April 23, 2020

Director Brian Golden
Boston Planning and Development Agency
Attn: Tim Czerwienski

Re: Harbor Garage Redevelopment

Dear Director Golden:

WalkBoston is Massachusetts’ primary pedestrian advocacy organization, and we frequently provide comments on major public and private development and infrastructure projects, with a focus on how those projects serve and affect pedestrians.

The redevelopment of the Harbor Garage has been under discussion for many, many years with major public disagreement about the appropriate scale and mix of uses that the project should comprise. We will not weigh in on those issues because the Municipal Harbor Plan has now set the stage to allow a very large mixed-use development. Our comments focus on a more detailed and fine-grained set of issues that will affect the ways in which people walking to, through and next to the project will be affected. We believe that the next steps in the environmental review should include further evaluations of impacts on the pedestrian realm.

The building site presents a complicated puzzle for the circulation of people and vehicles because all four sides of the site are public facing, each with its own personality and constituency.

• Over many years, WalkBoston has invested time and energy (with many partners) to establish and preserve the integrity of a wide and pedestrian-friendly sidewalk along Atlantic Avenue, both as a core walking route for thousands of people every day and as a component of the Rose Kennedy Greenway. We remain committed to maintaining the preeminence of this walking route. Atlantic Avenue’s significant pedestrian (and bicycle) volumes, can only be expected to grow in the coming years.
• Milk Street is the primary connection from the City to the Aquarium and serves millions of visitors every year and will be part of the Aquarium’s planned Blueway. Special attention to this walking link to the harbor is an essential component of the site’s redevelopment.
• The HarborWalk is the City’s waterfront front door and pedestrian corridor with critical public realm and resiliency functions and serving thousands of walkers every day. As one of Boston’s most loved and important pedestrian assets and spaces, the HarborWalk deserves great attention to design, programming and management.
• East India Row provides access to both the project site and the Harbor Towers residential development. It is used by both pedestrians and vehicles as an important link between Atlantic Avenue and these sites.

From the pedestrian perspective, we believe that the current proposal has a better footprint and urban design than earlier development concepts. Improvements to the sidewalks, landscaping and scale of the pedestrian areas around the site will all contribute to a more comfortable and attractive streetscape than the existing conditions surrounding the garage.

Our comments and questions focus on:

• Vehicle access to the building
• Pedestrian circulation around and through the development site
• Public programming to support a lively public realm and welcome a diverse set of visitors
• Shadow, wind and microclimate
• Coordination with existing and future waterfront resiliency efforts that will affect people walking

Vehicle Access

Because the site will continue to provide parking for the Aquarium and the Harbor Towers, as well as serving the Project’s commercial, retail and residential occupants, it is not realistic to hope that the garage use on the site will be eliminated. However, we urge the Proponent, the City, the Aquarium and Harbor Towers to re-examine the amount of parking included and squeeze it to the greatest extent possible because access into and out of the garage creates a significant problem for pedestrians. Any reduction in total vehicle trips into the site will reduce the Project impacts on pedestrians as well as its contributions to traffic and greenhouse gas emissions.

As currently configured and programmed, vehicle access into the garage for most of the garage users and all of the building deliveries will require the vehicles to cross the Atlantic Avenue sidewalk. Access via this garage entrance will be for all passenger vehicles for office, retail, Aquarium and public parking, and for all loading (residential, office, retail). Egress across the sidewalk will serve all loading (residential, office, retail). As shown on the plans in the PNF, the driveway serving the garage entryway looks almost as wide as Milk Street.

According to the PNF (Table 2-7), during the morning peak hour there will be 292 vehicle trips turning across the Atlantic Avenue sidewalk – or about 5 vehicles/minute. The pedestrian data provided in Figure 2-7B indicates that under existing conditions approximately 700 pedestrians walk along Atlantic Avenue during the morning peak hour – or about 12 people/minute. The volume of vehicles turning across this busy sidewalk, without traffic signals to provide a safe time for pedestrians to walk along the sidewalk, is comparable to the right turn volumes of 238 vehicles from Seaport Boulevard onto Atlantic Avenue during the weekday PM peak hour (see Figure 2-6B), and the pedestrian volume walking along Atlantic Avenue of 738 people is also comparable. (PM pedestrian trips along Atlantic Avenue at the project site are even higher than AM trips, so a shift from garage access to garage egress would create even greater conflict.)

