MPO Meeting Minutes
Draft Memorandum for the Record
Boston Region Metropolitan Planning Organization Meeting
February 6, 2020 Meeting
10:00 AM–12:30 PM, State Transportation Building, Transportation Board Room, 2nd Floor, 10 Park Plaza, Boston
Steve Woelfel, Chair, representing Stephanie Pollack, Secretary, and Chief Executive Officer, Massachusetts Department of Transportation (MassDOT)
The Boston Region Metropolitan Planning Organization (MPO) agreed to the following:
See attendance on pages 14 and 15.
There were none.
S. Woelfel announced Benjamin Muller as the new liaison to MPO staff in the Office of Transportation Planning (OTP) at MassDOT.
There were none.
L. Diggins reported that the Advisory Council will host Josh Ostroff from Transportation for America at its next meeting on February 12, 2020.
T. Teich reported that staff have held several successful “MPO 101” events for onboarding new MPO board members and have compiled an online list of resources for members.
T. Teich announced new hires at CTPS: Leila Azizi, Transportation Modeler; Marty Milkovits, Associate Director of Regional Modeling and Analysis, and Ariel Patterson, Transportation Planner in the Certification Activities group.
T. Teich reported that staff hosted a successful first meeting of the MPO’s pilot Transit Working Group. Many representatives of transit providers and other agencies in the region participated. MPO staff are planning another meeting for late spring.
This work program is a request from the MBTA to provide service planning support and access to the travel demand model. The Haymarket Station Redevelopment project is a continuation of the 2012–13 Bullfinch Crossing project. The focus of the work program is to support the MBTA in examining the transit impacts associated with the development. Short-term assistance involves
a) bus service planning for a relocated Haymarket Bus Terminal;
b) analysis of Haymarket Station if a temporary closure is necessary; and
c) analysis of bus rerouting if a temporary closure of Congress Street is needed.
Long-term assistance includes forecasting demand for
Haymarket Station in 2040 and in 2060, given the projected density of the site
with 700 new housing units, a hotel, office space, retail, and 6,000 employees.
This work is estimated to cost $65,000, and take one year to complete.
Daniel Amstutz (At-Large Town) (Town of Arlington) asked about the timeline of the Congress Street closures. S. Peterson says it will start later this year or early next year, depending on how much analysis is required.
L. Diggins asked who the key stakeholders are. S. Peterson replied that stakeholders include HYM Construction, the City of Boston, the MPO board, and the MBTA. L. Diggins asked that members of the public and the Advisory Council be involved in the early stages so that they can provide feedback.
Jay Monty (At-Large City) (City of Everett) expressed the importance of keeping the MPO board in the loop on progress because this is a critical urban area.
T. Teich stated that the scope of this project for CTPS does not include direct engagement with the public. S. Peterson added that the MBTA is forming a working group that would be tasked with the public engagement components for the project. CTPS is acting in a support and analysis role.
David Koses (At-Large City) (City of Newton) asked if any transit studies were required as part of the project’s approval process. S. Peterson replied that in 2011, MBTA data was used for transit analysis but that data is now outdated and needs refreshing.
Tom Bent (Inner Core Committee) (City of Somerville) asked a question about mitigation contributions from the project’s developer. S. Peterson said he was not involved in this aspect of the project and deferred to the City of Boston and the MBTA.
Jim Fitzgerald (City of Boston) (Boston Planning & Development Agency) explained more about the project’s outcomes including the public process and the overall review process.
T. Bent suggested that the project incorporate intersection improvements.
Steve Olanoff (Three Rivers Interlocal Council Alternate) asked about the project’s effects on pedestrians. S. Peterson stated that there will be substantial pedestrian improvements once the project is complete.
J. Fitzgerald described more of the project design and impact on pedestrians associated with garage removal and a redesigned bus terminal.
A motion to approve the work program for the Haymarket Station Redevelopment Analysis was made by the Metropolitan Area Planning Council (MAPC) (Eric Bourassa) and seconded by the MBTA Advisory Board (Brian Kane). The motion carried.
