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Comments on Notice of Project Change for the Mohegan Sun Massachusetts in Revere EEA #15006

By WalkMassachusetts | March 7, 2014

March 7, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on Notice of Project Change for the Mohegan Sun Massachusetts in Revere EEA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the Notice of Project Change (NPC) for the Mohegan Sun Massachusetts project in Revere and offers the comments below.

The NPC was prompted by the shift of the project location to Suffolk Downs property that is located solely in Revere. This change will have significant impacts on pedestrian movement into and through the project. The elements of the project – two hotels, large gaming space, numerous restaurants and spa– have not changed. But, in the new location, the buildings have a substantially reduced footprint and are much closer to existing business and residential areas.

Walking Access to Transit – Beachmont MBTA Station

The principal impact of the project change for people arriving on foot is the much greater proximity of the development to transit access, now shifted to the Beachmont MBTA Station (formerly focused on the Suffolk Downs Station). The revised location for the proposed resort places the main entrance only 300 feet from Beachmont Station, and will likely shift some trips from autos to transit because of this proximity.

In order to encourage transit and walking trips, we suggest exploring several pedestrian amenities including the following:

A significantly wider sidewalk along Winthrop Avenue between Beachmont Station and the site of the resort.
An weather-protected sidewalk along Winthrop Avenue between the primary entrance and exit locations at Beachmont Station to Washburn Avenue. The canopy or arcade should connect directly to the existing MBTA station entrance which already has weather protection.
A weather-protected walkway from the edge of the resort property on Washburn Avenue to the main resort entrance.
Significant upgrades in wayfinding inside Beachmont Station and along the route to the resort to encourage transit ridership and reinforce the convenient transit access.
Upgrades of escalators and elevators inside Beachmont Station to adequately and safely handle greater numbers of riders using transit.
Signalization or signage protection for pedestrians crossing Washburn Street on the south side of Winthrop Avenue.

Traffic Mitigation

We are fearful that the project will add a great deal of traffic to an area that cannot handle it easily. Winthrop Avenue and the Revere Beach Parkway are heavily used already. Improvements to the interchange with Route 1 will only add to the use of these streets, which cannot easily accommodate them.

Better access might be provided via Tomesello Way, from Route 1A the Suffolk Downs Racetrack parking areas, which will have greater capacity for storage of vehicles and a more orderly approach to the casino. We think the proponent would be well advised to encourage use of Tomesello Way and the MBTA Blue Line for principal access points into the casino property.

In addition, the parking garage is enormous, suggesting a commitment only to vehicular access. Perhaps the proponent could save some of the construction cost of this garage through the use of thoughtful techniques of encouraging patrons not to drive – perhaps a benefit of some sort that patrons could use on the floor of the casino.

We appreciate your consideration of our comments and look forward to your responses to them.

Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Robert Sloane
Senior Project Manager

Cc Massachusetts Gaming Commission
Mayor Dan Rizzo

Comments on the Draft Environmental Impact Report for Wynn Everett, MEPA #15060

By WalkMassachusetts | February 20, 2014

February 10, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Anne Canaday
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the EIR for Wynn Everett, MEPA #15060

Dear Secretary Sullivan:

WalkBoston offers the following comments on the Wynn Everett Draft Environmental Impact Report. While we are pleased to see that the DEIR includes the proposal for the harbor walk and water transportation docking facilities, we are concerned about the traffic impacts and the lack of sufficient preparation for pedestrian access to the site. Improved pedestrian access is crucial to encouraging transit use as a significant travel choice for both employees and patrons.

Our comments are organized around two key issues: (1) enhancing and encouraging walking and transit, (2) mitigating the impacts of auto trips.

Enhancing and encouraging walking and transit
An Everett casino should be viewed through the lens of an urban re-development project that fits within its neighborhood and enhances the lives of its neighbors as well as its patrons and employees. In order to do that, the development should maximize the number of transit and walking trips, and minimize the number of auto trips.

