSIP’s implementation timeline and progress status from 2023 through
the end of 2024. The 2023/2024 EDR , Section 7.4.2 Chapter 7, Noise and the User’s Guide,
Section U7.5.2, discuss the RSIP’s goals and objectives in greater detail, progress data and years, and
also provide key project milestones with achievement status updates. See Table U7-4 the User’s
Guide, Section U7.5.2 for a list of schools treated under Massport’s RSIP between 1982 and 2004.
2-12: Climate Change
While sustainability and resilience actions are both appropriate responses to climate change, they
are not the same. Given the importance of each, we would recommend distinct chapters on
sustainability and climate resilience going forward.
As discussed in Comments A-8 and A-67 in Appendix A, MEPA Certificate and Responses to
Comments , the 2023/2024 EDR includes a new Chapter 11, Sustainability and Climate Resilience
which is dedicated to Massport’s climate resiliency reporting and initiatives with linking to other
Massport sustainability and resiliency resources. While these two distinct topics are collocated in the
same chapter, the chapter separates these discussions into two distinct sections, with sustainability
discussed in Section 11.1 , Section 11.3 focused on climate resilience, and a third section, Section
11.2 , devoted to Massport's Net Zero programs and initiatives. The chapter also introduces the new
Office of Climate Innovation and Resilience (OCIR), led by the Chief Climate and Resilience Officer,
which works in close partnership with senior staff from Capital Programs, Strategic Planning, Real Estate
Asset Management, and Aviation, and leads environmental and climate action at Massport, serving
stakeholders with innovative solutions that build climate resilience and cut emissions. Comment Letters and Response to Comments B-26
Boston Logan International Airport 2023/2024 EDR B
2-13: Climate Change
We would encourage a future chapter on resilience to focus explicitly on the plans and projects that
actively address the risks of extreme heat, intense precipitation, and coastal flooding including
efforts focused on employees, guests, operations, assets and adjacent properties.
As discussed in Comments A-8 and A-67 in Appendix A, MEPA Certificate and Responses to
Comments , the 2023/2024 EDR includes a new section in Section 11.3 of Chapter 11, Sustainability
and Climate Resilience , dedicated to Massport’s climate resiliency measures. Since 2013, Massport
has maintained and continuously enhanced a comprehensive set of climate resiliency measures to
protect critical infrastructure and surrounding communities from climate change impacts, including
extreme heat, intense precipitation, and coastal flooding and sea level rise. Climate resiliency is an
embedded practice in Massport’s planning, design, construction, and daily operations. In addition,
Massport has prioritized awareness, education, and training on climate resiliency for both internal staff
and external stakeholders, reinforcing its commitment to long-term sustainability and preparedness.
Massport collaborates with regional organizations, including the Massachusetts EEA, the ResilientMass
program, U.S. Army Corps of Engineers (U.S. ACE), and the City of Boston to share knowledge, align
goals, and advance initiatives to protect the community.
Chapter 11 reports the initiatives Massport has taken, and continues to take, to protect critical
infrastructure, maintain operational continuity, and safeguard employees and surrounding communities
from these evolving risks. Massport commits to providing updates on these initiatives in future EDR
and ESPR filings and via the Net Zero website.
2-14: Climate Change
We request that EDRs and ESPRS include the annual Sustainability and Resiliency Report and that it
be prominently posted in the Environmental section of Massport’s website.
As discussed above in Comments 2-12 and 2-13 and in Comments A-8 and A-67 in Appendix A,
MEPA Certificate and Responses to Comments , the 2023/2024 EDR includes a new section in
Chapter 11, Sustainability and Climate Resilience, dedicated to Massport’s climate resiliency
measures, with information on the initiatives Massport has taken and continues to take. Massport
commits to providing updates on these initiatives in future EDR and ESPR filings and will continue
reporting on sustainability initiatives and progress through the recently launched [WEBSITE NAME /
HYPERLINK] website.
2-15: Environmental Justice
Section 2.3.2.2 should be edited to reflect that the Massport CAC was established by the
Massachusetts General Court in 2014.
Massport will review the referenced section in the 2022 ESPR and revise as appropriate, as well as
confirm this information is presented correctly in the 2023/2024 EDR and the User’s Guide. Comment Letters and Response to Comments B-27
B Boston Logan International Airport 2023/2024 EDR
2-16: Ground Access to and From Logan Airport
We have never seen the MassDEP Rideshare survey results and there is no reason to expect that it
would address the issues of an urban airport comprehensively. Detailed information about outreach
strategies and their relative success should be provided in EDRs and ESPRs.
Detailed information on Massport’s outreach efforts and strategies to promote HOV and Shared Ride
use are provided in Sections 6.1 and 6.4 of Chapter 6, Ground Access , and the efficacy of these
programs are also provided in the Logan Air Passenger Ground Access Survey reports for 2022 and
2024, summarized in Section 6.5 of Chapter 6, and available online for the public here:
https://www.massport.com/logan-airport/about-logan/air-passenger-survey .
Below are some highlights of the outreach strategies and their relative success for air passengers.
Updates on employee outreach initiatives are provided in response to Comment 2-17.
Massport has fully implemented Ride App shared ride incentives in partnership with Uber™ and Lyft™
to reduce Ride App vehicles through gateways by increasing vehicle occupancies. The Rematch
Program matches drivers dropping off passengers with passengers seeking pick-up, thereby increasing
the number of drivers leaving the Airport with a passenger customer. Massport implements a $3.25
per-trip fee for the Ride App. In March 2025, Massport signed an agreement with Lyft™ and Uber™ to
increase the per trip fee to $5.50, while shared rides will be subject to a lower fee of $1.50 per trip. Ride
App pick-up and drop-off transaction counts are provided in Section 6.1.4 of Chapter 6 , and these
have continued to increase each year, while the number of rental car and taxi dispatch transactions
continues to decrease each year.
Massport is currently constructing approximately 1,000 additional parking spaces at the Framingham
Logan Express garage site. The Peabody Logan Express was relocated to Danvers in 2023, and a new
Danvers Logan Express facility will be completed by 2028, providing more parking for both passengers
and employees and encouraging Logan Express use.
HOV ridership data demonstrating usage trends is provided in Section 6.1.2 and Section 6.1.3 of
Chapter 6. HOV use among Logan Express Bus, MBTA Transit, and Water Transportation increased in
2023 and 2024, except for private water taxi use, which has substantially decreased over time, and the
MBTA Silver Line, which increased ridership in 2023 but remained close to the same ridership in 2024.
2-17: Ground Access to and From Logan Airport
We believe Massport should detail the current status of the TMA beginning with the following
information:
• the number of employers on the airport;
• the number of employees who commute to a job at the airport;
• the number of employers that were members of the TMA in 2019, 2020, 2021 and 2022; Comment Letters and Response to Comments B-28
Boston Logan International Airport 2023/2024 EDR B
• the range of services offered/sponsored by the TMA in 2019, 2020, 2021 and 2022, utilizing a
checklist, with at least the following categories;
o subsidized transit pass,
o subsidized fares for HOV use (enumerate - ex. Logan Express, commuter bus,
ferry/water shuttles),
o free shuttle services-identify all,
o subsidized shuttle services (identify all and specify subsidy),
o secure bicycle parking protected from the elements,
o showers and changing rooms,
o ride matching service (explain process),
o number of three-person (or more) car/vanpools, and
o guaranteed ride home for commuters who qualify as walkers, transit-, HOV-, or
bicycle-users (we do not see Logan Express as a blanket guaranteed ride home).
Section 6.4 of Chapter 6, Ground Access presents current employee ground transportation initiatives
and parking programs and initiatives. Massport continues to adopt comprehensive ground
transportation initiatives for employees traveling to and from Logan Airport. The ground transportation
strategy is designed to offer a choice of HOV, transit, and shared-ride options that are convenient and
reliable, and that reduce environmental and community impacts.
Massport designates preferred parking for hybrid and electric vehicle (EV) charging stations. The
Economy Garage is not directly connected to the terminals; therefore, Massport offers a free, 24-hour
shuttle bus service between the garage and the terminals.
Massport offers employee parking in Chelsea, along with free shuttle bus transportation to the Airport.
The shuttle bus to the Terminals (Route 77) operates 24 hours a day, seven days a week. Massport also
provides an employee parking lot at Wonderland, the Blue Line terminus in Revere, with shuttles to the
Airport. In 2023, Massport opened a new employee park-and-ride lot in Quincy, offering shuttle service
to the Airport. Logan Express sites operate early-morning and late-night bus service to encourage use
and better serve Logan Airport employees. Massport offers reduced employee rates to promote the
use of Logan Express facilities. Massport also supports the Sunrise Shuttle, which provides early-
morning bus service for employees from East Boston and parts of Winthrop and Revere before the start
of MBTA service.
In addition to providing a $300 per month subsidy to Massport employees for MBTA, Commuter Rail,
Logan Express bus service, and water taxis, Massport also operates free shuttle buses between Airport
Station and employment areas in the Southwest Service Area and the South Cargo Area locations
(Routes 44, 66, and Logan Office Center). Free shuttle buses operate between the MBTA Airport Station
and the Terminals (Routes 22, 33, 55, and 88). Comment Letters and Response to Comments B-29
B Boston Logan International Airport 2023/2024 EDR
Massport maintains a comprehensive sidewalk and walkway system at Logan Airport to facilitate
pedestrian access and circulation. Bicycle racks are available at Terminal A, Terminal E, the Logan Office
Center, the Signature General Aviation Terminal, the Economy Parking Garage, the Green Bus Depot,
and the Airport MBTA Blue Line Station. Covered (sheltered) bike parking is provided at Terminal A, the
Rental Car Center, and the Economy Parking Garage. Covered shelter bike parking is provided at
Terminal A, the Rental Car Center, and the Economy Parking Garage. Massport also provides showers
and changing facilities at the Logan Office Center for its employees.
Massport advises Airport employers on transit benefits, including transit subsidies, and provides
information on available commuting alternatives, ride-matching services, and reduced-rate HOV and
transit fare options. Massport also provides its employees with subsidies for water transportation and
transit use. Consistent with Logan Airport transportation management goals, Massport offers financial
support for the Sunrise Shuttle and other benefits as noted above.
2-18: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: Does Massport provide free and/or subsidized parking to its employees? If
there are charges to riders, please explain. If, for example, carpool or vanpool vehicles are offered
incentives, please identify them.
As discussed above in Comments 2-16 and 2-17, and in Comment A-61 in Appendix A, MEPA
Certificate and Responses to Comments , Section 6.4.4 of Chapter 6, Ground Access , and the User’s
Guide, Sections U6.5.4 , Massport has implemented several employee ground transportation and
parking programs and initiatives.
Massport provides a free, 24-hour shuttle bus service between the Economy Garage and terminals;
employee parking in Chelsea with free shuttle bus transportation to the Airport; and free shuttle buses
between Airport Station and employment areas in the Southwest Service Area and the South Cargo
Area locations (Routes 44, 66, and Logan Office Center). Massport also advises Airport employers on
transit subsidies and reduced-rate HOV and transit fare options, in addition to providing Massport
employees with subsidies for water transportation and transit use.
Massport continues to adopt comprehensive ground transportation initiatives for employees traveling
to and from Logan Airport. The ground transportation strategy is designed to offer a choice of HOV,
transit, and shared-ride options that are convenient and reliable, and reduce environmental and
community impacts. An update and comparison of recent ground access conditions are presented in
Sections 6.1 of Chapter 6 .