WalkBoston does not believe that a garage entrance into the project site that carries this volume of vehicles across the busy Atlantic Avenue sidewalk is an appropriate solution for the Project’s garage access. We strongly urge the BPDA and the Proponent to reconsider this access, and to find a garage access point that will impact far fewer pedestrians. While we understand that East India Row also serves pedestrians, it serves significantly fewer people walking and providing both access and egress to the garage from this location may be a more reasonable solution.

No specific information is provided about the number of loading trips that will enter and leave the building across the sidewalk. We request that this information be provided in the PIR, along with a description of how these trips will be managed safely for pedestrians if loading continues to be provided via Atlantic Avenue.

Pedestrian circulation around and through the development site

Pedestrian circulation around the building, on the site and through the building seems to provide attractive pedestrian routes and easy access to all the public spaces within the development. The Proponent has noted that a variety of sidewalk, accessibility and landscape improvements will be made to enhance the walking environment.

We could not find a description of whether the diagonal interior pedestrian passage through the building would be open to the public 24/7.  We ask that the Proponent describe the operating plans for this pedestrian circulation in the next filing.

Public programming to support a lively public realm and welcome a diverse set of visitors

While the document provides several sentences describing the Proponent’s intent to provide site programming worthy of this important site and significant development, very little detail is included. We ask that the following questions be addressed in the next filing.

• What will be the annual budget for programming of public activities on the site? How many years of programming will the Proponent provide?
• Will there be children’s programming to align with Aquarium? Will the Aquarium have the opportunity to provide (and be compensated) for such programming?
• How will the Proponent enliven the site during winter months?
• What low and no-cost activities will be provided?
• How will the Proponent ensure that people of all races, ethnicities and income groups feel welcome and included in both the interior and exterior spaces of the project?

Wind, shadow, and microclimate

We are pleased that developer has explicitly worked to design a building façade/skin that is intended to reduce the wind impacts of the building and we look forward to seeing the wind studies that will be provided in future filings.

A project of this scale will have unavoidable shadow impacts on the streets, sidewalks and open spaces around it and this project is no exception.

Given the hope that this project will invite many people to enjoy the waterfront, we urge the developer to look in detail at ways to create comfortable outdoor spaces that are sheltered from the existing windiness of the waterfront; are shaded in the summer; and take full advantage of the sun in colder months. We suggest that the design team look at best practices for creating human-friendly microclimates on the site. This could mean spray stations for the summer, seating with solid legs and backs and wind protection for the winter, and different orientations to take advantage of the sun at every season. We look forward to learning more about the designs in the next filings.

Coordination with existing and future waterfront resiliency efforts that will affect people walking

The development plan meets the City’s resiliency guidance for the development site itself. We ask that the developer formally commit to working with the City and with other waterfront property owners and managers to ensure that public access to the HarborWalk will be safe and attractive over the long term as sea levels rise.

Thank you for the opportunity to comment on this significant new project. WalkBoston would be pleased to answer any questions about our comments and to meet with City or development team staff.

Sincerely,

Stacey Beuttell                             Wendy Landman
Executive Director                      Senior Policy Advisor

 

 

February 4, 2020

Jeff Thielman
Chair, Arlington High School Building Committee
Arlington, MA

Dear Mr. Thielman and Arlington High School Building Committee Members:

In the most recent AHS Building Project Bulletin – February 2020, WalkBoston learned that several key site features designed to promote safer walking and biking to school have been removed from the project scope to reduce project costs. These features include:

• Elimination of the Minuteman Bikeway connector ramp
• Elimination of the east staircase and ramp connecting Massachusetts Avenue to the
athletic fields, and
• Reduction of site plantings and benches.