In 2016, CTPS conducted a study for the MassDOT OTP that identified segments of Greater Boston roadways where the installation of dedicated bus lanes would be the most beneficial for bus riders, as measured by the rate of delay that the riders encountered. As a follow-up to the 2016 study, the MBTA requests CTPS’ support in its introduction of additional bus lane corridors in the region to prioritize funding to the corridors with the greatest potential for significant reduction in bus passenger travel time. The categorizing of roadway segments into prioritization tiers will assist MBTA staff with the allocation of capital funds for bus lane construction, in coordination with municipal partners. CTPS will develop an interactive database and a guidebook on priority corridors for municipalities. The work program is funded by the MBTA. It is estimated to take eight months to complete and cost $82,245.
T. Bent asked whether the project will assess impacts on traffic flow from bus lane installation. J. Belcher replied that this is not included in the scope of work and deferred to Wes Edwards, Assistant General Manager of Service Development for the MBTA. W. Edwards confirmed by restating project scope and the MBTA’s goals. He said that the next step of the project, once priority lanes are identified, is to study traffic impacts on all transportation modes and coordinate with cities and towns on implementation.
D. Amstutz asked about public involvement, partnerships with external entities, and the approach to identifying priority bus lanes in targeted corridors. J. Belcher said this information will be determined in final product.
Tom Kadzis (City of Boston) (Boston Transportation Department) asked for further explanation of why traffic analysis is not included in the CTPS study, whether the results will be released publicly, and whether municipalities would be responsible for conducting the traffic analysis. W. Edwards responded that the MBTA does not have the capacity to do analysis of all intersections in the 51 cities and towns, so the first step is to identify priority areas and then do a traffic analysis of those areas.
T. Kadzis suggested that the MBTA include some basic information in their outreach explaining to municipalities this is a multistage project. W. Edwards acknowledged his input.
B. Kane stated that that board was getting ahead of itself in regards to traffic analyses, and confirmed that municipalities will be involved in the project at later stages, but first identification of priority areas is need. B. Kane asked J. Belcher to keep in mind the costs to municipalities and the MBTA for ongoing maintenance.
D. Koses asked if the unselected corridors on the map handout were already determined as nonpriority routes. J. Belcher said it is a fair assumption, due to volume and rider delay, as these corridors did not pass the MBTA’s delay threshold. However, municipalities can still ask for further analysis.
T. Teich reminded the board that they approved funding for dedicated bus lane infrastructure in the latest Long-Range Transportation Plan (LRTP), and municipalities are welcome to bring priorities to the table via this process if corridors are not prioritized in this work scope.
Brandon Wilcox (Federal Highway Administration) asked about the implementation of dedicated bus lanes in Medford, and whether there are any plans to look back at the initial analysis once lanes are implemented to validate the assumptions of the study. J Belcher said there is no traffic analysis within the scope. Staff will be updating data on some corridors (for example, bus speeds) that have changed since previous studies; however, staff is not looking at impact on other modes.
A motion to approve the work program for the Prioritization of Dedicated Bus Lanes Part II was made by the North Shore Task Force (City of Beverly) (Aaron Clausen) and seconded by the South West Advisory Planning Committee (Town of Medway) (Glenn Trindade). The motion carried.
In response to the Federal Transit Administration’s (FTA) requirements for TAM, federal guidance directs MPOs to revisit its targets when making updates to LRTP and Transportation Improvement Programs (TIP). MPO staff recommend updating the MPO’s TAM targets to reflect new transit agency SFY 2020 TAM targets. These targets are based on SFY 2020 (July 2019 to June 2020) targets set by the MBTA, the MetroWest Regional Transit Authority (MWRTA), and the Cape Ann Transportation Authority (CATA). These targets account for recent asset inventory and condition data and these agencies’ expectations for asset procurement and improvement during SFY 2020. MPO staff would then incorporate these updated TAM targets into its federal fiscal years (FFYs) 2021–25 TIP.
The MPO has made progress in its Performance-Based Planning and Programming practices by setting initial targets in all performance measures and incorporating them into the most recent LRTP, Destination 2040, and TIP. The FTA’s TAM rule is intended to improve transit asset state of good repair for better service delivery, which includes greater safety and reliability. The goal is to minimize the percentage of assets that have met or exceeded their Useful Life Benchmark (ULB) for rolling stock and equipment, decrease the percentage of facilities with an FTA Transit Economic Requirements Model (TERM) scale rating lower than 3.0, and minimize the percentage of track segments with speed restrictions.