2-19: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: How many parking spaces does Massport provide off of the airport for its Comment Letters and Response to Comments B-30
Boston Logan International Airport 2023/2024 EDR B
employees and where are the off-airport spaces located? Is 2,448 the correct number of on-airport
spaces available to Massport employees?
Incentives for Massport employees are discussed above in Comments 2-17, 2-18, and A-61 in
Appendix A, MEPA Certificate and Responses to Comments , and Section 6.4.4 of Chapter 6,
Ground Access , presents the current employee parking spaces inventory, and 2,448 is the correct
number of allowed on-Airport spaces for employees. Of the 2,448 spaces allowed, 2,360 spaces were in
service in 2023, and 2,304 spaces were in service in 2024.
2-20: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: How do employees access the airport from those parking locations? If they are
served by shuttles, please indicate the hours and frequency of operation. If this does not include
Park N Ride locations, please identify the Park N Ride locations served by shuttles.
As noted in Table 6-11 of Chapter 6, Ground Access , Massport provides employee parking in Chelsea
with free shuttle bus transportation to the Airport. Massport offers reduced employee rates to
encourage the use of Logan Express facilities. Additional early morning and late-night bus service has
been added to Logan Express sites to promote use and better serve the schedules of Logan Airport
employees. Massport supports the Sunrise Shuttle, which provides early morning bus service for
employees from East Boston and parts of Winthrop and Revere before the start of MBTA service.
2-21: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: How many employee showers and employee changing areas serve employees
on the airport, where are they located, and how are employees made aware of them? Are they
available 24-hours/day?
Massport also provides showers and changing facilities for its employees within the Logan Office
Center at 1 Harborside Drive, which are part of the building’s fitness center. This information is included
on Massport’s careers website here: https://www.massport.com/working-here/benefits . Other showers
and changing facilities are available for tenants and other employees, interspersed among Airport and
Massport facilities and close to employee work areas.
2-22: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: How often are free employee shuttles run from Airport Station to employment
areas in SWSA and South Cargo Area?
Massport operates On-Airport Shuttle Routes 22, 33, and 55 between the MBTA Airport Station (Blue
Line) and the Rental Car Center (RCC), located in the Southwest Service Area (SWSA). Routes 22 and 33
run daily from 9:00 AM to 10:00 PM, while Route 55 provides service during early morning and late Comment Letters and Response to Comments B-31
B Boston Logan International Airport 2023/2024 EDR
evening off-peak hours. Route 66 connects the MBTA Airport Station (Blue Line) to the Water
Transportation Dock, near the South Cargo Area. This route operates daily from 5:00 AM to 11:00 PM.
On-Airport Shuttle information and route details are found at: www.massport.com/logan-
airport/getting-to-logan/on-airport-shuttle.
2-23: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: What are the transit & water shuttle subsidy rates for Massport employees?
Comment A-61 in Appendix A, MEPA Certificate and Responses to Comments , Chapter 6, Ground
Access , Section 6.4.4 , and the User’s Guide, Sections U6.5.4 , Massport has implemented several
employee ground transportation and parking programs and initiatives. Massport offers reduced
employee rates to encourage the use of transit and water shuttle facilities, and provides a $300 per
month subsidy to employees for transit. More information is provided here:
https://www.massport.com/working-here/benefits
2-24: Ground Access to and From Logan Airport
Massport should provide information about TDM and Massport employees as outlined in the
following questions: Is the ‘new’ employee Park N Ride in Quincy for employees who use the
Braintree Logan Express? If so, how do they get to the Logan Express?
In 2023, Massport opened a new employee park-and-ride lot in Quincy, offering shuttle service to the
Airport. The Braintree Logan Express service capacity for air passengers was increased in the short term
by relocating employees to a new, dedicated park-and-ride lot in Quincy. Employees are picked up by a
Logan Express bus directly from this lot, but they must show their employee identification before
boarding the vehicle.
2-25: Ground Access to and From Logan Airport
Each EDR and ESPR should provide some basic information about TDM measures that are available
to employees with specific information from employees sought through a periodic (we suggest
annual) survey. We believe that a commitment to doing a survey on a scheduled basis is necessary
to ensure attention to this issue and are requesting that each EDR/ESPR provide detail about the
most recent employee survey to include: date, a copy of the survey tool, method of administration,
number of respondents, and a table of answers. The survey should not be limited to asking about
current transportation habits but should also be used to assess what additional methods might
encourage employees not to drive, particularly in SOVs. To start, we suggest a check-list of existing
amenities/measures and employees should be asked if they are aware of them and if they are made
available
Massport appreciates the thoughtful suggestions provided regarding TDM measures and employee
surveys. Massport recognizes the importance of soliciting employee input and continually improving Comment Letters and Response to Comments B-32
Boston Logan International Airport 2023/2024 EDR B
transportation options and amenities. These recommendations will be considered as part of on-going
planning efforts to enhance access, encourage sustainable commuting, and better serve Logan
Airport employees in the future.
2-26: Ground Access to and From Logan Airport
We ask that the following TDM measures be considered as part of a standard, comprehensive plan
by all employers if they are not already offered:
• Free or subsidized transit pass
• Reduced-fee Logan Express-needs to indicate charges for employee parking and bus ticket
• Guaranteed Ride Home program - needs not to be Logan Express (see notes below)
• A ride-matching service for employees who may want/need to commute by car and are
looking to carpool/vanpool
• Advantageous (on-airport) parking for carpoolers (3 or more employees)/vanpoolers
• Free shuttle from off-site car/vanpool parking locations in addition to Chelsea
• Bicycle amenities/programming (see notes below)
• Showers and changing rooms in various areas of the airport; some available 24-hours, with
safe transportation to work locations
As discussed above, in particular the response to Comment 2-17, as well as in Comment A-61 in
Appendix A, MEPA Certificate and Responses to Comments , Chapter 6, Ground Access , Section
6.4.4 , and the User’s Guide, Sections U6.5.4 , Massport has implemented several employee ground
transportation and parking programs and initiatives. Those listed here have been discussed in the
comment responses immediately preceding this response.
2-27: Ground Access to and From Logan Airport
We suggest that a bicycle storage room (perhaps with a repair station), showers and changing
rooms be part of the 4,300-space parking garage to be built in front of Terminal E. In addition, we
suggest consideration of employee parking spaces for verified three- or more person carpools and
vanpools in easy on- and off- locations in the new garage.
Massport appreciates these suggestions and will evaluate the feasibility of incorporating these
recommendations into future planning discussions for other on-airport facilities. As for the Terminal E
Garage’s 4,300 spaces, the preliminary design process considered current on-Airport parking
conditions and reconfirmed the need for additional commercial parking spaces to encourage
passenger long-term parking at the Airport, rather than drop-off and pick-up trips. Logan Airport is
primarily an Origin and Destination (O&D) market, and the majority of passengers look for
transportation modes that can accommodate luggage. As such, these recommendations for
improvements focused on commuting employees would likely be more effective at other on-Airport Comment Letters and Response to Comments B-33
B Boston Logan International Airport 2023/2024 EDR
facilities, which Massport will take into consideration during the planning and development process for
future onsite facilities.
2-28: Ground Access to and From Logan Airport
We suggest that the Website post a one-page Master Schedule that would allow for [Logan Express]
passengers to quickly assess potential options. It’s also not clear if the very early and very late trips
are exclusively for employees and serve limited sites or if they serve all sites and are open to anyone
who has a ticket. Clarification on the nature of these trips would be helpful.
Massport has a single-page schedule that covers all five Logan Express locations on the Massport
website (https://www.massport.com/logan-airport/getting-to-logan/logan-express). As of this filing,
the current schedule for the five service offerings is available at LEX Schedules 1Aug2024 . The schedule
is updated as service changes occur. Passengers can find real-time information and updates on bus
locations and arrival times on the website https://www.massport.com/logan-airport/getting-to-
logan/bus-locator. Alternatively, they can download the FlyLogan app and use the bus locator feature
to track when buses are due to arrive.
2-29: Ground Access to and From Logan Airport
We would also suggest a [Logan Express] site in the area of JFK/UMass.
The MBTA Red Line stops at the JFK / UMass Station and is an approximately six-minute ride to South
Station, where the Silver Line’s SL1 service provides direct access to each Logan Airport terminal. SL1
service frequency is every 9 to 13 minutes, depending on the time of day. Silver Line buses are
articulated, 60-foot vehicles with on-board storage areas for luggage. Silver Line (SL1) service from
Logan Airport is free, as are transfers to the Red Line subway service at South Station. Massport offers
free Silver Line boardings at the Airport, and the free-fare program is expected to continue indefinitely.
In addition to surveys from prior years, the 2024 Logan Air Passenger Ground Access Survey informs
Massport’s evaluation of Logan Express sites. It supports a data-driven planning process for changing
or expanding service options. As discussed above and in other comments, recent Massport initiatives
have successfully encouraged Logan Express’ use and improved its overall capacity. Information on
these projects is found in Sections 4.1.3 through 4.1.5 of Chapter 4 , Airport Planning . Additional
Logan Express service details are found in Section 6.1.2.1 of Chapter 6, Ground Access .
2-30: Ground Access to and From Logan Airport
While there are inherent benefits to taking a bus to the airport, the Airport Security Line Priority is
an additional incentive. It is identified in some materials as a benefit of using Logan Express, but we
would like clarity on the current status of the program.
Back Bay Logan Express piloted priority airport passenger security line status for riders when operations
at Back Bay restarted in October 2022. The priority program, Ticket to Skip, continues to be available to Comment Letters and Response to Comments B-34
Boston Logan International Airport 2023/2024 EDR B
Back Bay Logan Express and water transportation riders. Section 6.1.2 of Chapter 6, Ground Access ,
provides information regarding Logan Express and water transportation initiatives.
2-31: Ground Access to and From Logan Airport
We suggest planning for certain remote sites to become TSA security screening locations so that
passengers can clear security and check baggage which will be transported separately and securely
to Logan…We suggest asking on the next air passenger survey if this level of convenience would
entice passengers to use this kind of service.
The Transportation Security Administration (TSA) holds the responsibility and authority to conduct
security screening of travelers and baggage, and the TSA manages secure facilities with specialized
equipment within Logan Airport for this purpose. In summer 2026, Massport will initiate a reservation-
based pilot program of a remote access terminal at the Logan Express facility in Framingham. Should
the pilot program be successful, and with the cooperation of TSA, Massport’s next step would be
evaluating the feasibility of rolling out the remote terminal model to other Logan Express facilities.
2-32: Ground Access to and From Logan Airport
We would like Massport to address the following questions about these sites. Are there safe, indoor
waiting areas available for the earliest passengers and for those whose flights may arrive late and
may, therefore, delay ultimate passenger pick up? How does Logan Express work for the suburban
sites when flights are delayed and arrive after the last bus is scheduled to leave Logan? Given that
passengers don’t have reservations on Logan Express, are they then left on their own to get from
Logan to Framingham at 2 am, for example? Is this tracked somehow?
The Logan Airport terminals, prior to TSA security checkpoints, remain open 24 hours a day, seven days
a week, and offer safe, indoor waiting areas for early morning and late-night passenger arrivals.
The latest scheduled arrivals for flights to Logan Airport generally occur before 12 am, and the last
Logan Express bus service for Braintree, Framingham, Danvers, and Woburn destinations is 1:15 am for
Terminal A and a few minutes after 1:15 am for the other terminals. The last SL1 bus departs Logan at
1:18 am on weekdays and 2:15 am on Fridays and Saturdays. The previous Back Bay bus leaves at 10
pm.
