Category: Comment Letter

Comments on Landmark Center Expanded Environmental Notification Form – MEPA #15183

Comments on Landmark Center Expanded Environmental Notification Form – MEPA #15183

May 9, 2014

Secretary Richard Sullivan, Jr.
Executive Office of Energy and Environmental Affairs
Attn: Deidre Buckley, Director, MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114

Re: Landmark Center, Boston MA
Expanded Environmental Notification Form – MEPA 15183

Dear Secretary Sullivan:

The Landmark Center, formerly the Sears Warehouse and Distribution Center, occupies an 8.8 acre site in the Fenway. It is a major city landmark and retail center that is at the heart of a burgeoning residential district. This proposed development will intensify the use of the site, making it more of a transit-oriented development, and includes 600 housing units, additional retail and new office spaces. The residential units will be housed in a high-rise building of some 12-13 stories immediately adjacent to the Fenway MBTA station. There will be 110,000 sf of new retail space, including a new Wegman’s Supermarket. Office space, already the single largest use in the building, at 635,000 SF, will be only slightly increased.

Many of the design features of this proposal will benefit pedestrians. Surface parking is replaced by about 1.3 acres of open space, setting off the historic Sears Building and including generous pedestrian walking and sitting accommodations. A new public green at the corner of Park Drive and Brookline Avenue is located where the heaviest pedestrian traffic crosses the street. The existing surface parking and the existing parking garage will be removed. A new underground garage will replace the existing 1500 parking spaces.

The proposed design is organized around pedestrian access. The existing internal circulation in the old Sears Building will be augmented by new pedestrian facilities connecting the Wegman’s market facing Fullerton Street on the east side of the property with retail facilities that face Park Drive on the west. A new pedestrian connection will be made via a walking route that passes through the building connecting the MBTA station on the north side of the site and Brookline Avenue on the south.

To build on these excellent elements of the proposal, we suggest that the proponent also consider the following possibilities:

1. Rationalize the odd combination of parallel streets on the east side of the site. 

Both Fullerton and Minor Streets, directly parallel and adjacent to each other, abut the site on the east side. At present, pedestrians may be only slightly affected by this oddity, largely because both streets are narrow and carry little traffic. However, under the proposed design Fullerton Street is being laid out as the major access route for all trucks and service vehicles and a major entrance into the underground parking garage. Fullerton Street is also called out as a pedestrian connection to the Fenway Multi-Use Path on the north side of the site, and carries large volumes of pedestrians before and after Red Sox games when the garage is in heavy use. Pedestrian safety on Fullerton Street may become an issue, depending on traffic volumes using the street for site access.

2. More clearly define and design the proposed use of the pedestrian areas.
The spacious new open space on the Park Drive side of the site is only vaguely outlined in the EENF. It replaces a large parking area, and will provide a substantial improvement in safety and amenity for pedestrians walking between the MBTA station and both the project and Brookline Avenue. To make this a successful outdoor space that functions as more than a passage around the buildings consideration should be given to sitting, eating, strolling and potential assembly areas. Design of each of the spaces might take into account the need for some protection from the elements (sunlight included). Major features of interest such as a fountain, a sidewalk café, or a sculpture or other visual displays might be added.

3. Work with the City to complete the portion of the Fenway Multi-Use Path that is adjacent to the property
This project and the air rights project (Parcel 7) at Kenmore both include segments of the proposed path that connects the Riverway and Kenmore Square. The proponent has made construction of the path contingent on the City obtaining necessary approvals, and we urge
the proponent to work closely with the City to accomplish that goal, and to work with the City to clarify a list of needed approvals and explain how they will obtained. We also suggest that the proponent explore the possible use of the space for Red Sox related displays, photos, sculptures, artifacts since it is a potentially essential walking route for fans moving between the Fenway MBTA station and Fenway Park. The proponent should also work with the City to provide wayfinding signs along the path.

4. Clarify responsibility for building the Fenway Multi-Use Path connection to the Emerald Necklace.
In addition to the portion of the path that is adjacent to the property (described above), there is an additional relatively short section of the Path between the Riverway and the project site that is extremely important. Under existing conditions, some Fenway Station patrons must cross Park Drive at grade, in a location directly above the station that does not even have a crosswalk. Driver’s sight lines of pedestrians are compromised due to the ‘hump’ of the bridge as it crosses over the Green Line. The completion of the Fenway Multi-Use Path under the Park Drive viaduct, directly adjacent to the Green Line tracks, would allow station patrons and other pedestrians to make this connection more safely and conveniently. This connection is important to the success of the site as a transit oriented development and the proponent should take a positive and active role in its construction. We urge the proponent to work with the MBTA and commit to constructing this important pedestrian facility. It would also be helpful if the pedestrian access that will be adjacent to the station could provide access to St. Mary’s Street to improve safety for riders coming to the station from northwest of the point where Park Drive crosses Fenway Station.

Thank you for the opportunity to provide comments on this significant project.