The federally required performance measures cover a subset of transit system assets and focus on specific condition metrics for capturing the state of good repair. Federally required targets are short-term management tools that function more as forecasting tools than targets. There are no rewards or penalties for transit agencies, states, or MPOs related to target achievement outcomes. Once the transit agency (or sponsor) sets a target, the MPOs will establish regional targets.
In the Boston Region MPO, its transit agencies include CATA, MWRTA, and the MBTA. MPO staff’s proposed regional targets reflect these transit agencies’ ongoing assessments and planning. Tables 2 through 5 of the memorandum list TAM targets for the MBTA and regional transit authorities (RTAs), with some aggregation of asset categories. In the upcoming FFYs 2021–25 TIP development, the MPO will incorporate updated TAM targets and information on how investments affect TAM performance measures into the next TIP. Transit agencies continue to collect performance data and refine forecasts and plans as part of the TAM process.
J. Linnell began the discussion of the MBTA’s SFY 2020 TAM targets by stating that, beginning in SFY 2018, transit agencies receiving federal funds must set and report targets for each performance measure, set by the TAM Final Rule (49 CFR part 625) and based on the current asset inventory, condition, and anticipated capital investments or other improvements. The four categories of capital assets include rolling stock, equipment, facilities, and infrastructure. J. Linnell provided examples of the MBTA’s fiscal year (FY) 2020 capital programs driving asset performance for each category. J. Linnell described the MBTA’s 2019 Performance Measures, the 2020 Performance Targets and the 2019 to 2020 trend for each asset category. The major takeaways include:
· Rolling Stock: Performance is expected to improve in FY 2020 as new Orange Line cars, Red Line cars, buses, and paratransit vehicles are commissioned.
· Equipment: The MBTA’s Nonrevenue Vehicle program is focused on replacing the highest impact vehicles.
· Facilities: Performance is expected to continue to improve in FY 2020 due to continued investments in passenger, parking, maintenance, and administrative facilities.
· Infrastructure: Improvements in this category include Heavy Rail Fixed Guideway and Light Rail Fixed Guideway infrastructure, all of which have several track renewal and repair projects underway, which will continue to bring this measure down in future years.
M. Scott continued the presentation on RTA performance targets for CATA and MWRTA by reviewing Tables 2–4 from the memorandum, which details the Rolling Stock, Equipment, and Facilities figures. The CATA and MWRTA asset inventories are not as large as the MBTA’s; however, the assets are crucial in providing service to northern and western parts of the region. M. Scott said MPO staff would hold discussions with the MBTA and RTAs on how they conduct capital planning to aid in MPO TIP development. M. Scott requested that the MPO board vote to support the staff-recommended set of SFY 2020 TAM targets.
E. Bourassa asked J. Linnell for an example of an MBTA station or facility below a three on the FTA’s rating scale. J. Linnell responded that the Alewife, Braintree, and Quincy bus facilities score below a three, but there are planned rehabilitation projects to prioritize them.
E. Bourassa commented to J. Linnell about the underperforming maintenance facilities. J. Linnell recognized the need to improve these non-passenger facing assets, and stated that the Office of the Chief Engineer is currently addressing these. The hope is that these assets will be reflected in the upcoming Capital Investment Plan.
L. Diggins expressed appreciation for J. Linnell’s presentation of this material prior to the meeting, and her engagement with the Advisory Council.
T. Teich noted that members are welcome to contact MPO staff for further explanation of presentation topics ahead of meetings.
A motion to approve the Proposed SFY 2020 TAM Targets was made by the South West Advisory Planning Committee (Town of Medway) (G. Trindade) and seconded by MAPC (E. Bourassa). The motion carried.
M. Genova presented a follow-up discussion to the cost-effectiveness presentation by Beth Osborne of Transportation for America at the January 23, 2020, meeting. B. Osborne discussed approaches to measuring cost-effectiveness used by other transportation agencies across the country. M. Genova stated that MPO staff are not proposing implementing a specific approach to measuring cost-effectiveness during this year’s TIP cycle. The goal of this presentation was to explore different options and think through what might work for the MPO. M. Genova summarized the key takeaways of B. Osborne’s presentation, describing approaches to cost-effectiveness from the Virginia Department of Transportation (DOT) SmartScale program, the Atlanta-Region Transit Link Authority, and the Metropolitan Transportation Commission in the San Francisco Bay Area. All approaches demonstrate that there is not one correct strategy for implementing cost-effectiveness analysis; that a transparent, consistent process generates buy in from stakeholders; and that comparing benefits to cost works best when benefits are measured in a scaled way.