Tickets can be purchased online for future travel and do not expire or restrict travel times as long as
the buses are still running for a given day, so reservations are not necessary, and passengers can still
board the bus to return to their original Logan Express station if flights are delayed. While safe, indoor
waiting areas are provided at each Logan Express location, these may not remain open late at night or
very early in the morning.
Should passengers miss the last bus departure, traditional ground transportation services, such as taxis
and ride-sharing app services, remain available. The number of passengers who miss the previous Comment Letters and Response to Comments B-35
B Boston Logan International Airport 2023/2024 EDR
departing bus and are unable to use Logan Express services due to delayed flights is not currently
tracked.
2-33: Ground Access to and From Logan Airport
Do we know why Peabody wasn’t more popular? Does Danvers address deficiencies that were
present in Peabody?
Massport relocated the Logan Express facility from Peabody to Danvers to improve service reliability
and address operational limitations. The Peabody site experienced low ridership, constrained parking
capacity, and reduced service frequency, which limited its effectiveness. The Danvers facility, which
opened in August 2024, offers expanded parking, enhanced regional access via Route 128 and I-95,
and permanent infrastructure designed to support long-term operations. This relocation strengthens
Massport’s commitment to providing efficient and accessible Logan Express service to North Shore
communities.
2-34: Ground Access to and From Logan Airport
What remains unclear is, how does Massport document the number of air passengers in any vehicle?
The Logan Airport Air Passenger Ground Access Survey has been Massport’s primary tool for
understanding the changes in air passenger travel behavior, including ground access mode choices,
travel patterns, and market characteristics. The survey data help determine how many air passengers
are traveling together in the same ground-access vehicle among the various automobile modes. In
2024, the survey asked respondents how they arrived at Logan Airport and how many people were in
the vehicle. These responses for passengers per vehicle were weighted according to the methodology
outlined in Section 2.4, Sample Weighting, of the 2024 Logan Air Passenger Ground Access Survey .
2-35: Ground Access to and From Logan Airport
In general, how are RideApp operations tracked?
The Logan Air Passenger Ground Access Survey has been Massport’s primary tool for determining how
many air passengers are traveling together in the exact ground-access vehicle among the automobile
modes, including Ride App vehicles. Details on the survey and its methodology are provided in the
User’s Guide, Section U6.4 , and the results for the 2024 Logan Air Passenger Ground Access Survey are
included in the 2023/2024 EDR , Section 6.5 of Chapter 6, Ground Access .
In addition to the survey, Ride App trip data is also provided to Massport by transportation network
companies Uber™ and Lyft™. Massport maintains an internal dashboard tracking monthly Ride App
statistics and trends, including the number of deadhead trips. The internal dashboard aids Massport in
planning future Ride App operations policy. Counts of automobile transportation modes for 2023 and
2024 are included in Section 6.1.4 of Chapter 6 , and information on the Ride App Management is
presented in the 2023/2024 EDR , Section 6.4.1 of Chapter 6. Comment Letters and Response to Comments B-36
Boston Logan International Airport 2023/2024 EDR B
Massport also plans to conduct a study to collect dwell-time data from Ride App operations, which
make up approximately 27 percent of Logan Airport’s ground transportation vehicle counts, in
designated pick-up areas within Logan Airport’s parking garages. The study’s data and results will
augment the data provided by the Ride App companies and help refine operations tracking procedures
in the future.
2-36: Ground Access to and From Logan Airport
How do things work for black car limousines so that Massport has an accurate count?
Since the late 1970s, the Logan Air Passenger Ground Access Survey has been Massport’s primary tool
for understanding the changes in air passenger travel behavior, including ground access mode choices,
travel patterns, and market characteristics. The survey data help determine how many air passengers
are traveling together in the exact ground-access vehicle among the various automobile modes. This
helps with understanding travel characteristics for arriving via private vehicles, rental vehicles, taxis,
Ride App services, and other car services, such as limousines. Details on the survey and its
methodology are provided in the User’s Guide, Section U6.4 , and the results for the 2024 Logan Air
Passenger Ground Access Survey are included in the 2023/2024 EDR , Section 6.5 of Chapter 6, Ground
Access .
2-37: Ground Access to and From Logan Airport
What specific strategies have been identified to meet the goals of the RideApp Management Plan
(2020/2021 EDR)? We have gleaned that the dedicated drop-off/pick-up in the Central Garage and
reduced fees for shared rides are being relied upon to increase RideApp shared rides, reduce
deadhead trips and reduce congestion. How are potential riders made aware that sharing a trip
would save them money? How does Massport quantify the improvement it makes in congestion and
in a related drop in GHG emissions?
As discussed in Comment A-52, Massport has implemented a Ride App Management Plan since 2017
to facilitate the sustainable use of ride app services at Logan Airport. The strategy has implemented
programs, including Ride App rematch, introducing rideshare, and developing a Ride App fee structure
to support HOV. Roadway and garage projects have also included plans for centralization for Ride App
pick-up and drop-off to help support shared rides, reduce deadhead trips, and reduce curbside
congestion. Refer to 2023/2024 EDR , Section 6.4.1 of Chapter 6, Ground Access , for more
information on the Ride App Management Program, and see Table 6-8 for a summary of the Ride App
initiatives implemented and their overall efficacy.
2-38: Ground Access to and From Logan Airport
Please identify other RideApp strategies and describe what success looks like, how is it quantified?
As mentioned in Comment 2-37, details on the Ride App Management Program and its progress are
found in the 2023/2024 EDR , Section 6.4.1 of Chapter 6, Ground Access , and the strategies Comment Letters and Response to Comments B-37
B Boston Logan International Airport 2023/2024 EDR
implemented are summarized in Table 6-8 . As the program continues to develop and improve, more
background information on the program will be included in the User’s Guide, Section U6.5.1 .
2-39: Ground Access to and From Logan Airport
What does exploring RideApp Last Mile connections mean?
Ride App last-mile connections at Logan Airport refer to initiatives designed to integrate ride apps
(Uber™ and Lyft™) with other transportation modes, particularly Logan Express and other high-
occupancy vehicle (HOV) options to complete the final leg of a passenger’s journey to or from the
Airport. This initiative advances Massport’s goals of promoting sustainability, enhancing the passenger
experience, and reducing environmental impacts.
Ride App last mile connections aim to:
• Encourage shared rides, including rapid transit, to reduce congestion and vehicle volume.
• Promote Logan Express usage by integrating Ride Apps, allowing passengers to connect from
suburban transit hubs to the Airport.
• Support urban shuttle services to streamline connections and reduce single-occupancy (SOV) trips.
2-40: Ground Access to and From Logan Airport
How many parking spaces are in the co-located RideApp Pool Lot/Cell Phone Waiting Lot on Porter
Street? How is it monitored for idling and the five-minute idle law enforced?
The Cell Phone Waiting Lot was relocated in 2023 to a site across from Terminal E, as noted in Table
6-9 of Chapter 6, Ground Access . The Cell Phone Waiting lot contains 94 parking spaces.
Massachusetts General Law (MGL) requires vehicles to shut off engines when vehicles are stationary for
more than five minutes. Massport has enforcement mechanisms in place at the taxi, cell phone, Ride
App, bus, and limousine pool areas.
2-41: Ground Access to and From Logan Airport
How does Ride Rematch work, how has it been advertised and facilitated and how has success been
measured? What are the numbers?
Massport has implemented the Ride App Rematch Program as part of its Ride App management
strategy. The program allows drivers who have just dropped off a passenger to quickly pick-up another
passenger as part of the software app’s features for drivers. This initiative is fully implemented and has
been supported by infrastructure improvements, such as the creation of dedicated pick-up and drop-
off areas in the Central Garage and Terminal E Garage, which means Ride App drivers no longer have to
drive to the Cell Phone Waiting Lot, where they may sit with their cars idling, or drive around the
Airport while waiting for their next customer. Although recently implemented, Massport now maintains
an internal dashboard tracking monthly Ride App statistics and trends, including the number of Comment Letters and Response to Comments B-38
Boston Logan International Airport 2023/2024 EDR B
deadhead trips. The internal dashboard aids Massport in planning future Ride App operations policy,
and this data will inform future EDR and ESPR reporting.
Massport has actively advertised shared ride services through partnerships with transportation network
companies like Uber™ and Lyft™. The success of these efforts is measured through the Logan Air
Passenger Ground Access Survey , which tracks changes in air passenger travel behavior, including
ground access mode choices and vehicle occupancies. The survey data, along with transaction counts
for Ride App pick-ups and drop-offs and curbside dwell time studies, are used to assess the
effectiveness of shared ride initiatives. In 2024, Ride App activity surpassed the 2019 benchmark year’s
activity by about 15 percent for pick-up transactions and 4 percent for drop-off transactions. Refer to
Section 6.4.1 of Chapter 6, Ground Access , Comment A-52 in Appendix A, MEPA Certificate and
Responses to Comments , and User’s Guide, Section U6.5.1 for further information on Ride App
management.
2-42: Ground Access to and From Logan Airport
What percentage of RideApp drivers who drop off a passenger or passengers stay on-airport to wait
for a passenger to leave Logan?
As discussed in Comment 2-41 above, although recently implemented, Massport now maintains an
internal dashboard tracking monthly Ride App statistics and trends, including the number of deadhead
trips. The internal dashboard aids Massport in planning future Ride App operations policy and this data
will inform future EDR and ESPR reporting.
The ability for a Ride App driver to immediately “rematch” or be dispatched from the Ride App pool
varies greatly by time of day and is most successful during the times when arriving and departing
aircraft are in balance. Overall, in 2023 and 2024 about 52 percent of drivers either rematched directly
at the curb or waited in the Ride App lot after dropping off a departing passenger.
2-43: Ground Access to and From Logan Airport
How have passenger-shared rides been advertised and facilitated and how successful have the
efforts been? How has success been measured?
Massport has actively promoted passenger-shared rides through partnerships with transportation
network companies like Uber™ and Lyft™. These efforts include implementing shared ride incentives to
increase vehicle occupancies and reduce congestion at Logan Airport. The Ride App management
strategy, detailed in Section 6.4.1 of Chapter 6, Ground Access in the 2023/2024 EDR, includes
initiatives such as the Ride App Rematch Program and centralized pick-up and drop-off locations to
facilitate shared rides.
Success is measured through the Logan Air Passenger Ground Access Survey , which tracks changes in air
passenger travel behavior, including ground access mode choices and vehicle occupancies. The survey
data help quantify improvements in congestion and reductions in greenhouse gas emissions. Comment Letters and Response to Comments B-39
B Boston Logan International Airport 2023/2024 EDR
Additionally, transaction counts for Ride App pick-ups and drop-offs are provided in Section 6.1.4 of
Chapter 6, showing an increase in shared ride usage over time.
2-44: Ground Access to and From Logan Airport
How are numbers obtained in order to calculate the 38.4% HOV mode share?
HOV mode share data is obtained through the Logan Air Passenger Ground Access Survey . The
complete 2022 Logan Air Passenger Ground Access Survey Section 2.0 presents the Study Methodology.
A total of 4,224 passengers across 437 flights participated in the survey. After reviewing and validating
the data, a total of 4,093 surveys were used. Detailed results of the 2022 survey are presented in
Section 4.0 of the report. The results of the 2024 Logan Air Passenger Ground Access Survey are
published on Massport’s website at: https://www.massport.com/logan-airport/about-logan/air-
passenger-survey and summarized in Section 6.5 of Chapter 6, Ground Access .