1. Transit access and emphasis.
As currently planned, primary subway transit access will be provided by the Orange Line Sullivan Square MBTA Station which is about .75 miles from the site. Transit stations at Wellington and Assembly Square are each over 1.5 miles from the site, and currently have indirect, time-consuming pedestrian routes to the proposed casino. Transit should be encouraged through a number of different carrots and sticks.

• Bus service should be enhanced by improving nearby bus stops or providing subsidies to provide additional service for nearby routes. The safe use of bus stops on the far side of Route 99 is especially important to consider; the proponent should assure that there are traffic signals at all bus stops to provide safe passage for pedestrians crossing at these locations.

• Providing an off-site, transit-convenient and/or shuttle-served location for parking used by the majority of employees is one important option. The connection of proponent- or operator-controlled shuttles to these locations will reduce the impact of vehicles at the access points into the site. To attract patrons to use the bus, the proponent may want to experiment with shuttles that are attractive and “fun.”

• The proponent has included shuttle buses to nearby subway stations and to offsite parking lots. Frequency of the proposed service should allow Orange Line and bus riders to be served within very short (maximum 15-minute) wait times. All shuttle services should be made free for employees and patrons.

• The proponent and operator of the casino should price parking spaces to discourage parking during all times of day and evening during which transit service is available.

• Carpooling should be encouraged and subsidized for employees who live outside the MBTA service area or who work late-night shifts.

• The proponent should subsidize ferry services to make use of the proposed water transportation facility.

• The proponent should establish a transportation management organization that can efficiently deal with transit encouragement through subsidized transit passes, and other means that encourage the use of transit.

• Monitoring and reporting on the successes of the proponent and operator of the site in reducing vehicular traffic should be undertaken on an annual basis for the first 10 years of use of the new facilities.

2. Pedestrian access improvements
• Significant improvement of pedestrian access to Sullivan Station should be included in the proponent’s transportation mitigation plan. Access for pedestrians along Lower Broadway remains a concern. When Route 99/Broadway was reconstructed by the state, new bicycle lanes were added in both directions, but the existing sidewalks were narrowed to permit expansion for other transportation modes. The proponent should detail the ways in which sidewalks will be upgraded for pedestrian access into the site. Improved sidewalk access should extend at least as far as the MBTA Sullivan Square Station, which will require the proponent to work closely with the City of Boston.

• The new intersections serving the site should be carefully planned to include safety measures for pedestrian crossings. This should include pedestrian phase timing at these and other signalized intersections constructed or modified as part of the proposal.

• The potential new pedestrian and bicycle connection that the proponent proposes to create an approximately .75 mile direct route between the site and Santilli Circle – is intended to encourage pedestrian traffic. The proponent should be required to continue its work with the DCR and the MBTA to assure that this very short, relatively inexpensive connection actually gets constructed. The proponent should promote use of this route to encourage its use.

• A connection between the site and the City of Somerville could be provided by access over the Amelia Earhart Dam. This connection would lead to both the new Assembly Square MBTA Station and to the Somerville/Charlestown Mystic River path network. A connection across the dam could make the Assembly Square station the closest transit access point for the site. The proponent should work with the cities, as well as the DCR and the MBTA (owners of the land) to see whether this long sought pedestrian amenity that would link the extensive riverfront path networks on the two sides of the river, could be provided by the project.

• A concept plan for the streetscape in Everett has been mentioned. We trust that the plan, if developed, will be generous in its recommendations for pedestrian access.

Mitigating/managing the impacts of auto trips
We are concerned that the location of the site and its considerable distance from centers of population and regional transit stations will result in motor vehicles providing the majority of the access to the site, as the proponent has stated. The emphasis on access for vehicular traffic via Broadway leads to potentially difficult traffic concentrations – not only for Broadway, but also for Sullivan Square and the Sweetser Circle at Route 99/16. Both of these locations are already challenged by daily traffic patterns and the addition of casino traffic would seem to bring new and extensive challenges.

