That definition of bus station quoted below is
*NOT in the law*. That definition quoted below is in *the guidelines the
EOHLC created*. The law itself just says “bus station”.

*We need to be consistent*. If the argument being made is that we don’t
believe the guidelines, then a bus station is a bus station according to
the law. The law tasks the EOHLC with creating guidelines to determine
compliance.

*If we ignore the EOHLC and stick to the law as described, then option C is
not compliant with the letter of the law given the inclusion of a
mixed-used district*. The law doesn’t allow for that but the guidelines do.
This change happened in August of this year.

*Let me reiterate, options C and D1-D3 and E comply with the law according
to the guidelines.*

It is important to note that mass.gov says the following about the agency:
The Executive Office of Housing and Livable Communities (EOHLC) (…) is
required to promulgate guidelines to determine if an MBTA community is in
compliance with Section 3A.



On Sat, Nov 18, 2023 at 4:06 PM Don Seltzer <[email protected]> wrote:

> On Sat, Nov 18, 2023 at 3:46 PM Karla Gravis <[email protected]>
> wrote:
>
>> Utile and the HCAWG would not submit proposals that don’t satisfy the
>> letter of the law. Options D have been blessed by both parties. Options E
>> offer a combination of approved parcels already existing in Options C and
>> Ds.
>>
>> Options D and E are compliant with the letter of the law. All of those
>> options have 100% of their units
>> *“located not more than 0.5 miles from a commuter rail station**, subway
>> station, ferry terminal or bus station**.”*
>>
>
> Utile and HCAWG submit proposals that will satisfy the Executive Office of
> Housing and Livable Communities guidelines, not what the actual law states.
> Regarding 'bus station', that is very narrowly defined as
>
> *“Bus station” means a location with a passenger platform and other fixed
> infrastructure serving as a point of embarkation for the MBTA Silver Line.*
>
> A bus stop for a low capacity bus line does not come close to qualifying
> as a Bus Station under this law.
>
> MBTA communities are at the mercy of a few bureaucrats in EOHLC that have
> dreamed up guidelines that have little to do with the Legislature enacted.
> Let us be honest in this discussion.  We are not trying to meet the Letter
> of the Law, but rather satisfying an overreaching executive office.
>
>
> Don Seltzer
>
>
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