2-45: Ground Access to and From Logan Airport
We would like definitions for preferred parking and descriptions of how limousines, van services
and buses are notified of the incentives and how qualified vehicles are recognized. A summary of
the marketing and use of these incentives should be provided annually.
Massport defines preferred parking as designated spaces for hybrid and electric vehicles (EVs)
equipped with charging stations. Limousines, van services, and buses are notified of incentives through
direct communication channels, including email and industry meetings. Qualified vehicles are
recognized through a registration process that ensures compliance with Massport's environmental and
operational standards. Massport provides annual summaries of the marketing and use of these
incentives, which are detailed in Section 6.4 of Chapter 6, Ground Access .
2-46: Ground Access to and From Logan Airport
We request that Massport identify the locations of all chargers and any limits, if any, on who may
access and use them.
In January 2025, Massport updated the Sustainability Design Guidelines (SDGs) to align with the
Roadmap to Net Zero by 2031 . The electric vehicle (EV) charging services and capacity to be provided
will correspond to the needs of airport users, with considerations incorporated into the planning
process, including vehicle duration of stay on Airport property, parking space availability, and site
limitations such as available electrical capacity. Massport will continue to update plans for
accommodating EVs and the SDGs to meet increasing local and regional adoption of EV use.
Currently, more than 100 charging ports have been installed at Logan Airport and its Logan Express
sites. Of these, 60 were available for public use in 2024, with four located at Framingham Logan
Express, 46 located within the terminal area garages, and ten located in Economy Garage. See the Comment Letters and Response to Comments B-40
Boston Logan International Airport 2023/2024 EDR B
2023/2024 EDR , Section 6.4.2 of Chapter 6, Ground Access , and Section 11.2.3.3 of Chapter 11,
Sustainability and Climate Resilience for more information.
2-47: Ground Access to and From Logan Airport
We suggest that at least 15% of spaces in the new parking garage have a charging portal.
In January 2025, Massport updated the SDGs to align with the Roadmap to Net Zero by 2031 . The
electric vehicle (EV) charging services and capacity to be provided will correspond to the needs of
airport users, with considerations incorporated into the planning process, including vehicle duration of
stay on Airport property, parking space availability, and site limitations such as available electrical
capacity. Massport will continue to update plans for accommodating EVs and the SDGs to meet
increasing local and regional adoption of EV use. Of these, 60 were available for public use in 2024,
with 46 located within the terminal area garages and ten located in Economy Garage. See the
2023/2024 EDR , Section 6.4.2 of Chapter 6, Ground Access , and Section 11.2.3.3 of Chapter 11,
Sustainability and Climate Resilience, for more information.
2-48: Ground Access to and From Logan Airport
The surveying methodologies and results were not fully described in the ESPR. What was the 2022
Air Passenger Ground Access Survey protocol? What was the sample target? How many passengers
participated in the survey? For HOV users, ask about how many in their traveling party used and
HOV to get to Logan.
The complete 2022 Logan Air Passenger Ground Access Survey Section 2.0 presents the Study
Methodology. A total of 4,224 passengers across 437 flights participated in the survey. After reviewing
and validating the data, a total of 4,093 surveys were used. Detailed results of the 2022 survey are
presented in Section 4.0 of the report. The results of the 2024 Logan Air Passenger Ground Access
Survey are published on Massport’s website at: https://www.massport.com/logan-airport/about-
logan/air-passenger-survey and summarized in Section 6.5 of Chapter 6, Ground Access .
As discussed in 4D-36 and 4D-37 and in Comments A-56 and A-57, recent Massport initiatives have
successfully encouraged Logan Express’ use and improved its overall capacity. Information on these
projects is found in Sections 4.1.3 through 4.1.5 of Chapter 4 , Airport Planning. Additional Logan
Express service details are found in Section 6.1.2.1 of Chapter 6, Ground Access .
In addition to surveys from prior years, the 2024 Logan Air Passenger Ground Access Survey informs
Massport’s evaluation of Logan Express sites. It supports a data-driven planning process for changing
or expanding service options. These studies surveyed passengers on how they would respond to
various policy options and initiatives and evaluated how these policies would change passenger
decisions regarding Airport access modes. These results are published on Massport’s website at:
https://www.massport.com/logan-airport/about-logan/air-passenger-survey and summarized in
Section 6.5 of Chapter 6, Ground Access . Comment Letters and Response to Comments B-41
B Boston Logan International Airport 2023/2024 EDR
2-49: Ground Access to and From Logan Airport
We suggest that Massport make the most of this one opportunity to get information from
passengers and ask if their HOV trip was satisfactory and if there are improvements to HOV options
in general that would make them more attractive. Focusing on Logan Express should be
predominant.
As discussed in Comment A-56 in Appendix A, MEPA Certificate and Responses to Comments , the
2024 Logan Air Passenger Ground Access Survey informs future service adjustments and demand for
increased and expanded Logan Express facilities. Recent Massport initiatives have successfully
encouraged the use of Logan Express and improved overall capacity. The Braintree Logan Express
service capacity for air passengers was increased in the short term by relocating employees to a new,
dedicated park-and-ride lot in Quincy. The Braintree, Framingham, Woburn, and Back Bay Logan
Express service frequencies have been improved, and construction has begun for approximately 1,000
additional parking spaces at Framingham. Massport enhanced marketing efforts to increase ridership
and invested in a new, larger facility in Danvers to temporarily relocate the Peabody Logan Express.
Information on these projects is found in Sections 4.1.3 through 4.1.5 of Chapter 4 , Airport
Planning . Additional Logan Express service details are found in Section 6.1.2.1 of Chapter 6, Ground
Access .
2-50: Ground Access to and From Logan Airport
There are also no questions about the use of EV chargers at Logan and the survey would be an
opportunity to learn more about EV users. We suggest the following questions:
• Did you drive an electric vehicle (EV) to Logan and park it here during your trip?
• Did you park it and leave it at a charging station?
• How many kWh does your car need to charge?
• If you needed to charge your car when you left it, how much charging time did it need?
• If there had been a cost to charge your car and then move it to a preferred parking space
without a charger for your pick-up, would you still drive your EV to Logan?
As discussed in Comment A-56 in Appendix A, MEPA Certificate and Responses to Comments , the
2024 Logan Air Passenger Ground Access Survey informs future service adjustments and demand for
increased and expanded facilities. Massport appreciates this suggestion and will consider incorporating
this element into future survey efforts. Massport endeavors to ensure the EV charging services and
capacity provided corresponds to the needs of airport users, with considerations incorporated into the
planning process for vehicle duration of stay on Airport property, parking space availability, and site
limitations, such as available electrical capacity. Massport will continue to update plans for
accommodating EVs and the SDGs to meet increasing local and regional adoption of EV use. Comment Letters and Response to Comments B-42
Boston Logan International Airport 2023/2024 EDR B
3. Town of Milton
Comment Letters and Response to Comments B-4 3
3-1
3-4
3-6
3-5
3-3
3-2
3-7
3-8
3-9
3-10 Comment Letters and Responses to Comments B-44
3-11 Comment Letters and Responses to Comments B-45
3-12 Comment Letters and Responses to Comments B-46
3-13
3-14
3-15
3-16 Comment Letters and Responses to Comments B-47
3-17
3-18 Comment Letters and Responses to Comments B-48
3-19
3-20
3-21
3-22
3-23 Comment Letters and Responses to Comments B-49
Comment Letters and Responses to Comments B-50
Comment Letters and Responses to Comments B-51
Comment Letters and Responses to Comments B-52
Comment Letters and Responses to Comments B-53
3-24 Comment Letters and Responses to Comments B-54
Comment Letters and Responses to Comments B-55
Comment Letters and Responses to Comments B-56
Comment Letters and Responses to Comments B-57
Comment Letters and Responses to Comments B-58
Comment Letters and Responses to Comments B-59
Comment Letters and Responses to Comments B-60
Comment Letters and Responses to Comments B-61
Comment Letters and Responses to Comments B-62
Comment Letters and Responses to Comments B-63
Comment Letters and Responses to Comments B-64
Comment Letters and Responses to Comments B-65
Comment Letters and Responses to Comments B-66
Comment Letters and Responses to Comments B-67
Comment Letters and Responses to Comments B-68
Comment Letters and Responses to Comments B-69
Comment Letters and Responses to Comments B-70
Comment Letters and Responses to Comments B-71
B Boston Logan International Airport 2023/2024 EDR
Town of Milton Responses to Comments
3-1: Logan Airport Environmental Review and Planning
We urge the EEA and the DPH to engage with Massport, the FAA, and the affected overflight
communities to achieve meaningful solutions to the public health issues that the FAA's
concentration of flight paths has created for overflight communities such as Milton.
As discussed above and in Comments A-1 and A-5 in Appendix A, MEPA Certificate and Responses
to Comments , Massport is committed to collaborating with communities, state agencies, and local
officials to address environmental concerns associated with Logan Airport operations. To that end,
Massport is an active participant in the MEPA’s Logan Airport Work Group (Work Group) established in
collaboration with the Massachusetts Environmental Policy Act (MEPA) Office and the Office of
Environmental Justice & Equity (OEJE) in February 2025. The Work Group’s primary objective is to
assess and discuss potential supplemental mitigation measures that could address environmental
concerns associated with Logan Airport operations among environmental justice (EJ) communities.
Section 7.4.1 of Chapter 7, Noise , summarizes how Massport, the Federal Aviation Administration
(FAA), the Massport Community Advisory Committee (Massport CAC), and Massachusetts Institute of
Technology (MIT) have continued to collaborate on how to successfully design and implement Area
Navigation (RNAV) procedures that comply with the 2016 memorandum of understanding (MOU)
between Massport and the FAA. Implementing the Block 1 and 2 procedures requested by the
Massport CAC and affected communities, which confines flight tracks to within a defined noise
abatement corridor area of more compatible land use.
In 2025, Massport won the 2025 Jay Hollingsworth Speas Airport Award for Logan Airport for “excellent
collaborative work by MIT and Massport to reduce aircraft noise for residents under Boston Logan
International Airport approach paths while simultaneously reducing fuel burn and distance traveled.
The award recognizes the collaborative effort between the FAA, Massport, and MIT to identify potential
modifications to RNAV procedures, conduct outreach with community groups and operational
stakeholders, and implement the procedures following FAA review.
3-2: Logan Airport Environmental Review and Planning
Not to certify the 2022 ESPR, and to direct Massport to prepare a supplemental ESPR which fully and
realistically addresses projected increases to Logan operations and airport throughput, and the
resulting environmental impacts.
Massport remains dedicated to identifying and pursuing opportunities to improve forecasting and
environmental conditions reporting practices; however, Massport’s current methodologies exceed
prevailing FAA and current industry standards in both rigor and transparency. Massport recognizes the
importance of reporting accurate, comprehensive data and will continue to refine approaches to better
serve both stakeholders and impacted communities. Comment Letters and Responses to Comments B-72
Boston Logan International Airport 2023/2024 EDR B
3-3: Noise
Direct Massport to demand that the FAA test and implement all of the recommendations in Block 1
and Block 2 of the recent MIT Study, and specifically those relating to Runways 4R and 27.