M. Genova stated that, were the MPO to adopt a cost-effectiveness analysis as part of TIP development, it would likely take place after initial project scoring is complete. Cost effectiveness would function as an additional tool in the final decision-making process, after weighing the pros and cons of each project. M. Genova presented the following questions for member discussion:
1) What elements of these approaches to cost-effectiveness would be helpful to you in making project selection decisions?
2) What elements of these approaches concern you?
3) Are you interested in pursuing an approach to cost effectiveness that considers project cost increases, including rescoring projects after programming decisions have been made?
4) What do you see as the biggest barriers to the MPO implementing a cost-effectiveness approach in its decision-making process?
5) What questions or issues do you want staff to explore further on this topic?
John Romano (MassDOT Highway Division) asked for confirmation on the funding source for projects evaluated with Virginia DOT’s SmartScale. M. Genova stated that the project proponent (i.e., the municipality or the county) can contribute funding for the overall project cost on top of state funding. This makes projects more cost-effective.
J. Monty commented on the Virginia DOT model compared to MassDOT, stating the importance of communicating state and municipal roles in contributing funds to a project, especially in terms of design requirements.
D. Amstutz agreed with J. Monty and asked for specifications on scoring projects for cost-effectiveness and project cut-off amounts. M. Genova stated that the Virginia project cut-off is used for planning processes, but it is important to be mindful when setting any sort of financial thresholds for projects given the differences between Virginia’s process, and that of the Boston region.
E. Bourassa expressed support for this process and asked for an example methodology, and a list of projects with scoring details to see if there are any impacts from revised cost-effectiveness criteria. E. Bourassa expressed support for rescoring projects if the costs have increased because of the potential unfairness to other project proponents with unfunded projects due to the lack of available funds.
Sheila Page (At-Large Town) (Town of Lexington) supports using cost-effectiveness analysis and rescoring projects that cross a certain threshold. S. Page noted the potential challenges in implementing such changes as it puts more pressure on the municipality and may penalize them for things out of municipality control—as was the case in the pedestrian bridge project for the Town of Ashland. S. Page noted that it is unclear how cost-effectiveness analysis could address the fact that some communities are unable to contribute funding to a project, given that doing so would boost a cost-effectiveness score.
Tina Cassidy (North Suburban Planning Council) (City of Woburn) underscored the need for periodic evaluations of investments and expressed support for the Metropolitan Transportation Commission’s approach that allows project sponsors to demonstrate the merits of these projects even when the cost-effectiveness scores are low.
L. Diggins stated his surprise that the cost-effectiveness analysis comes at end of the TIP scoring process. M. Genova said that the placement of the cost-effectiveness component within the TIP scoring process is open for discussion.
B. Kane commented on the Virginia model, and how funding was distributed equitably across the regions.
D. Amstutz, agreeing with E. Bourassa, asked for examples of projects that might be subjected to rescoring to gain a better understanding of the new scoring methodology.
T. Kadzis stated that it may be time to revisit the design premium like MassDOT does, which was previously discussed but never followed up on. There is also a need to address MassDOT Highway Division capacity to increase the number of 75 percent design projects in the event that the MPO pursues the rescoring route.
Note: At this point in
the meeting, Bryan Pounds (MassDOT) assumed the Chair’s seat.
M. Genova stated the principles guiding the TIP Criteria revisions, including today’s proposed revisions to the Clean Air and Sustainable Communities criteria. The Clean Air and Sustainable Communities criteria currently has 16 points out of a total 134 possible points, representing about 12 percent of overall point total. The current criteria include:
· Reduces carbon dioxide (CO2) (up to five points)
· Reduces other transportation-related emissions (up to five points)
· Addresses environmental impacts (up to four points)
· Designated as a EOEEA-certified “Green Community” (up to two points)
M. Genova noted that point values will be refined at a later date, and that the resiliency criteria will be more formally expanded on in the System Preservation goal area discussion in the spring. M. Genova shared a summary of the feedback received through the November 2019 to December 2019 survey on TIP criteria revisions, and from the seven public focus groups. M. Genova proposed a revised point scale for reducing CO2 emissions that would increase the penalty for projects that are anticipated to increase these emissions.