All of the access via Sullivan Square will deeply affect the Charlestown neighborhood and its plans for improvements at Sullivan Square. The proponent should work closely with residents of Charlestown and the City of Boston to reach an improved understanding of potential traffic volumes and impacts and the methods that might be used to partially mitigate the effects on the neighborhood. This should include traffic data collection and analysis, and detailed work with the City of Boston to review and assess all options for mitigating the impacts that casino related traffic will have on city streets, intersections and sidewalks. A community agreement between the City of Boston and the proponent should be reached prior to further planning.

Thank you for considering our comments. Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Robert Sloane
Senior Project Manager

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Support for Inclusion of Active Streets in Transportation Bond Bill

By WalkMassachusetts | February 20, 2014

February 5, 2014

Chairman Brian Joyce
Senate Committee on Bonding, Capital Expenditures, and State Assets
State House, Room 109D
Boston, MA 02133

Re: Support for Inclusion of Active Streets in Transportation Bond Bill

Dear Chairman Joyce:

WalkBoston writes to urge you to support the “Active Streets Certification Program” that is included in the Transportation Bond Bill that was recently passed by the House (H3882). Senator Harriette Chandler and Representative Jason Lewis (S68/H3091) filed a version of this language as standalone legislation.

As Massachusetts’ leading pedestrian advocacy organization, WalkBoston works with communities across the state to help them create a safer and more convenient walking environment for their residents. We see very strong interest in walking in urban, suburban and rural municipalities, and we also see communities that are having a difficult time designing and investing in sidewalks and walkways.

The program created under this proposal would encourage communities to build streets and roads that accommodate walking, bicycling and transit use – a.k.a. “Complete Streets” – by creating a small grant program for which they would become eligible after passing a Complete Streets bylaw or ordinance in addition to taking several other actions.

The presence of improved walkways and bicycle facilities encourages an active, healthy lifestyle and reduces auto dependency. In addition to health benefits, Complete Streets can boost the local economy supporting local business districts and increasing property values. While some cities and towns in Massachusetts have already taken steps to implement Complete Streets, this program would provide the necessary incentives and support to encourage even more cities and towns do so.

Thank you very much for your consideration of our request. Please feel free to contact me if you have any questions or concerns, 617-368-9255 or wlandman@walkboston.org

Best regards,

Wendy Landman
Executive Director

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MGM Springfield Draft Environmental Impact Report EEA #15033

By WalkMassachusetts | February 20, 2014

January 31, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Sullivan:

WalkBoston has reviewed the Draft Environmental Impact Report for the MGM Springfield proposal and offers the comments below.

Within the DEIR, there are some changes in the dimensions of the plan. The proposal now includes a somewhat smaller, 501,108 square feet casino resort that includes retail/restaurant uses and banquet facilities in addition to gaming space. Adjacent to the casino will be a somewhat smaller 250-‐room hotel, 54 residential units, and an expanded, 159,397 SF retail and entertainment center to be known as Armory Square. A somewhat smaller, 3,740 space on-‐site multi-‐level parking garage will be provided. In most cases, these alterations to the plan do not appear to affect volumes or paths for walkers.

The ENF Certificate provided by Secretary Sullivan called out additional analysis to be included in the DEIR, and specified that the proponent was to meet with WalkBoston about our comments on the ENF. The Secretary’s Certificate included this language:

“I strongly encourage the proponent to consult with WalkBoston during the preparation of the DEIR to identify opportunities to enhance the development of pedestrian access to and within the site as well as incorporation of safe pedestrian access for off-‐site roadway improvements.”

The proponent did meet with us to discuss the project, and were very forthcoming about the pedestrian components of the project. In our discussion we covered many of the ideas that now appear in the DEIR and have solidified the commitment to serving walkers in the project plans and designs.

Secretary Sullivan’s Certificate on the ENF mentioned some specific aspects to be explored further in the DEIR. These are important and form the basis of our comments on the DEIR:

1. Existing and proposed traffic signals.
2. Consistency with a Complete Streets design approach.
3. Existing and proposed connections for pedestrians.
4. A commitment to making improvements to increase the use of walking routes.