As discussed in Comment A-63, A-65, and A-66 in Appendix A, MEPA Certificate and Responses to
Comments , Massport, the FAA, the Massport CAC, and MIT have continued to collaborate on how to
successfully design and implement Non-Area Navigation (RNAV) procedures that comply with the 2016
MOU between Massport and the FAA. As discussed in Appendix I , Noise Supporting Documentation,
Section I.8 , implementing the Block 1 and 2 procedures requested by the Massport CAC and affected
communities has resulted in the recent 2023 Runway 27 Standard Instrument Departure (SID) update,
which confines flight tracks to within a defined noise abatement corridor area of more compatible land
use and reduces the impacts from aircraft overflight noise.
The FAA completed a Noise Screening Analysis Report for Logan Airport’s proposed RNAV SID in May
2024, concluding that there were no reportable or significant noise impacts, and that the update meets
NEPA compliance. In a presentation to the Massport CAC in August 2024, the FAA also confirmed the
Runway 9/27 SID update and implementation of Block 1 and 2 procedures has achieved the MOU goal
to confine at least 68 percent of flight tracks to within a defined noise abatement corridor area of more
compatible land use. Block 2 departure procedures were published on November 30, 2023 and
modified the RNAV departures to include a speed restriction, which enables aircraft to turn to the east
earlier in their departures and shifts aircraft tracks to the north and away from Hull. For more detailed
information, please refer to the 2023/2024 EDR , Table 7-4 in Section 7.4 of Chapter 7, Noise , and the
User’s Guide, Section U7.5 .
3-4: Noise
Work with the FAA, Massport, and Milton to develop and implement late-night aircraft overflight
restrictions which are protective of Milton and its residents, including consideration of an 11 :00 PM
to 6:00 AM landing prohibition on Runways 4R and 4L.
Massport appreciates the Town of Milton and its residents' concerns regarding late-night aircraft
overflight restrictions and noise. Massport is committed to working collaboratively with the FAA and
local communities to explore feasible noise abatement strategies that align with safety and operational
requirements. Currently, Massport implements several noise abatement measures, including nighttime
runway use restrictions and prioritization of late-night over-water operations to minimize noise impacts
on surrounding communities. The use of Runways 4R and 4L is subject to operational constraints,
including wind and weather conditions, which are critical for safe aircraft operations.
Massport continues to engage with the FAA and the Massport CAC to evaluate and implement noise
mitigation strategies, including the potential for additional restrictions or procedural adjustments. For
more detailed information on noise abatement strategies and runway use, please refer to the
2023/2024 EDR , Section 7.4 of Chapter 7, Noise and the User’s Guide, Section U7.5 . Comment Letters and Responses to Comments B-73
B Boston Logan International Airport 2023/2024 EDR
3-5: Noise
Direct Massport and the Massport Community Advisory Committee ("MCAC") to promptly develop
a system for the fair and equitable distribution of aircraft overflights that provides real relief to the
highly impacted surrounding communities, especially those that are under multiple RNAVs (defined
herein).
Massport, in collaboration with the FAA and the Massport CAC, is committed to exploring feasible
solutions to address overflight noise concerns while also maintaining air safety and operational
efficiency, and Massport continues to engage with the Massport CAC and other stakeholders to
evaluate and implement noise mitigation strategies, including potential procedural adjustments to
more equitably distribute overflights. As discussed in Comment 3-3 and Section 7.4.1 of Chapter 7,
Noise in the 2023/2024 EDR and Section I.4.5 of Appendix I , Noise Supporting Documentation , the
FAA and Massport have implemented several RNAV procedures, including RNAV SIDs and approaches
for various runways, such as Runway 22L/R and Runway 33L, which are designed to keep traffic over
water and away from densely populated areas. The RNAV Pilot Project also includes developing RNAV
procedures to confine flight tracks to defined noise-abatement corridors, thereby reducing the
concentration of noise over specific areas. For more detailed information, please refer to the 2023/2024
EDR , Table 7-4 in Section 7.4 of Chapter 7, Noise , and the User’s Guide, Section U7.5
3-6: Logan Airport Environmental Review and Planning
Direct Massport to collaborate with DPH and DEP to develop and conduct noise and air pollution
studies in highly impacted surrounding communities, especially those that are under multiple
RNAVs.
EDRs and ESPRs provide areawide noise and emissions environmental data that focus on areas within
the arrival and departure paths. For more information, refer to Section 2.4 of Chapter 2, Outreach
and Environmental Justice, which presents a new section: “Public Health Existing Conditions Review”.
As discussed above in Comment 3-1, and in Comments A-1 and A-5 in Appendix A, MEPA Certificate
and Responses to Comments , Massport is committed to collaborating with communities, state
agencies, and local officials to address environmental concerns. Massport is an active participant in the
MEPA’s Logan Airport Work Group (Work Group) whose primary objective is to assess and discuss
feasible supplemental mitigation measures that could address environmental concerns associated with
Logan Airport operations among EJ communities.
Chapter 7, Noise , Section 7.4.1 , RNAV Procedures summarizes how Massport, the FAA, the Massport
CAC, and Massachusetts Institute of Technology (MIT) have continued to collaborate on how to design
and implement RNAV procedures successfully, implementing the Block 1 and 2 procedures requested
by the Massport CAC and affected communities, which confines flight tracks to within a defined noise
abatement corridor area of more compatible land use. Comment Letters and Responses to Comments B-74
Boston Logan International Airport 2023/2024 EDR B
3-7: Logan Airport Environmental Review and Planning
Direct Massport to consider off-airport noise and pollution impacts, including but not limited to the
health impacts from increased and concentrated arrival and departure operations due to RNAVs, in
all communities under any RNAV, in all future EDRs and ESPRs.
The Executive Office of Energy and Environmental Affairs (EEA) Secretary’s Certificate guides Massport’s
preparation of each EDR and ESPR. Each EDR and ESPR includes a detailed analysis of noise and
emissions impacts of aircraft arrivals and departures. The FAA is responsible for developing and
implementing RNAV procedures and has prepared a Federal Environmental Assessment (EA) under the
National Environmental Policy Act (NEPA) to consider the environmental and operational effects of
RNAV procedures. The FAA continues to support the evaluation of those procedures. As directed by
the Secretary, the EDR presents “any data used to measure the effectiveness of these improvements,
including the number of noise complaints from the previously impacted areas.”
EDRs and ESPRs provide areawide noise and emissions environmental data that focus on areas within
the arrival and departure paths. For more information, refer to Section 2.4 of Chapter 2, Outreach
and Environmental Justice, which presents a new section: “Public Health Existing Conditions Review”.
3-8: Logan Airport Environmental Review and Planning
Direct Massport to include all of the points made above in the scope of the 2022 ESPR…includes
impacts to health from noise and pollution from: off-airport impacts of growth, cumulative impacts
of RNAV overflights, increased nighttime operations, moving to updated noise measurements which
are more protective of human health and which account for acute impacts more realistically than
the DNL standard; and working directly with impacted communities to more fully understand and
evaluate the human health effects from Logan operations.
As discussed in Comment 3-7 above, the EEA Secretary’s Certificate guides Massport’s preparation of
each EDR and ESPR. Each EDR and ESPR includes a detailed analysis of noise and emissions impacts of
aircraft arrivals and departures. The FAA is responsible for developing and implementing RNAV
procedures and prepared a federal EA under NEPA to consider the environmental and operational
effects of RNAV procedures, and continues to support the evaluation of those procedures. As directed
by the Secretary, the EDR presents “any data used to measure the effectiveness of these improvements,
including the number of noise complaints from the previously impacted areas.”
EDRs and ESPRs provide areawide noise and emissions environmental data that focus on areas within
the arrival and departure paths. For more information, refer to Section 2.4 of Chapter 2, Outreach
and Environmental Justice , which presents a new section: “Public Health Existing Conditions Review”.
3-9: Noise
Include the hours from midnight to 7:00 AM in the dwell and persistence calculations to provide a
clearer indication of the noise burden being borne by communities subject to nighttime operations. Comment Letters and Responses to Comments B-75
B Boston Logan International Airport 2023/2024 EDR
Currently, the Day-Night Average Sound Level (DNL) metric, which is the primary means for evaluating
the annual noise environment around Logan Airport, already accounts for nighttime noise by applying
a 10 dB penalty to noise events occurring between 10:00 PM and 7:00 AM. This adjustment reflects the
increased sensitivity to noise during nighttime hours. However, Massport’s noise abatement strategies
consider adopting possibly better analysis tools, noise research findings, and improved modeling
techniques, as well as enhancements to the noise analysis method, after evaluating the feasibility and
potential benefits of incorporating additional metrics or adjustments to existing calculations. For more
information, please refer to the 2023/2024 EDR , Chapter 7, Noise , Section 7.1.2 and the User’s
Guide, Section U7.1 .
3-10: Environmental Justice
For future public health existing conditions reviews and future ESPRs and EDRs, direct Massport to
include impacts to environmental justice ("EJ") populations that are located in overflight
communities.
As discussed in Comment A-39 in Appendix A, MEPA Certificate and Responses to Comments , the
2023/2024 EDR revised the content organization to dedicate Chapter 2, Outreach and Environmental
Justice, exclusively to EJ, outreach, and community conditions and Massport’s beneficial measures. The
2023/2024 EDR , at the direction of MEPA, utilized Massachusetts Department of Environmental
Protection (MassDEP)’s Cumulative Impact Analysis (CIA) framework to assess existing public health
conditions within 1 mile of Logan Airport. These findings are presented in Chapter 2, Section 2.4, and
the detailed data is included in Appendix E, Environmental Justice Supporting Documentation . The
User’s Guide, Section U2.3.1 provides the study’s methodology and assumptions. For future ESPRs
and EDRs, Massport will consider appropriate and scientifically supported methods to expand the
scope of the existing conditions assessment, thereby more accurately capturing potential
environmental impacts.
3-11: Activity Levels
Direct Massport to consider, for future ESPRs and EDRs, the impacts of emerging advanced air
mobility ("AAM") technology on communities overburdened by operations at Logan.
Advanced air mobility (AAM) operations near airports can offer significant benefits to communities,
including enhanced connectivity, reduced ground vehicle congestion, and faster transportation options.
These benefits can positively impact local economies, potentially leading to innovative transportation
solutions and job creation in new sectors. However, potential noise impacts, increased air traffic, new
emissions sources, and airspace safety and management could be issues for neighboring communities.
Therefore, when AAM becomes a more tangible transportation service option at Logan Airport,
Massport will address this new technology and its possible effects on surrounding communities with
the same diligence and concern as other transportation modes operating within Massport facilities. Comment Letters and Responses to Comments B-76
Boston Logan International Airport 2023/2024 EDR B
3-12: Environmental Justice
We urge you to require Massport, in future ESPRs and EDRs, to cast a much wider net in reviewing
impacts on EJ populations and overflight communities generally.
Massport is committed to working with MEPA to advance EJ and public health analysis within the EDRs.
In addition to the existing public health conditions assessment discussed above in Comments 3-8 and
3-10, as well as in Comment A-39 in Appendix A, MEPA Certificate and Responses to Comments ,
Massport will consider appropriate and scientifically backed methods to expand the scope of the
existing conditions assessment to more accurately capture environmental impacts that may be
associated with Airport operations. For more information, refer to the 2023/2024 EDR Chapter 2,
Outreach and Environmental Justice Section 2.3 and Section 2.4 and Appendix E, Environmental
Justice Supporting Documentation . The User’s Guide, Section U2.3.1 provides the study’s
methodology and assumptions.