After MPO board members commented on the first proposed revision, M. Genova continued presenting the proposed revisions to the “reduces other emissions” (volatile organic compounds [VOC], nitrogen oxide [NOx], carbon monoxide [CO], particulate matter [PM2.5]) criterion. Similar to the CO2 criterion, M. Genova proposed a revised point scale for reducing other emissions that would increase the penalty for projects that are anticipated to increase these emissions, and incorporate PM2.5 into project evaluations. Adding PM2.5 to the scoring process came from outreach efforts, where participants expressed interest in the connection between transportation and public health outcomes. It also coincides with MassDOT’s current practices in its project evaluations. M. Genova stated the inability to measure PM2.5 at the project level but proposed that projects score bonus points for reducing transportation emissions in areas with above-average PM2.5 concentrations.
After MPO board members commented on the proposed revision, M. Genova continued the presentation on the proposed revisions to the “addresses environmental impacts” criterion. M. Genova proposed changes in scoring to emphasize reducing impervious surfaces, investing in green infrastructure, and using storm water best management practices to improve existing conditions. M. Genova asked the board if they preferred a scaled approach or a consolidation of points into one category.
After MPO board members commented on the proposed revision, M. Genova continued the presentation on the proposed revisions to the “EOEEA-certified ‘Green Community’” criterion. M. Genova stated that the criterion should be eliminated and replaced with a “project enhances natural environment” criterion. This updated criterion measures tangible benefits like increased tree canopy coverage, and increased access to parks, open space, and other natural assets. Currently, 80 percent of towns are EOEEA-certified “Green Communities,” making the designation relatively meaningless for scoring purposes. After discussion of all proposed revisions, M. Genova provided a timeline of next steps in the TIP development process.
J. Monty asked about incorporating future CO2 emissions into current project scoring, and looking at the larger picture on behavior changes and modal shifts.
D. Amstutz, agreeing with J. Monty, asked how emissions are calculated, why some projects are scored zero, and the significance of thresholds for CO2 emissions. M. Genova described the process of deciding on the revised point scale by using historical TIP project data and the air quality methodology, outlined in federal Congestion Mitigation and Air Quality guidance. M. Genova also stated that very few projects increase emissions by 1,000+ annual tons of CO2.
B. Pounds clarified how projects can receive a score of zero due to its qualitative traits. M. Genova said repaving projects are a good example. B. Pounds stated that only a handful of projects increase CO2 emissions.
J. Monty asked if the CO2 emissions question should be restricted to certain types of projects, ones that are larger in scale.
Tom O’Rourke (Three Rivers Interlocal Council) (Town of Norwood/Neponset Valley Chamber of Commerce) asked for examples of projects that have emitted large amounts of CO2. B. Pounds asked M. Genova to bring some examples to an upcoming meeting.
T. O’Rourke asked, in regards to PM2.5, where there are areas with known air quality issues. B. Pounds stated that MassDOT conducted a health impact study that explains the methodology to evaluate these projects. M. Genova stated that PM2.5 tends to be high in areas with high amounts of diesel exhaust.
J. Romano commented on PM2.5 and air quality on the “Big Dig” project. B. Pounds commented on the importance of health in MassDOT’s work. M. Genova said he is coordinating closely with MassDOT so that all project proponents are operating on the same base.
L. Diggins asked how PM2.5 relates to black carbon on behalf of the Rider Oversight Committee members. M. Genova said that black carbon is a component of PM2.5, representing about 12 percent. It is less of a concern now than it was 15 years ago.
D. Amstutz expressed support for the criteria revisions on behalf of the Town of Arlington.
T. Cassidy, in response to the “addresses environmental impacts” criterion revision, likes the scaled approach but commented that there might be a situation in which a project does not avoid all negative impacts but still improves upon existing conditions. T. Cassidy added that points for storm water “Best Management Practices,” and avoiding negative impacts to cultural resources, open space, wetlands, natural resource areas, wildlife areas, or protected habitats, might be better as part of separate criteria.
A. Clausen, in response to the “Green Community” criterion revision, supports its elimination stating, there are other ways for similar designation, such as Complete Streets certification, and Municipal Vulnerability Program participation.
T. Cassidy commented on the proposed tree canopy criteria component, stating that the language could be broadened to include other improvements that enhance the natural environment, such as the removal of impervious surfaces.