1. Existing and proposed traffic signals.
We are pleased to note that the DEIR calls for updating pedestrian signal equipment at the study area intersections around the site.

We note that two mid-‐block crossings with refuge islands and flasher assemblies are proposed – one on State Street and the other on Union Street -‐ both roughly half way between Main Street and East Columbus Avenue and located at the exterior of the proponent’s site.

Another mid-‐block crossing is noted in the DEIR that allows for a mid-‐block crossing to reach a bus stop. This crossing is located on Main Street at Howard Street, and represents a response to one of WalkBoston’s recurring concerns -‐ that transit riders should not be required to walk to corner locations to reach a bus stop if the stop is mid-‐block. Instead, crosswalks should be added to provide safe and convenient walking routes for transit users.

We encourage the efforts of the proponent to provide a diagonal pedestrian crossing at the intersection of Main and State Streets, where a direct connection to the Mass Mutual Convention Center may be of significant use. We hope that the City of Springfield will work with the proponent to establish this crossing.

The proponent vows to upgrade pedestrian push buttons to MUTCD standards at all locations where new signals will be installed as part of this project or the mitigation efforts that result from the construction of the project. Upgrades of pedestrian push buttons are very welcome as are any other forms of enhancements for pedestrians crossing streets on the perimeter of the project.

2. Consistency with a Complete Streets design approach.
The proponent has been mindful of the design of streets on the perimeter of the project. In particular, the width of sidewalks has been discussed and the design now provides positive benefits to walkers.

For example, sidewalks on Main Street, according to several of the maps, vary in width from 10.5’ to 18.’ On the widest sidewalks, there is the promise of added pedestrian amenities, such as benches, pedestrian level lighting landscaping and other streetscape improvements. The designs of the narrowest sidewalks should be carefully considered to provide a clear walk zone of at least 5 feet, with no obstructions, such as trees or benches, intruding on that width.

We note that the pedestrian network evaluation preceding design has led to proposed improvements to sidewalk pavement conditions, sidewalk widths, crosswalks, and compliance with current accessibility standards.

One of the requirements of a complete streets approach to street design is adequate provision for buses, bus stops and transit riders. In central Springfield, including Main Street along the east boundary of the site, heavy bus traffic (including four major PVTA bus routes) serves downtown employers and merchants and ordinarily occupies a lane that can be shared with bicycles, but should otherwise be retained for exclusive use by buses.

In addition to the PVTA bus routes, a proposed downtown trolley line will connect the casino site to rail and bus service in the vicinity of Union Station, about ½ mile north of this site. The trolley line makes the connection efficiently, and will encourage transit use by casino employees and patrons.

3. Existing and proposed connections for pedestrians.
The proposal includes several connections for pedestrians into the large complex, particularly along Main Street. The proponent has made progress is the design of the proposed Armory Plaza at the south edge of the casino building by providing a car-‐free area that combines the open space surrounding the old, restored Armory building with the relatively small but useful open space of DaVinci Park. The use of the Plaza may be combined with the uses in the adjacent Armory Marketplace building and may host civic events and a farmers’ market.

A new pedestrian attraction is the provision of a landscaped plaza atop the casino building. This plaza is completely removed from vehicular traffic and provides a quiet space where people may walk or sit.

A pedestrian connection already exists between the site and the Connecticut River pedestrian and bicycle trail. An existing at-‐grade crossing at the foot of State Street allows pedestrians to move between the proponent’s site and the trail. It is anticipated that this connection will be used as a way to get from the site to the nearest open space. Lighting under I-‐91 at State Street will help open the area to pedestrians by making it more legible and safe.

A similar pedestrian connection exists at Union Street, where the walkway link that passes under I-‐91 allow pedestrians to reach the Naismith Basketball Hall of Fame. The distance is relatively short and is eminently walkable. The connection will be improved by the proposed lighting to be placed under I-‐91.