3-13: Noise
We reiterate our prior comment that the FAA's civil aviation noise policy (the "Noise Policy"), which
relies on DNL 65 dB as its sole noise metric, is outdated and wholly inappropriate to measure noise
in the PBN/RNAV context.
Evaluation of aviation noise is guided by FAA policies and regulations. Notwithstanding the referenced
report, the FAA has yet to revise its federal noise policy. Massport will adjust its noise impact analyses
in accordance with updates provided by the FAA. Massport continues to present a range of
supplemental noise metrics in an effort to broaden the assessment of noise impacts beyond the DNL
65 dB metric. For more detailed information, please refer to the 2023/2024 EDR , Chapter 7, Noise ,
Section 7.1, and the User’s Guide, Section U7.2 .
3-14: Noise
We continue to urge real and substantive collaboration between Massport, the Secretary, the FAA,
and the communities impacted by Logan overflights.
As discussed in Comment A-66 in Appendix A, MEPA Certificate and Responses to Comments ,
Massport continues to coordinate with FAA and the Massport CAC on matters related to noise. For
more detailed information on the Massport Noise Abatement Management Plan and associated
measures to reduce airport-related noise effects, please refer to the 2023/2024 EDR , Table 7-4 in
Section 7.4 of Chapter 7, Noise , and the User’s Guide, Section U7.5 .
3-15: Noise
These communities should have direct and regular access to Massport and the Secretary, and both
agencies should be willing to work on real and meaningful solutions to address the problems from
airport operations - especially noise and pollution - occurring in those communities. Comment Letters and Responses to Comments B-77
B Boston Logan International Airport 2023/2024 EDR
As discussed above and in Comments A-1 and A-5 in Appendix A, MEPA Certificate and Responses
to Comments , Massport is an active participant in the MEPA’s Logan Airport Work Group established
in collaboration with the MEPA Office and the OEJE in February 2025. The Work Group includes
representatives from state agencies, local officials, and community stakeholders and has a primary
objective to assess and discuss potential supplemental mitigation measures that may address concerns
among nearby communities.
Appendix A, MEPA Certificate and Responses to Comments , Comment A-66, summarizes how
Massport continues to coordinate with FAA and the Massport CAC on matters related to noise. For
more on Massport’s Noise Abatement Management Plan , please refer to the 2023/2024 EDR , Table 7-4
in Section 7.4 of Chapter 7, Noise , and the User’s Guide, Section U7.5 .
3-16: Activity Levels
However, as we noted in our 2019 comment letter on the 2017 ESPR, Massport has consistently
underestimated the increased number of airline operations and passenger throughput at Logan.
Massport follows industry best practices in preparing activity level estimates and future forecasts for
passenger activity levels and operations, considering several key factors, including economic
conditions, airplane manufacturers' plans, future aircraft in the fleet mix, social factors, and anticipated
airline route plans. The assumptions, data sources, and enhanced methodologies Massport currently
uses for these forecasts are documented in the User’s Guide, Section U3.4 . While Massport is
committed to refining its forecasting methodologies to reflect realistic growth estimates and actual
impacts more accurately, Massport’s current methodologies exceed prevailing FAA and current industry
standards in both rigor and transparency.
3-17: Activity Levels
Future ESPRs and EDRs must take into account AAM as it moves from the design stage to the
testing and implementation stages.
Massport actively participates in AAM planning through its partnership with the MassDOT Aeronautics
Division and a coalition of stakeholders selected by NASA. Massport contributes to infrastructure
planning, operational use case development, and regulatory integration to support the safe and
efficient deployment of AAM technologies across the state. Massport will continue to provide updates
on AAM engagement in future EDR and ESPR filings. When AAM becomes a more tangible
transportation service option at Logan Airport, Massport will address this new technology and its
possible effects on surrounding communities with the same diligence and concern as other
transportation modes operating within Massport facilities.
3-18: Noise
Like the 2017 ESPR, the 2022 ESPR does not discuss the importance of noise annoyance as a factor of
environmental impact and harm. Comment Letters and Responses to Comments B-78
Boston Logan International Airport 2023/2024 EDR B
As discussed in Comment 3-13, evaluation of aviation noise metrics is guided by FAA policies and
regulations. In EDR and ESPR filings, Massport continues to present a range of supplemental noise
metrics in an effort to broaden the assessment of noise impacts. For more on Massport’s Noise
Abatement Management Plan , please refer to the 2023/2024 EDR , Table 7-4 in Section 7.4 of Chapter
7, Noise , and the User’s Guide, Section U7.5 . Expanded discussion on annoyance factors was
developed for the new User’s Guide as well in User’s Guide, Section U7.1.2 .
3-19: Noise
We request that the Secretary work with the FAA, Massport, and Milton to implement late night
aircraft restrictions, similar to those set forth in 740 CMR 24.04, which are protective of Milton and
its residents, as well as EJ populations in and around Milton.
As discussed above in Comment 3-5, 3-4, and 3-14, and in Comment A-66 in Appendix A, MEPA
Certificate and Responses to Comments , Massport continues to coordinate with FAA and the
Massport CAC on the Logan Airport noise mitigation program and to evaluate and implement noise
mitigation strategies, including the potential for additional restrictions or procedural adjustments.
Currently, Massport implements several noise abatement measures, including nighttime runway use
restrictions and prioritization of late-night over-water operations to minimize noise impacts on
surrounding communities. Information on noise abatement strategies and runway use is provided in
the 2023/2024 EDR , Section 7.4 of Chapter 7, Noise and the User’s Guide, Section U7.5.1 .
3-20: Noise
Discuss restrictions on RNAV usage and routes that overfly residential neighborhoods, including
spreading the routes further so that the nighttime noise is less concentrated in residential
neighborhoods, or moving routes over the ocean during certain periods of time.
As discussed above in 3-3, 3-5, and 3-13, and in Comments A-63, A-65, and A-66 in Appendix A,
MEPA Certificate and Responses to Comments , Massport continues to coordinate with FAA and the
Massport CAC on Logan Airport noise mitigation initiatives. The 2023/2024 EDR , Section 7.4 of
Chapter 7, Noise , and the User’s Guide, Section U7.5.5 , include information on the Massport Noise
Abatement Management Plan and RNAV procedures.
3-21: Noise
There are already nighttime restrictions on arrivals to Runway 4L, we request the same restrictions
(no arrivals between 11 :00 PM and 6:00 AM) for Runway 4R.
As discussed above in 3-3, 3-5, and 3-13, as well as in Comment A-66 in Appendix A, MEPA
Certificate and Responses to Comments , Massport continues to coordinate with FAA and the
Massport CAC on the matters related to runway use and the on-going RNAV Pilot project. The
2023/2024 EDR , Section 7.4 of Chapter 7, Noise , and the User’s Guide, Section U7.5.5 , include
information on the Massport Noise Abatement Management Plan and RNAV procedures. Comment Letters and Responses to Comments B-79
B Boston Logan International Airport 2023/2024 EDR
3-22: Logan Airport Environmental Review and Planning
We request that the Secretary direct Massport, in conjunction with DPH and the Department of
Environmental Protection ("DEP"), to conduct noise and air pollution studies in Milton and other
overflight communities that receive a substantial number of low-flying arrival aircraft. This work
would be consistent with the evolving science on this point, and protective of the residents in these
communities.
Massport acknowledges the concerns regarding noise and air pollution in Milton and other overflight
communities. Massport has a history of collaborating with the Massachusetts Department of Public
Health (MassDPH) and other agencies to assess environmental impacts related to Logan Airport
operations. For instance, Massport supported the MassDPH study, which focused on the noise and air
quality impacts within a five-mile radius of Logan Airport. For more information, refer to Section 2.4 of
Chapter 2, Outreach and Environmental Justice, which presents a new section: “Public Health
Existing Conditions Review”.
As discussed above in Comment 3-1, and in Comments A-1 and A-5 in Appendix A, MEPA Certificate
and Responses to Comments , Massport is an active participant in the MEPA’s Logan Airport Work
Group (Work Group) whose primary objective is to assess and discuss feasible supplemental mitigation
measures that could address environmental concerns associated with Logan Airport operations.
Section 7.4.1 of Chapter 7, Noise , RNAV Procedures summarizes how Massport, the FAA, the
Massport CAC, and Massachusetts Institute of Technology (MIT) have continued to collaborate on how
to design and implement RNAV procedures successfully, implementing the Block 1 and 2 procedures
requested by the Massport CAC and affected communities, which confines flight tracks to within a
defined noise abatement corridor area of more compatible land use.
Massport remains committed to addressing environmental concerns and continues to engage in
studies and initiatives aimed at understanding and mitigating the impacts of aviation emissions. Recent
collaborations include studies conducted by Tufts University and Olin College, which focus on air
quality monitoring in communities near Logan Airport. Additionally, Massport is involved in on-going
research efforts with institutions such as Boston University and the FAA's ASCENT project, which
assesses the contributions of aviation emissions to ultrafine particle concentrations.
Massport will continue to collaborate with relevant stakeholders, including the Department of
Environmental Protection (DEP) and other community partners, to explore additional studies and
initiatives that align with the evolving scientific understanding and aim to protect the health and well-
being of residents in affected communities. Comment Letters and Responses to Comments B-80
Boston Logan International Airport 2023/2024 EDR B
3-23: Logan Airport Environmental Review and Planning
We further request that (a) the scope of future ESPRs and EDRs be expanded to consider the health
impacts from increased and concentrated arrival and departure operations due to RNAVs, and (b)
pollution data be measured for every community under any of the many Logan RNAVs.
As discussed above in Comment 3-8, the EEA Secretary’s Certificate guides Massport’s preparation of
each EDR and ESPR. Each EDR and ESPR includes a detailed analysis of noise and emissions impacts of
aircraft arrivals and departures. The FAA is responsible for developing and implementing RNAV
procedures and prepared a federal EA under NEPA to consider the environmental and operational
effects of RNAV procedures, and continues to support the evaluation of those procedures. As directed
by the Secretary, the EDR presents “any data used to measure the effectiveness of these improvements,
including the number of noise complaints from the previously impacted areas.”
EDRs and ESPRs are environmental data that focus on areas within the arrival and departure paths. For
more information, refer to Chapter 2, Section 2.4, which presents a new section: “Public Health
Existing Conditions Review”. Chapter 7, Noise , Section 7.4.1 , RNAV Procedures summarizes how
Massport, the FAA, the Massport CAC, and Massachusetts Institute of Technology (MIT) have continued
to collaborate on how to successfully design and implement RNAV procedures, which confine flight
tracks to within a defined noise abatement corridor area of more compatible land use.
3-24: Noise
b. Work with the FAA, Massport, and Milton to develop and implement late-night aircraft
overflight restrictions which are protective of Milton and its residents, including
consideration of an 11:00 PM to 6:00 AM landing prohibition on runway 4R.
c. Direct Massport and the MCAC to promptly develop a system for the fair and equitable
distribution of aircraft overflights that provides real relief to the highly impacted
surrounding communities, especially those that are under multiple RNAVs.
d. Direct Massport to collaborate with DPH and DEP to develop and conduct noise and air
pollution studies in highly impacted surrounding communities, especially those that are
under multiple RNAVs.
e. Direct Massport to consider off-airport noise and pollution impacts, including but not
limited to the health impacts from increased and concentrated arrival and departure
operations due to RNAVs, in all communities under any RNAV, in all future EDRs.
f. Direct Massport to include all of the points made above in the scope of the 2017 ESPR. This
includes impacts to health from noise and pollution from: off-airport impacts of growth,
cumulative impacts of RNAV overflights, increased nighttime operations, moving to
updated noise measurements which are more protective of human health and which
account for acute impacts more realistically than the DNL standard; and working directly Comment Letters and Responses to Comments B-81
B Boston Logan International Airport 2023/2024 EDR
with impacted communities to more fully understand and evaluate the human health effects
from Logan operations.
g. Include the hours from midnight to 7:00 AM in the dwell and persistence calculations to
provide a clearer indication of the noise burden being borne by communities subject to
nighttime operations.