Sincerely,

Robert Sloane
Senior Planner

Bridge Project Management, Project File No. 606475 (Allston / I-90 Massachusetts Turnpike Interchange Improvement Project)

Bridge Project Management, Project File No. 606475 (Allston / I-90 Massachusetts Turnpike Interchange Improvement Project)

April 24, 2014

Patricia Leavenworth, P.E., Chief Engineer
MassDOT
10 Park Plaza
Boston, MA 02116

ATTN: Bridge Project Management, Project File No. 606475
Delivery via email to dot.feedback.highway@state.ma.us

Dear Ms. Leavenworth,

WalkBoston is pleased to provide comments on the Allston I-90, Massachusetts Turnpike Interchange Improvement Project and the April 10, 2014 public meeting. We are also pleased to have been invited to participate in the project advisory group.

We write to note the issues that we hope will be addressed by the project, some of them to be included in long-range planning and others to be included in project design – but all of them will contribute to the successful reclamation of a large and important piece of the City that has for too long been disregarded as a part of the surrounding community.

1. Project scope – The scope of the project needs to extend far enough along the Turnpike to look at bigger picture auto circulation, including access between the Longwood Medical Area, the Fenway, Back Bay and the Turnpike and relief of traffic at the Bowker Overpass and on Storrow Drive. Addressing these major vehicular demands will potentially provide significant opportunities to enhance the regionally important open space, walking, running and bicycling assets along the Charles River.

2. Pedestrian access throughout the project – Scoping of the project should include guidelines for designs to facilitate pedestrian travel through the project and into surrounding neighborhoods.

3. Air rights development – Intensive use of the air rights above the rail yards and the Turnpike can be foreseen as part of any long-range plan. Ramps and access roads, the mainline of the Turnpike and the commuter rail yards should be designed to accommodate development of the air rights.

4. Land uses in the newly available land – The needs of the community and adjacent institutions should guide development, rather than the needs of traffic to and from the Turnpike. Traffic needs should not limit the explorations of the potential uses of the land.

5. Affordable housing for residents of Allston – Housing goals should be outlined early to permit inclusion in all aspects of the study.

6. Minimize the impacts of regional traffic on neighborhood streets – The alignment and connections of turnpike on and off-ramps should be designed to minimize cut through traffic and to protect the integrity of residential areas.

7. Rail Yards – The design for reconstruction of the rail yards should minimize the number of required tracks (possibly looking at other locations to provide some of the necessary rail yards) and provide footprints for the supporting columns that enable air rights development above them.

8. Commuter rail station – The design of a new West Station should be advanced to a point where its location and likely dimensions are known, to allow for planning its access to proceed as part of this project. Station access should be provided for both sides of the rail tracks between North Allston and Commonwealth Avenue.

9. Reconnecting Packard’s Corner area and North Allston – An impenetrable wall of rail tracks and the Turnpike will separate the two parts of this neighborhood forever, unless provision for crossing is planned from the beginning, either with air rights or with bridges, or both.

10. Transit access – Bus, commuter rail and other modes of public transportation should be considered as part of the overall design at a very early date.

11. Turnpike main line – The lanes in the new portion of the Turnpike between Agganis Way and Cambridge St. should be separated sufficiently to allow for the construction of supporting columns for new uses on air rights above the Turnpike.

12. Turnpike access ramps – Access ramps should be designed in spare and efficient ways that afford the maximum use of the land for non-transportation purposes. Short tunnels should not be excluded from consideration.

13. Storrow Drive Alignment – A long-range plan for the area should include relocation of a portion of Soldiers Field Road away from the river. All access to and from the Turnpike and Cambridge Street should take this into consideration and not preclude potential options for connections.

14. A new park along the river – Relocation of Storrow Drive away from the river allows expansion of the adjacent parkland, which is now very narrow and constrained.

15. Connecting the area with the Charles River – Alternatives should be examined for connections between development in this area and the river for both pedestrians and bicycles.

Thank you for the opportunity to provide input to the project.

Best regards,

Wendy Landman
Executive Director

Bob Sloane
Senior Project Manager

Comments on Plans for the Connect Historic Boston project

Comments on Plans for the Connect Historic Boston project

March 12, 2014

William R. Egan, PE
Chief Civil Engineer
Boston Department of Public Works
Boston City Hall, Room 714
Boston MA 02201

RE: Comments on the current plans for the Connect Historic Boston project

Dear Mr. Egan:

WalkBoston has reviewed the most recent plans for the four projects within the Connect Historic Boston program – Commercial Street, Union Street (and the Blackstone Block), Joy Street and Causeway Street). We offer the comments below.

Commercial Street
Of the four projects, we feel that this project does not seriously affect walkers. The Commercial Street project has been carefully designed to incorporate cycle tracks into the existing street layout without affecting pedestrian access or sidewalk availability. We note that the current design provides visual and physical separation between bicycles and pedestrians along the new cycle track/sidewalk proposed on the harbor side of Commercial Street.