4. A commitment to making improvements to increase the use of walking routes.
The proponent’s site is central to the Springfield urban area and will become an integral part of downtown as it is developed. Within the site, there are many places to walk that may require little effort to get patrons to explore. Each entrance/exit to the site should have wayfinding signs to assist walkers and encourage them to walk to destinations within and outside the entertainment complex. The signs should indicate where to find locations such as the center of the casino, the hotel, the outdoor plaza, shops and theatres on the south side of the site, Former Armory, Armory Square Marketplace, the rooftop landscaped plaza, and the main entrances to the parking garage.

Outside the casino complex, there are many attractions in downtown Springfield, and wayfinding signs that guide walkers should include: the Mass Mutual Convention Center, Union Station/Main Bus Depot, Dr. Seuss Sculpture Garden, Springfield Museums, the Civic Center, Springfield Armory, and nearby parks.

Signs should also indicate how to find the riverside attractions including views of the river and the Connecticut River Pedestrian and Bicycle Trail and the Naismith Basketball Hall of Fame.

Wayfinding signs should include walking times to reach destinations. Pedestrians do not think in terms of miles, and minutes required to take a walk are much more effective in conveying the effort that might be involved. Walkers may think little of having to walk ten minutes, but recoil at the prospect of walking ½ mile, even though the distances are the same.

Specific wayfinding signs that should include walking information as well as vehicle and bicycle information are:
• Signs along West Columbus Avenue on the river-‐facing side of the site,
• Signs on Union Street at the edge of the project, and
• Signs along the East Columbus Avenue side of the site.

Wayfinding can be enhanced with local walking maps that help people find their way around the site and its environs.

We appreciate your consideration of our comments and look forward to your responses to them.

Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Robert Sloane
Senior Project Manager

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Mass Central Rail Trail – Wayside Branch, MEPA # 15133

By WalkMassachusetts | February 15, 2014

December 16, 2013
Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs
Attn: Purvi Patel
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Expanded Environmental Notification Form for the Mass Central Rail Trail – Wayside Branch, MEPA # 15133

Dear Secretary Sullivan:

WalkBoston has reviewed the Expanded Environmental Notification Form for the Mass Central Rail Trail – Wayside Branch. We are very pleased that this facility is being seriously examined for construction, as it is essentially the spine of a trail network that will eventually extend east-west across the full width of the state. As proposed, the new trail will extend 23 miles through eight communities, through a 19 feet wide corridor reserved for construction. The proposed trail will be 10’ wide. Its importance cannot be understated: it will serve as the main stem of a network of state-wide greenways.

Our analysis of this proposal suggests that design of the rail trail should ensure that it includes features attractive to a wide range of users, including more than pedestrians, cyclists, and in-line skaters. The trail should be designed to encourage extensive use by runners and joggers. We bring this suggestion into the current review process because it may lead to a consideration of additional width and different materials on a trail surface that provides the best possible conditions for runners and joggers.

Why is WalkBoston involved with runners and joggers? WalkBoston has become involved with runners and joggers because we work for all people on foot –whether they walk slow or run fast – all using the same facilities. For 6 years, WalkBoston has been the recipient of support from the running community through the Boston Marathon Charity program, first as a Boston Athletic Association team and subsequently with charity bibs provided by the John Hancock Insurance Corporation. Our runners have enjoyed partnerships with us and with our coaching team under a program we have called RunBoston. Our staff includes competitors who have run the Marathon and we now have a staff person who is a United States Track & Field (USATF) Certified Level 1 Coach and an Executive Board member of the Mass State Track & Field Coaches Association (MSTCA).

Why add space for runners and joggers? Running and jogging are growth industries. In 2012 over 29,000,000 people ran 50 or more days per year. Evidence of runners is often seen near pathways throughout the state, where they have made their own parallel trails, running in the grass until a semi-permanent dirt path becomes established. Recognizing that such running paths are beneficial to runners, the state Department of Conservation and Recreation has not only retained the informal paths, but is also thinking of new ways to add permanence to running paths that would fully incorporate runners and joggers in their path-making.