L. Diggins suggested giving these sustainability categories more weight than the current 16 points. B. Pounds responded that in later meetings, the board will discuss point allocation more broadly. M. Genova said he appreciates the feedback.
B. Pounds commented that it would be helpful to see examples of projects scored for these categories, including tree canopy coverage. M. Genova further clarified the “net increase in tree canopy coverage” item, acknowledging that while some projects may reduce the tree canopy during construction, which could be seen as a negative for air quality, points should be awarded for increasing the net tree canopy coverage as a result of the project.
D. Amstutz commented on the possible conflict between the revised criteria, and the definition of “access.” M. Genova stated his appreciation of this feedback as staff are also thinking about how to frame certain items.
Jennifer Constable (South Shore Coalition) (Town of Rockland) supported removal of the “Green Community” criteria item, but stated that one way for the MPO to continue including this criteria may be to replicate EOEEA’s “Green Community” scoring categories.
This item was postponed to a future agenda.
There were none.
A motion to adjourn was made by the MBTA Advisory Board (B. Kane) and seconded by the Advisory Council (L. Diggins). The motion carried.
At-Large City (City of Everett)
At-Large City (City of Newton)
At-Large Town (Town of Arlington)
At-Large Town (Town of Lexington)
City of Boston (Boston Planning &
City of Boston (Boston Transportation
Federal Highway Administration
Federal Transit Administration
Inner Core Committee (City of Somerville)
Massachusetts Department of Transportation
MassDOT Highway Division
Massachusetts Bay Transportation Authority
Massachusetts Port Authority
MBTA Advisory Board
Metropolitan Area Planning Council
MetroWest Regional Collaborative (City of
Thatcher Kezer III
Minuteman Advisory Group on Interlocal
Coordination (Town of Acton)
North Shore Task Force (City of Beverly)
North Suburban Planning Council (City of
Regional Transportation Advisory Council
South Shore Coalition (Town of Rockland)
South West Advisory Planning Committee
(Town of Medway)
Three Rivers Interlocal Council (Town of
Norwood/Neponset Valley Chamber of Commerce)
MassDOT District 6
Quincy Mayor’s Office
Boston Transportation Department
City of Revere
Cape Ann Transportation Authority
Town of Saugus
Transportation Planning Staff
Tegin Teich, Executive Director
The Boston Region Metropolitan Planning
Organization (MPO) operates its programs, services, and activities in
compliance with federal nondiscrimination laws including Title VI of the
Civil Rights Act of 1964 (Title VI), the Civil Rights Restoration Act of
1987, and related statutes and regulations. Title VI prohibits discrimination
in federally assisted programs and requires that no person in the United
States of America shall, on the grounds of race, color, or national origin
(including limited English proficiency), be excluded from participation in,
denied the benefits of, or be otherwise subjected to discrimination under any
program or activity that receives federal assistance. Related federal
nondiscrimination laws administered by the Federal Highway Administration,
Federal Transit Administration, or both, prohibit discrimination on the basis
of age, sex, and disability. The Boston Region MPO considers these protected
populations in its Title VI Programs, consistent with federal interpretation
and administration. In addition, the Boston Region MPO provides meaningful
access to its programs, services, and activities to individuals with limited
English proficiency, in compliance with U.S. Department of Transportation
policy and guidance on federal Executive Order 13166.
The Boston Region MPO also complies with the
Massachusetts Public Accommodation Law, M.G.L. c 272 sections 92a, 98, 98a,
which prohibits making any distinction, discrimination, or restriction in
admission to, or treatment in a place of public accommodation based on race,
color, religious creed, national origin, sex, sexual orientation, disability,
or ancestry. Likewise, the Boston Region MPO complies with the Governor's
Executive Order 526, section 4, which requires that all programs, activities,
and services provided, performed, licensed, chartered, funded, regulated, or
contracted for by the state shall be conducted without unlawful
discrimination based on race, color, age, gender, ethnicity, sexual
orientation, gender identity or expression, religion, creed, ancestry,
national origin, disability, veteran's status (including Vietnam-era
veterans), or background.
A complaint form and additional information can be
obtained by contacting the MPO or at http://www.bostonmpo.org/mpo_non_discrimination. To request this
information in a different language or in an accessible format, please
Title VI Specialist
 EOEEA = Executive Office of Energy and Environmental Affairs.