Union Street/Blackstone Block
The proposed improvements on Union Street appear excessively vehicle oriented. The proposed sidewalk along the Blackstone Block side of Union Street is intended to encourage pedestrianism and sidewalk cafes, but does not appear to have enough space to accomplish both goals. Thus pedestrians will be walking in the raised street with vehicles. This suggests the need for a very low speed limit on this block (5-10 mph).

The space being devoted to parking could be incorporated into the raised and combined street/sidewalk and used only by pedestrians. Movement by vehicles would not be impeded by enlarging the area intended for pedestrians. One lane should be sufficient for the vehicles that would use this street in the future, and would serve emergency vehicles, and not general traffic. Loading for adjacent businesses might be accommodated in a time-based method, such as that used in the Downtown Crossing shared streets – Washington, Winter and Summer.

The sharing of Union Street between vehicles and pedestrians should be reflected in signage. The shared street area should be signed as a ‘Shared Street” at the entrance to the street with a speed limit of 5-10 mph. Drivers are not being deprived of movement through the area, because they have an alternative parallel street – Congress Street – which is very close. The speed limit should also reflect that this area, bounded by historic buildings and a park, is a prime tourist district, where walkers may not be aware that vehicles are likely to be alongside as they walk from the park to Union Street businesses.

Joy Street
Joy Street is also to become a shared street, with the street raised to sidewalk level. Streetsharing by vehicles and pedestrians requires appropriate signage at the entrance to this street, such as a ‘Shared Street” sign with an accompanying speed limit of 5-10 mph. This is especially important in this densely settled residential area, where Joy Street is often used as a vehicular cut-through street from Beacon Street to Cambridge Street.

Causeway Street
Raised street crossings for pedestrians at the intersections of Canal and Haverhill Streets had long been a part of the planning. We think that their removal is a serious mistake for pedestrian safety. Thus, we offer other suggestions that might be incorporated into the plan to improve safety for walkers. These include:

  •  A right turn lane at Canal and Causeway Streets
    The potential for drivers leaving Canal Street northbound and turning left onto Canal Street appears difficult to resolve. To avoid this issue, 3” bumps in the center of the Intersection of Canal and Causeway have been proposed. We feel these bumps are potential tripping hazards for the walkers who will surge across this intersection during morning and evening commuter rail commuting times and before and after major events at the TD Garden. In large groups of people, many will simply not see the bumps and may fall on encountering them.

Another way to prevent left turns is to change the street geometry. A very tight, single lane right turn lane could be provided to direct northbound traffic onto Causeway Street. A bulbout on the west side of the Canal Street intersection where it meets the sidewalk could divert all vehicles to the right, and could include a rollover curb to permit fire engines to make the left turn in emergencies.

 

  •  Level crossing on sidewalks on each of the side streets
    All of the side street pedestrian crossings along Causeway should be raised to sidewalk level at the entrance to intersections. This would help to reduce speeds and assist in warning drivers to make only safe and permitted movements. A level crossing could be combined with the right turn lane suggested for the Canal Street crossing.

 

  • Canal Street intersection striped from corner to corner
    The volume of pedestrians crossing the Canal Street intersection is one of the largest in the city. Surge traffic from commuters and the attendees of TD Garden events suggests that the intersection needs significant protection for pedestrians. We urge the painting of the entire intersection (curb-to-curb in both directions) to indicate that pedestrians may cross safely anywhere within the intersection. Within this ultra-wide zebra crossing, a modification could be made by painting with a different color the route of the cycle track within the intersection.

 

  • Elimination of right turn on red at all Causeway Street intersections
    It is appropriate to have vehicular traffic in all directions stopped to permit walkers to cross safely and to prohibit any kinds of turning movements that might infringe on walking movements. For example, at Canal Street, forbidding right turns during pedestrian crossing cycles would help protect walkers.

 

  • Wider crosswalk between T station entrances on Haverhill Street
    The crosswalks on Causeway Street at Haverhill Street connect directly on both ends to subway access points. This crosswalk has the potential of attracting numerous pedestrians. The crosswalks should be enlarged beyond the standard widths to accommodate surge flows. • Cobble warnings Cobbles or other rough paving should be placed on the approaches to both the Canal Street intersection and the Haverhill Street intersection to warn drivers of pedestrian concentrations ahead. The cobble warnings should be supplemented with signs indicating that pedestrian crossings are ahead.

 

  • 20 mph speed zone
    The frontage along Causeway Street is about to become even more intensely used than at present. In addition to the rail commuters and event attendees, a very large development with millions of square feet and many new residents and workers is to be placed between the Garden and the front of the property. This intensely developed area will increase the pedestrian concentration at all intersections, but principally at the Canal Street crossing. Because of the many modes of transportation and the concentration of pedestrians at this location, the speed limit should be made a cautious 20 mph on Causeway Street for the safety of all.

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

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

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

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

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

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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