Massport has responded to similar commentary in responses to the Town of Milton’s Comments within
this section and within the Appendix A, Logan Airport Environmental Review and Planning section
above, and in Comments A-63, A-65, and A-66 in Appendix A, MEPA Certificate and Responses to
Comments . The EEA Secretary’s Certificate guides Massport’s preparation of each EDR and ESPR. Each
EDR and ESPR includes a detailed analysis of noise and emissions impacts of aircraft arrivals and
departures. The FAA is responsible for developing and implementing RNAV procedures and prepared a
federal EA under NEPA to consider the environmental and operational effects of RNAV procedures and
continues to support evaluation of those procedures.
As directed by the Secretary, the EDR presents “any data used to measure the effectiveness of these
improvements, including the number of noise complaints from the previously impacted areas.” EDRs
and ESPRs are wide-area noise and emissions environmental data analyses that focus on areas within
the arrival and departure paths. Section 2.4 of Chapter 2, Outreach and Environmental Justice of
this 2023/2024 EDR also presents a new section: “Public Health Existing Conditions Review”. Chapter 7,
Noise , Sections 7.1 , 7.2 , and 7.4, and the User’s Guide, Sections U7.2 , U7.3 , and U7.5 include
information on these topics. Comment Letters and Responses to Comments B-82
Boston Logan International Airport 2023/2024 EDR B
4. Airport Impact Relief, Inc. (AIR, Inc.) Comment Letters and Responses to Comments B-83
To: EEA
From: AIR, Inc.
June 26, 2024
Good Morning,
I’m writing today to express deep concerns with Massport’s ESPR 2022 environmental
documentation. After the Climate Roadmap Law, the public had a right to expect improvements
on to many procedural complaints regarding Massport’s iterative disclosure series detailed
within comments to MEPA submitted by AIR, Inc. over many years.
Not only is the document NOT provided in a scalable, searchable format which is acceptable to
stakeholders whose only internet connectivity is provided through smart phone use, but its
length and complexity are still unacceptable. Unfortunately, it appears as though Massport has
used the climate Roadmap as an opportunity to take its reporting further in the wrong direction.
To this point I first call attention to the second chapter of the ESPR, titled Sustainability,
Outreach and Environmental Justice . This chapter is a new addition to the document series
which is intended to address Massport’s responsibilities pursuant to the Climate Roadmap and
recommendations in previous EEA certificates. In Ch 2, Massport misclassifies environmental
justice as among ‘informal’ or voluntary commitments by asserting that ‘formal’ mitigation
commitments are made as part of projects for which MEPA review is required.
The formal versus voluntary classification when applied to the ESPR / EDR series supports
Massport’s assertion that the document series are not subject to MEPA review. AIR, Inc. plans
to challenge this on the grounds that such a conclusion could only be true if all impacts over the
expected lifetime of MEPA-level project proposal EIR’s had been evaluated within the EIR
review in accordance with the standard MEPA review protocols.
However, the Weld / Cellucci era regulatory procedure which has been hand-crafted for and is
unique to Logan removes air pollution emissions and noise impacts from consideration in the
EIR review process for Logan projects, displacing them into the iterative annual documentation
series. Importantly, the EDR / ESPR documents subsequently do not report air pollution and
noise data on a project by project basis. This combination of #1 removal of consideration of
public comment regarding environmental pollution from airport facilities project MEPA EIR
review, and #2 failure to specifically track, report and make available for public comment the
subsequent environmental pollution data of each individual project over time violates the state’s
environmental protection laws by denying the public a meaningful opportunity to comment on
decisions which hold the likelihood of increasing adverse environmental burdens.
For example, the Terminal E EIR theorized that demand for air travel is driven NOT by the
facilities Massport builds, but by a combination of external economic and industry conditions
outside of Massport’s control. AIR, Inc. objected to this claim in its comments, pointing out that
the new terminal was built to address capacity constraints and would allow the Authority to
process more passengers, increasing the negative environmental burdens. AIR, Inc. further
commented that alternatives to building the expanded terminal capacity at Logan -such as
offloading over-capacity demand to other regional commercial airports- existed, but were not
evaluated in the scoping process for the project.
The Authority counterclaimed that they had considered alternatives (full build, half build, no
build), and that if further congestion at Logan developed, the environmental consequences
would be worse without the newer, more efficient facilities. In essence this says that it’s better
when you are being polluted more, to at least be polluted by a smaller increase. Nowhere is
there an option not to be polluted more.
The result of the unique handling of Logan environmental filings under the regulatory review
procedure created by a Republican administration over 20 years ago, which was not included in
the recent MEPA regulatory review above AIR, Inc.’s objections, is that facilities get built to pave
the way for the growth of aviation activities at Logan without any opportunity for public comment
on environmental impacts, then growth just ‘happens’, and pollution rises.
A related issue of great concern is that due to the use of long range forecasts to predict
passenger levels and associated impacts, when growth occurs at faster than forecasted rates,
mitigation plans lag behind. So in this system, not only does the public not get any opportunity
to comment on the projects which pollute them, nor do we ever receive specific data on the
environmental performance of those projects, but the airport as a whole as a project with a
rolling segmented growth agenda, is allowed to pollute first, and mitigate later.
All agencies under MGL Part I, Title III, Chapter 30, Section 61 are required to minimize
environmental damage. The fact that under an internationally ineffective regulatory system,
certain procedures allow EIR level environmental damage to be displaced into an iterative
annual review of cumulative impacts, does not change that. Nowhere in the statute is there any
grey area about who is required to minimize damage.
The law states: “All agencies, departments, boards, commissions and authorities of the
commonwealth shall review, evaluate, and determine the impact on the natural environment of
all works, projects or activities conducted by them and shall use all practicable means and
measures to minimize damage to the environment.” Massport is an Authority.
Thus, Massport is required to minimize damage and whether they report any determination of
damage before or after the fact, and whether they report damage in EIR’s, EDR’s, or ESPR’s,
when they report damage they are issuing a determination of environmental impact, and
therefore, they are required to issue findings that all feasible measures have been taken to
avoid or minimize that damage. Thus, classification of Logan Express (LEX) HOV efforts, for Comment Letters and Responses to Comments B-84
instance, as voluntary -which Massport does in the ESPR, is incorrect. Traffic congestion is an
environmental impact. LEX is designed to reduce that impact. Massport is required to reduce
that impact by the statue. Therefore LEX is not a voluntary environmental mitigation program. It
is required.
Regarding expanded public outreach:
Massport has scheduled a public information session for tonight. The location for tonight’s
meeting, the Cathy Leonard McLean room, does not satisfy the requirements of public meeting
space for environmental justice community public information meetings as provided by the
Public Involvement Protocol for Environmental Justice Populations found within the Interim
Protocol on Climate Change Adaptation and Resiliency as required by the Climate Roadmap
law, which outlines public involvement requirements for projects identified as negatively affecting
EJ populations and states that “The meeting(s) must be held at accessible locations near public
transit to the greatest extent possible and facilitate remote attendance, with oral interpretation
required with 48 hours' notice.”
Located 0.6 miles from the center of the Jeffries Point neighborhood, 1 mile from Maverick, 1.25
miles from Eagle Hill, 1.5 miles from Harborview, 1.8 miles from the Belle Isle Inlet area, and
2.15 miles from Orient Heights, the Cathy Leonard McLean Community room is unnecessarily
remote from most of the residential environmental justice areas in East Boston. Its location in
the airport’s service area is difficult to find with no wayfinding signage posted in and around the
area to assist meeting-goers on foot or in cars. This facility is also not located along any MBTA
bus or train line.
Massport’s government affairs and community relations staff have access to multiple
appropriate meeting venues centrally located within walking distance to most of residential East
Boston, all of which are also located along numerous bus routes reaching all neighborhoods of
East Boston, and many in Chelsea, Winthrop, and Revere, as well as on within blocks of the
Blue Line’s WoodIsland station. Venues including the East Boston Public Library, Excel
Academy, and Spinelli’s function hall all satisfy the requirements for environmental justice public
information meetings.
The timing of this public information meeting is also not ideal. Community stakeholders are
offered an extended 60 day public comment period for airport filings due to their length and
complexity. While public information sessions held prior to the release of the ESPR provided
brief snapshots of the full report’s contents, this 678 page technical document contains
voluminous detail and should be expected to illicit many questions once thoroughly read.
Holding a public information session 19 days after the inception of the comment period does not
give the public access to the full comment period to sufficiently read the document and
formulate questions.
Furthermore, any new information which might be provided in response to potential questions
would alter the document and require additional extension of the comment period to provide the
public with the time needed to analyze and respond accordingly.
4A-1
AIR, Inc. reiterates its comments made in previous EDR and ESPR’s as well as through our
involvement in the recent MEPA regulatory review, that neither MEPA’s standard 45 day nor its
extended 60 comment period provide anywhere near an appropriate opportunity for public
comment. These iterative documents take the Port Authority nearly a full year to develop and
are compromised of a wide variety of dense technical concepts which require extensive
analyses. We once again suggest that these environmental reporting documents be released in
final draft form prior to their release formal submission for MEPA review.
We believe the current handling of Massport’s Logan Airport environmental reporting violates
both the letter and the spirit of Massachusetts law as during the antiquated disjointed comment
and answer cycle, public stakeholders never get the opportunity to communicate objections
such as these directly to EEA, nor do we have the opportunity to consult with the state’s
regulatory leaders about our concerns.
We ask that EEA specifically address our belief that:
1. The EIR - EDR/ESPR arrangement is illegal in that it denies the public due process (lack of
opportunity to comment on environmental pollution from specific projects)
2. The long range impact forecasting system is illegal in that it allows environmental impacts of
Logan to go unreported when growth of airport impacts accumulates beyond forecasted levels
(failure to review, evaluate, and determine)
3. That Massport’s refusal to evaluate alternatives to building further capacity at Logan and
deferring and delaying of efforts to avoid and minimize impacts is illegal in that they are required
to prove that they are taking all reasonable means (failure to provide findings that all measures
have been taken)
We believe that at a minimum, the certificate for the 2022 ESPR should:
1. Require the Port Authority to provide data and respond to comment on the environmental
impacts of all projects individually over time
2. Review, evaluate, and determine environmental impacts in real time by yoking policy and
mitigation planning to actual present and future impacts
3. Require the Authority to provide findings that all environmental mitigation efforts have been
and are being taken to minimize said environmental damage by developing and implementing
real time mitigation strategies by or before the time impact increases are realized
4 Require the Authority to report all mitigation efforts along a continuum of formal measures
required to minimize or avoid environmental damage
5 Require the Authority to release its next report closer to the end of the reporting period, and
then it’s next again closer
4A-8
4A-7
4A-6
4A-5
4A-4
4A-3
4A-2 Comment Letters and Responses to Comments B-85
6 Require the Authority to release a final draft report with a complete comment cycle
These are our thoughts for now. AIR, Inc. thanks you for your consideration of the above listed
concerns. We would also like to schedule a time to meet with the Secretary or her staff privately.