Why are runners different from other trail users? Runners prefer a ‘soft’ running surface, yet rail trails are most frequently constructed with a firm surface such as asphalt or concrete, chosen because these surfaces can serve the maximum number of potential users. But nearly all runners agree that a softer surface would be preferable. Concrete is uniformly cited by runners as the hardest surface – the most harmful surface for runners who want to avoid physical injuries. Paths constructed of grass, dirt, wood chips or stone dust are the four top preferred options for surfaces for running, because these surfaces are less likely to result in physical injuries such as a twisted ankle, shin-splints, sprains, Achilles tendonitis or other impact-related injuries. Soft surfaces, such as stone dust, lacking pebbles or rocks that might make running dangerous, also provide runners with greater traction and more control over pace and muscle use.

What design features could encourage running? Parallel running paths could be on both sides of the trail or on only one side, where a path would need to provide for two-way running traffic. The running path could be immediately adjacent to the paved trail or separated from it by a few feet. The path could be from 2-6 feet wide and should be as nearly free of camber in cross-section as possible. The former use of the corridor for rail service means that the gradient of the trail will be easily manageable for runners. Special signage is not necessary, as the alternative trail surface provide explanation for the existence of the addition to the trail.

A separate, parallel path would be useful for runners and possibly walkers as well. Such a path could not only provide the running surface runners prefer, it would also remove runners from the stream of bicycle and pedestrian traffic on the principal portion of the trail. Walkers could also use the path if they prefer a soft walking surface or would like to be somewhat removed from other trail traffic.

Where have running surfaces and separate facilities been provided? The 10 mile long Battle Road footpath is the best-known example in Massachusetts, as it provides a stone dust surface for its entire length between Lexington and Concord.

In Janesville, WI, off-street sections of the proposed bicycle path system are designed to meet AASHTO guidelines and WisDOT recommendations. A 10-foot two-directional paved path is the intended design for most sections. These off-street path segments are required through local regulations to include a two foot wide crushed gravel shoulder on at least one side to accommodate runners and walkers.

In Colorado Springs, CO, the Design Guidelines for US 24 Rural Section 25 include two types of trails paralleling the highway: primary trails, usually 12’ wide and paved with concrete; and secondary trails, adjacent soft surface trails, varying in width and designed to accommodate walkers, joggers and equestrian users.

In Denver, CO, several local trails provide both hard-surface and soft-surface parallel trails. The same approach has also been used in St.Louis, MO, Scottsdale, AZ., Minneapolis, MN, Newark, DE, at several locations in Florida, and along the Chesapeake and Ohio Canal in Maryland.

How can a soft surface be added to the Massachusetts Central Rail Trail project?
The proposal for this rail trail includes a specified right-of-way (negotiated with the MBTA) that is 19 feet wide. Within this right-of-way, a 10-foot wide path is proposed to be constructed. The 9-foot space that remains will provide a buffer to neighboring land uses, but a portion of it might be used for a running path, which could be constructed at the same time as the proposed rail trail. This space may vary in width as the rail trail passes over or under bridges, or near physically dangerous, precipitous banks. Locations where it is impossible to construct a parallel path might be avoided by requiring runners to rejoin the main path for a limited distance.

What costs might be incurred? Anticipated costs for construction of a running path vary considerably, but brief research suggests that the use of stone dust appears to cost less than asphalt. This would need to be corroborated.

Adding separate elements for runners fits with the state’s self-image as the most well- known and important marathon running state in the country. The running trail would clearly support the burgeoning running shoe industry that includes three shoe-building companies with headquarters in Massachusetts. Because of its considerable length, the rail trail could well serve as a training facility for runners who are vying for a running bib for the Boston Marathon. It could serve the Boston Athletic Association, which has just declared its intention to form a high-performance elite team to dig in and focus on creating a national-caliber and, hopefully, a world-class-caliber team that lives and trains in the Boston area. The trail just might also provide the setting for preparing a winner for the annual race in April!!

We appreciate your consideration of our comments and look forward to your responses to them. Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Wendy Landman
Executive Director

Cc Joe Orfant, DCR
Dan Driscoll, DCR
Paul Jahnige, DCR
Craig Della Penna, Mass Central Rail Trail , Coordinator

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