While we understand the need to cut costs, these specific project elements would provide students, staff, Minuteman Bikeway users, and visitors with safer, more direct connections to the new school. The site plantings and benches would enhance the overall built environment, providing needed shade and resting places for people walking. There are already so many reasons why people choose less healthy, less climate resilient means to travel to and from school. Inconvenient connections and unsafe crossings should not be among them.

Site elements often fall victim to value engineering activities because they can be perceived as extra or bonus features. However, the experience of getting to the new Arlington High School Building is as important as the educational spaces contained within it. We ask that you reconsider your decision to remove these key site elements from the Building Project, or at the very least, find alternate funding sources to ensure that they will be built.

Thank you for the opportunity to provide feedback.

Sincerely,

Stacey Beuttell, AICP
Executive Director

January 17, 2020

Director Brian Golden
BPDA
One City Hall, 9th floor
Boston, MA 02201
Attn: Aisling Kerr

Secretary Kathleen Theoharides
EOEEA
100 Cambridge Street, 9th Floor
Boston, MA 02114
Attn: EOEEA 15547, Alex Strysky

Re: Comments on 15 Necco Street, Notice of Project Change

Dear Secretary Theoharides and Director Golden:

WalkBoston twice submitted comments on the plan for a GE Headquarters on this site. Ever since our first comment letter, our chief concerns have been related to serving the needs of pedestrians needing an accessible route to the site from South Station. We believe that the project proponent and the City of Boston should work together to address this issue, as transit and walking are the primary means of access to the proposed project. We applaud the lack of parking to be provided, but are concerned that the building will not be accessible to people using a wheelchair or needing an accessible path of travel. In 2020 this is not an acceptable situation for a building in the middle of Boston and within minutes of the South Station transportation hub.

For clarity, we have excerpted portions of our earlier comment letters below.

January 20, 2017 comment letter:

Accessible Routes to the Site: Comments 8.8, 8.9, 8.10 and 8.11 asked that the Proponent work with the City and with other property owners in the neighborhood to improve the walking route from South Station to the site via Summer Street, particularly for people with disabilities who will not be able to use the stairway that connects Summer Street to the Harborwalk and then to the main entrance of this project. The response provided in the EA was, “The Proponents cannot orchestrate improvements off the Project Site.”

WalkBoston’s comments were made because along the direct route from the Proponent’s main entrance to Summer Street there is no complete or accessible sidewalk. With a projected 70% mode share of walk and transit trips (which are thus also walking trips) this issue deserves careful attention.

September 30, 2016 comment letter:

1. Off-site approaches to the Necco Street site entrance – The existing walking route from Summer Street (and thus South Station) to the boundary of the site is difficult for persons with disabilities to travel. The proponent should take the lead in ensuring that walking improvements are made to this route. This may require significant coordination with the City and with neighboring landowners, but will result in improved access for all users of the neighborhood.

• There is no curb ramp provided from Dorchester Avenue onto the Summer Street Bridge (south/GE side of the bridge). A curb ramp should be provided.
• Accessible access to GE from Summer Street will need to be provided via Melcher Street. However, the sidewalk along the south side of Melcher Street appears to have an excessive cross slope that is hazardous for persons with disabilities, and difficult for anyone pushing a stroller or pulling a suitcase. This cross slope will need to be fixed.

2. Winter weather conditions and general maintenance –

• Management and operations planning should ensure good snow clearance between the site and South Station along the Harborwalk and the sidewalks of Necco and Melcher Streets. The proponent should work with adjacent property owners and business associations to assure good access to its site under winter weather conditions.

Thank you for the opportunity to comment again on this project. We look forward to working with the proponent and the City to resolve the accessibility issues.

Sincerely,

Wendy Landman
Senior Policy Advisor

Cc        Kristen McCosh Commissioner, Boston Commission for Persons with Disabilities
Chris Osgood, Boston Chief of Streets