The last attempt we made to do so ended up to be a cbit version including MEPA, and
Massport. And while we appreciate ld that opportunity, we believe that our concerns would be
better addressed in discussion with EEA exclusively.
Sincerely,
Chris Marchi
Vice President
Airport Impact Relief, Incorporated
AIR, Inc.
161 Saratoga Street
East Boston, Ma 02128
[removed]
[removed]
4A-9 Comment Letters and Responses to Comments B-86
From: Chris Marchi
To: Hughes, Jennifer (EEA)
Subject: Supplemental AIR, Inc. comment
Date: Friday, October 11, 2024 6:55:26 PM
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do
not click on links or open attachments unless you recognize the sender and know the content is safe.
RE employee use of Logan Express:
AIR, Inc. believes that Logan Express must be reimagined as a high end transportation service. We understand that
employee use of the service is sometimes as much as 50% of certain location’s ridership. We believe that detailed
investigations into the user experience and preferences of air travelers would reveal that commingling industrial
employees is penny wise and pound foolish.
High volumes of airport employees could potentially compete and conflict with air travelers. Massport should
commit to providing a level comfort and relative luxury commensurate with the requirements of modern air travel as
well as to providing appropriate basic transportation options to its employees.
Sent from my iPhone
4B-1 Comment Letters and Responses to Comments B-87
CAUTION: This email originated from a sender outside of the Commonwealth of
Massachusetts mail system. Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
From: Chris Marchi
To: Hughes, Jennifer (EEA)
Subject: Supplemental AIR, Inc. comments
Date: Friday, October 11, 2024 6:31:23 PM
RE PRAS:
Massport continues to report in the Preferential Runway Assignment System, a computer
program written in the 1980’s, which sought to balance impacts at runway ends by setting
target annual arrival and departure percentages considering population density at runway ends
and calculating population weighted impacts. This Runway Use Program (RUP) produced
runway use recommendations for Air Traffic Controller.
PRAS was in informal RUP, meaning that acceptance of PRAS suggestions was
voluntary. However PRAS was extremely sophisticated in its design. Not only did it set target
runway use goals, and factor in population weighted impacts at runway ends, it also placed
limits on Dwell and Persistence -which respectively limited the the time over any one runway
end that overflights could dwell to under 6 hours in any 24 hour period and the duration of
persistence of overflights over any one runway end to less than 23 hours in any 72 hour
period. Not of these limits directly address traditional core complaints in noise impacted
communities about getting pounded with noise for unbearable periods of time.
The city of Boston suggests that we should eliminate this reporting. We understand the city’s
frustration with reviewing data for a program which is not in use. Only in the absurdly elusive
confines of an Massport environmental report could such a practice be explained. Instead,
however, AIR, Inc. recommends not that we give in to the futility which is the result
Massport’s divisiveness
-and eliminate PRAS reporting, but that we should double down on our convictions that we
can and must do better, and require Massport to live up to its obligations to update and
implement an effective Runway Use Program, which FAA gives them the authority and
procedural power to create.
PRAS is an avenue to fair sharing of noise burdens which equates to the very important
concept of minimizing overburden. Massport is legally bound to continue PRAS by the 2002
FAA Record of Decision which ordered Massport to update PRAS or continue to use it until it
is replaced. The ROD specifically directed this, as well as a study of Boston Logan Airport
noise known as BLANS, the Boston Logan
Airport Noise Study to ensure that EJ communities under the 33L departure runway end in
East Boston’s Eagle Hill and Chelsea would not be adversely affected by runway use
configuration changes as a result of construction of controversial runway 14/32.
The feared impact has in fact materialized, with EJ communities in East Boston and Chelsea at
the
33L runway end getting between two and three times the target noise after 14/32.
Instead of updating PRAS as required, Massport suggested to the Logan Community Advisory
4C-1
Committee that they should vote to abandon PRAS (over AIR, Inc.’s objections) and then
launched into an underfunded effort to replace the well thought out PRAS with a a rotational
runway use plan which would have potentially subjected the same communities to the worst
(most burdensome) noise exposure on a daily basis. The LCAC could not agree on a
replacement RUP. And so Massport has not satisfied the ‘u til replaced’ condition, leaving the
Authority legally bound by the FAA ROD to co ti is use of PRAS.
Massport should not be let off the hook for its responsibilities. Instead, it should be required to
update PRAS and seek its proper implementation.
Chris Marchi
AIR, Inc.
4C-2 Comment Letters and Responses to Comments B-88
October 11, 2024
The Honorable Rebecca Tepper,
Secretary Executive Office of Energy and Environmental Affairs
Attn: MEPA Office
100 Cambridge Street, Suite 900,
Boston, Massachusetts 02114
Re: Logan Airport 2020 / 2021 Environmental Status and Planning Report (2022 ESPR) EEA#
3247
Dear Secretary Tepper,
Airport Impact Relief, Incorporated (AIR, Inc.) thanks you for the opportunity to comment on the
Massport 2022 Logan Airport Environmental Status and Planning Report (the ESPR, the
Report, the Document). AIR, Inc. is a community volunteer-led 5013C established in 1981, by
East Boston resident airport activists of the 1960’s. We organize meetings, analyze airport plans
and reports, consult with our members and experts in related fields, and conduct community
engagement to promote understanding of the environmental impacts of Logan Airport.
AIR, Inc. participates in the Massachusetts Environmental Policy Act (MEPA) process to
contribute the perspectives of the environmental justice communities which are exposed to the
most severe impacts. Development of AIR, Inc.’s Logan comments involves reading,
researching, fact-checking and analysis and discussions of key topics, formulation of comments,
drafting, sharing, gathering feedback from other EJ agencies, final revision, sharing and
promoting understanding of the issues within the community, and organizing community action
when necessary. Unfortunately, the preliminary review, analyses and drafting efforts for the
massive documents Massport continues to submit absorbs most of the comment period, leaving
very little time for engagement of EJ communities.
Aviation topics can be technical and abstract. AIR, Inc. strives to make our comments as
informative as possible, designing them to explain not only perspectives on Logan’s impacts
and Massport policies, but also to provide insights into aviation topics not included in the ESPR,
but which have bearing on the review process. While these comments are very much focused
on Massport’s failures, AIR, Inc.’s goal is to advocate for improved environmental outcomes. For
this reason, these comments include numerous examples of programmatic and policy
alternatives not discussed in the ESPR, but which could significantly reduce environmental
impacts of Logan Airport.
We recognize and regret the extreme length of these comments. AIR, Inc. has implored
Massport and MEPA to reform this disclosure document series -particularly through streamlining
and improving the filings’ organization, but also by ceasing to pollute the important discussions
with unhelpful pro-aviation industry narratives. In all cases, the Port Authority has failed.
Instead, the Authority seems determined to use the ESPR as a public relations platform. For
instance, the Authority ingrains the word ‘efficiency’ throughout the entire ESPR, making over
123 references to the word ‘efficient’ or its derivatives. The Authority goes out of its way to
explain heating, ventilation, lighting and water fixture efficiencies, and insists through the report
that modern aircraft are quieter and more fuel efficient, and that more people will travel on less
flights, …increasing efficiency. They claim that increases in seat capacity utilization rates, and
multiple on airport projects are aimed at increasing Logan’s ability to efficiently handle
passengers. Landside, airside, regional, airline networks, roadways… every possible efficiency
claim is made. Regarding engine technology, Massport recites qualitative future benefits over
and over, saying that newer engines are cleaner and quieter and more efficient at every
possible opportunity. It is clear that the intention is to lean on the theory that technological
improvements will keep pollution under control.
We cannot neglect to comment on these transgressions, or else we risk that MEPA and the
Secretary will think we agree with Massport’s claims. Therefore, throughout our comments, we
must explain how Massport’s framing of concepts such as their postulations and implications
that improving efficiency will bring less pollution, noise and public health impacts are incorrect.
These comments will show that Massport’s claims are simply statements -nothing more than
opinions, and that they are not based on facts.
Impacted communities are interested in quantifiable net impact reduction. The public looks to
the ESPR to learn how much more or less noise, traffic, and emissions impacts might be, as
well as how the Port Authority can combat potential increases. These comments will also detail
how the Port Authority totally fails to explain basic facts and industry trends which are essential
to understanding airport planning options. And we will provide the lacking explanations and offer
examples of feasible alternative planning and mitigation options.
So throughout these comments, we must highlight the multiple misleading narratives Massport
has submitted, and correct them. Consider that Massport states that ‘enhancing the airports
roadways can lead to vehicular circulation efficiency’. But, are Logan’s roadways actually
becoming more efficient? Can this be even while Logan’s roads are increasingly choked with
traffic? Throughout these comments we point out that Massport’s intent is to mislead, parsing
words to tell us what could be, while stating that the opposite is happening. This trend is
repeated over and over in the ESPR to the extent where it is clearly not an accident, but instead
is an intended initiative to report that environmental conditions are improving even while
submitting data that show that environmental impact levels have not been, and will not be
improving.
We encourage most readers of these comments to browse through the table of contents and
read the sections which are of the most interest. To MEPA, we apologize for the length of these Comment Letters and Responses to Comments B-89
comments, and suggest that the Secretary demand reform in the circuitous, duplicitous and
inappropriate style of Massport’s submissions.
Environmental Justice
Plain language
Document format
Airport Activity levels
Regulatory approach
Airport Planning
RE Regional Airport Cooperative Planning
Organizational approach
EXAMPLE: Zero Idling Policy failure
Compliance
Commitment and timetables
Establishment of a collaborative framework
Engagement of EJ communities in document development
Accepting public input before ESPR submission
Identifying metrics and thresholds that would trigger mitigation
Response to request for assessment of socialized costs
Possibilities
Mitigation possibilities
EXAMPLE: Airproofing program
EXAMPLE: Air Quality Sensor Network
EXAMPLE: Remote airport terminals
EXAMPLE: Logan transit hubs
EXAMPLE: Tourism and climate
EXAMPLE: Impact Triggered Mitigation
Noise
Predicted impacts
Technological improvements
Backsliding
Nightime noise
Noise Mitigation
School soundproofing
Climate
Climate Backsliding
Sustainable aviation fuel
Underestimated carbon impacts
Emissions
Modeling
Reporting practices
Backsliding
Upgauging impacts
Standards
Fuel efficiency
Pollutant data
VOC
NOX
Particulate matter (PM)
CO
Ultrafine particulate pollution
Regional Transportation
Regional economic impacts
Rail
Public Health
Ground Access
Data gaps
Logan Express
Air traveler survey
Ride apps Comment Letters and Responses to Comments B-90
Environmental Justice
Regarding environmental justice and the AuthThe text goes on. The rest is in the file.
related records
Records whose documents say similar things, nearest first.
- Air & noiseMassachusetts Port AuthorityLogan Airport Environmental Data Report, 2018 and 2019
- Air & noiseMassachusetts Port AuthorityLogan Airport Environmental Data Report, 2020 and 2021
- Air & noiseMassachusetts Port AuthorityLogan Airport Environmental Status and Planning Report, 2022
- Air & noiseMassachusetts Port AuthorityLogan Airport Environmental Status and Planning Report, 2017
- Air & noiseMassachusetts Port AuthorityLogan Airport Environmental Data Report, 2016